Short Summary
The PTAB denied Motorola Solutions' request for rehearing of the Director Review Decision that vacated the institution of four IPRs, including the challenge to Stellar's patent 9,485,471. The Board held the rescission of the 2022 Interim Procedure Memo was not retroactively applicable and the petitioner offered no new substantive evidence.
Detailed Summary
In a decision dated May 23, 2025, the PTAB denied Motorola Solutions' request for rehearing of the Director Review Decision that had vacated the Board's institution decisions in four inter partes review proceedings, including IPR2024-01206 concerning Stellar's patent 9,485,471. Motorola argued that the USPTO improperly applied the rescission of the 2022 Interim Procedure Memo retroactively, violating the Administrative Procedure Act and due process. The Board referenced the March 2025 Memo, which clarified that the rescission only affects cases without a final institution decision, and found that the Director Review was still pending, rendering the rescission inapplicable. Additionally, the Board noted that Motorola failed to identify specific errors in the weighting of the Fintiv factors and that the new evidence cited did not meet the standard for rehearing. Consequently, the rehearing request was denied.
Practitioner Note
This case demonstrates the evidentiary and procedural standards applied in patent matters before local courts. Understanding the court's reasoning in MOTOROLA SOLUTIONS, INC. et al. vs Stellar, LLC is valuable context for structuring arguments or assessing risk in similar proceedings.
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