Judge Profile

Michael A. Valek

41 IP cases indexed. Covers patent matters.

Cases Presided Over

41 cases indexed | Page 1 of 2

patent all challenged claims upheld

Tempus AI, Inc. v.Guardant Health Inc.

· IPR2025-01435

The PTAB affirmed Guardant Health’s patent on cfDNA tagging methods, finding none of the 29 challenged claims unpatentable after rejecting Tempus AI’s obviousness arguments.

patent final

Samsung Electronics Co., Ltd. et al. v.Oura Health Oy et al.

· IPR2024-00928

The PTAB found that several claims related to finger-worn monitoring devices were unpatentable over prior art combinations. The Board adopted a narrow claim construction for 'substantially transparent external potting,' which aided the Petitioner's argument of obviousness.

patent final

Samsung Electronics Co., Ltd. et al. v.Oura Health Oy et al.

· IPR2024-01077

The PTAB issued a Final Written Decision rejecting all grounds of obviousness (35 U.S.C. § 103) against the smart ring patent. The Board upheld the validity of the claims, finding that the combination of prior art references required non-obvious structural overhauls and lacked proper nexus to the claimed invention.

patent final

Samsung Electronics Co., Ltd. et al. v.Oura Health Oy et al.

· IPR2024-01078

The Board upheld the validity of Oura Health's smart ring patent against Samsung Electronics in a Final Written Decision. The Panel found that the Petitioner failed to demonstrate obviousness over prior art combining physical activity monitoring and wearable input devices.

patent final

Axion Biosystems, Inc. v.Agilent Technologies, Inc.

· IPR2024-01467

The PTAB issued a final decision finding the challenged claims unpatentable over Xu-752 and Jones. The Board concluded that the Petitioner failed to demonstrate non-hindsight motivation for combining the references or making the necessary technical modifications, citing lack of support for millisecond time resolution.

patent final

PreOmics GmbH et al. v.The Brigham and Women’s Hospital, Inc.

· IPR2024-01473

The Board found that six claims (1, 4, 6, 17, 22, and 25) of the patent were unpatentable based on anticipation by prior art Cai. The decision hinged on a broad interpretation of key terms like 'biological sample' and 'subset of particles,' which favored the Petitioner's arguments regarding the scope of the claims.

patent mixed - some claims cancelled, some upheld

Samsung Electronics Co., Ltd. et al. v.Oura Health Oy et al.

· PGR2024-00030

Samsung Electronics challenged Oura Health's patent claims in a PGR proceeding, arguing obviousness and anticipation. The PTAB found the vast majority of the grounds unpersuasive, but ultimately cancelled two dependent claims (17 and 18) under § 112(d).

patent instituted

TikTok Inc. et al. v.Cellspin Soft, Inc.

· IPR2024-00767

TikTok Inc.'s challenge to Cellspin Soft's patent was instituted by the PTAB, finding a reasonable likelihood that at least one challenged claim is unpatentable. The Board focused on obviousness (35 U.S.C. § 103) over prior art references including Hiroishi, Kahn, and Bluetooth specifications. This decision sets up trial proceedings to determine if the combination of existing technologies renders the patent claims invalid.

patent instituted

TikTok Inc. et al. v.Cellspin Soft, Inc.

· IPR2024-00768

TikTok Inc. successfully navigated the institution phase of an IPR against Cellspin Soft, Inc., leading to a decision that reasonable likelihood of unpatentability was established for claims 1-10 over Singh129 and Singh906. The Board found that Petitioner adequately demonstrated material error in prior art consideration during prosecution regarding Ground 2.

patent instituted

TikTok Inc. et al. v.Cellspin Soft, Inc.

· IPR2024-00769

TikTok and its affiliates successfully petitioned for institution in an IPR against Cellspin Soft regarding wireless communication patents. The Board found a reasonable likelihood of unpatentability based on obviousness over multiple prior art references, including Singh129/Singh906 and Kahn/Bluetooth.

patent instituted

TikTok Inc. et al. v.Cellspin Soft, Inc.

· IPR2024-00770

TikTok Inc. successfully convinced the PTAB to institute IPR proceedings against Cellspin Soft, Inc.'s patent covering Bluetooth data transfer and content publishing. The Board found sufficient evidence that the claims are obvious over various combinations of prior art references.

patent instituted

Samsung Electronics Co., Ltd. et al. v.Oura Health Oy et al.

· IPR2024-00928

The PTAB granted institution of IPR for Samsung against Oura Health regarding the 'Wearable Computing Device' patent (9582034). The Board found a reasonable likelihood that Samsung would prevail on grounds of obviousness over LeBoeuf.

patent denied

Samsung Electronics Co., Ltd. et al. v.Oura Health Oy et al.

· IPR2024-00929

The PTAB denied institution of an IPR filed by Samsung against Oura Health because the patent owner had formally disclaimed all 12 challenged claims.

patent denied

Samsung Electronics Co., Ltd. et al. v.Oura Health Oy et al.

· IPR2024-00930

The PTAB denied Samsung's IPR petition against Oura Health because the patent owner had statutorily disclaimed all challenged claims.

patent instituted

Samsung Electronics Co., Ltd. et al. v.Oura Health Oy et al.

· IPR2024-01077

Samsung Electronics successfully pushed through the institution phase of its IPR challenge against Oura Health's '859 Patent. The Board found that the second challenge, based on prior art including Schröder and Mestas, met the threshold for obviousness (103).

patent denied

Samsung Electronics Co., Ltd. et al. v.Oura Health Oy et al.

· IPR2024-01079

The PTAB denied an IPR petition filed by Samsung against Oura Health because the patent owner had disclaimed all challenged claims. This denial was based on procedural rules regarding pre-institution claim disclaimer.

patent denied

Samsung Electronics Co., Ltd. et al. v.Oura Health Oy et al.

· IPR2024-01080

The PTAB denied an IPR petition filed by Samsung against Oura Health because the patent owner had disclaimed all challenged claims.

patent instituted

Samsung Electronics Co., Ltd. et al. v.Oura Health Oy et al.

· IPR2024-01078

The PTAB granted institution for a high-stakes IPR concerning wearable biosensor technology, specifically smart rings. The Board found sufficient evidence of obviousness (103) and anticipation (102) to proceed with trial on 17 claims.

patent instituted

Axion Biosystems, Inc. v.Agilent Technologies, Inc.

· IPR2024-01467

Axion Biosystems successfully navigated the Institution Decision phase in its IPR against Agilent Technologies, leading to the trial of key claims. The Board declined to deny institution, allowing the dispute over cell monitoring and impedance analysis technology to proceed to litigation.

patent instituted

PreOmics GmbH et al. v.The Brigham and Women’s Hospital, Inc.

· IPR2024-01473

PreOmics GmbH et al. successfully petitioned for institution in the IPR against The Brigham and Women’s Hospital, Inc., challenging claims related to sensor arrays for protein corona analysis. The Board found a reasonable likelihood of unpatentability based on grounds of anticipation (102) and obviousness (103).

patent denied

Cipla Limited v.Gilead Sciences, Inc.

· IPR2025-00033

The PTAB denied Cipla Limited's IPR petition against Gilead Sciences regarding patent 11,744,802, citing the advanced stage of parallel district court litigation and lack of compelling merits.

patent denied

Arthrex, Inc. et al. v.Medshape, Inc.

· IPR2025-00053

The PTAB denied Arthrex's IPR petition against Medshape's patent (7985222), citing the complex and overlapping nature of co-pending district court litigation.

patent instituted

LifeScan, Inc. et al. v.Cellspin Soft, Inc.

· IPR2025-00102

The PTAB granted institution for an IPR challenge against Cellspin Soft's patent (11234121), asserting obviousness over multiple prior art references. Petitioners, including LifeScan and Senseonics, successfully argued that the claims were rendered obvious by combinations of existing wireless technology standards and academic publications.

patent instituted

LifeScan, Inc. et al. v.Cellspin Soft, Inc.

· IPR2025-00103

LifeScan and co-petitioners successfully convinced the PTAB to institute trial on all 15 claims of patent 9900766 against Cellspin Soft, Inc. The Board found sufficient evidence that the claimed multimedia content distribution methods were obvious over various combinations of prior art references, including Singh906, Kahn, and Bluetooth specifications.

patent instituted

LifeScan, Inc. et al. v.Cellspin Soft, Inc.

· IPR2025-00104

LifeScan successfully petitioned the PTAB to institute an IPR against Cellspin Soft's patent, asserting that the claimed wireless data transmission methods are obvious over various combinations of prior art. The Board found a reasonable likelihood of prevailing on multiple grounds, moving the dispute into active review proceedings.

patent denied

Samsung Bioepis Co., Ltd. v.Regeneron Pharmaceuticals, Inc.

· IPR2025-00176

Samsung Bioepis sought to invalidate numerous claims of Regeneron Pharmaceuticals' ophthalmic formulations using grounds of obviousness (103). The PTAB denied institution based on a holistic Fintiv analysis, citing significant overlap with ongoing district court and MDL proceedings.

patent instituted

Merck Sharp & Dohme LLC v.Halozyme, Inc. et al.

· PGR2025-00024

Merck Sharp & Dohme LLC successfully challenged Halozyme, Inc.'s '590 patent on grounds of enablement and obviousness. The PTAB found the claims were overly broad regarding polypeptide scope, requiring undue experimentation for a skilled artisan.

patent instituted

Merck Sharp & Dohme LLC v.Halozyme, Inc. et al.

· PGR2025-00030

Merck Sharp & Dohme LLC successfully petitioned for institution in a PGR proceeding against Halozyme, Inc., challenging the '758 patent on grounds of enablement and obviousness. The Board adopted a broad claim construction for 'modified PH20 polypeptide,' which significantly broadened the scope of the challenged claims.

patent instituted

Merck Sharp & Dohme LLC v.Halozyme, Inc. et al.

· PGR2025-00033

Merck Sharp & Dohme LLC successfully challenged Halozyme, Inc.'s patent claims on grounds of enablement and obviousness. The Board ruled that the claimed modified polypeptides must exhibit hyaluronidase activity, narrowing the scope of the genus. This decision sets a precedent for interpreting functional limitations in polypeptide patents.

patent instituted

Merck Sharp & Dohme LLC v.Halozyme, Inc. et al.

· PGR2025-00039

Merck Sharp & Dohme successfully challenged Halozyme's patent claims in a PGR proceeding, focusing on enablement and obviousness. The Board adopted a functional claim construction requiring 'modified PH20 polypeptide' to exhibit hyaluronidase activity.

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