In Tech. Consumer Prods. v. Lighting Sci. Grp. Corp., the Federal Circuit ruled that the PTAB incorrectly upheld part of a Lighting Science Group Corp. ("LSG") LED patent, finding that the PTAB decision was based on misinterpretation of the claim language and misunderstanding of case law.
The PTAB found that a reference cited by IPR petitioner (Technical Consumer Products, Inc.) did not disclose the claimed height-to-diameter ratio, concluding instead that two heat dissipation elements in the reference together mapped to the claimed "heat sink," and the height-to-diameter ratio was not anticipated if both elements were considered in the calculation.
On appeal, the Federal Circuit found the PTAB ruling contradicted the plain claim language, which only required one particular heat dissipation element in the calculation. The Court further found the PTAB's claim construction lacked support in the specification and the prosecution history. LSG argued that the reference lacked enablement without both heat dissipation elements. The Court explained that whether a reference is enabling is a separate inquiry from whether it anticipates. Analyzed under the proper claim construction, the reference did not require removing any heat dissipation element to anticipate. The Court also noted that the PTAB reached a nearly opposite result assessing the same reference in a related IPR.
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