Precedential and Key Federal Circuit Opinions
1. WONDERLAND SWITZERLAND AG v. EVENFLO COMPANY, INC. [OPINION] (2023-2043, 2023-2233, 2023-2326, 12/17/2025) (Moore, Prost, Reyna)
Moore, J. The Court reversed the district court’s judgment of infringement of the asserted ’043 patent under the doctrine of equivalents (“DOE”), rejected a pair of claim construction arguments for the asserted ’043 patent, rejected a claim construction argument and a substantial evidence challenge for the asserted ’951 patent, reversed the grant of a permanent injunction for both the ’951 and ’043 patents, and (over the dissent of Judge Reyna) reversed the denial of a new trial on willful infringement of the ’043 patent. The asserted ’043 and ’951 patents were generally “directed to car seats for children,” and Wonderland accused five of Evenflo’s convertible car seat models of infringing various claims of those patents.
The Court concluded that substantial evidence did not support the jury’s finding of infringement of the ’043 patent by Evenflo’s 4-in-1 seats under DOE. Where the “locking mechanism” limitation required the seat back to include components for selective detachability, it was “insufficient, under, DOE to argue the overall mechanism w[as] the same or that a different claim element (i.e., the seat assembly) contain[ed]” the selective detachability component. The Court also rejected a pair of Evenflo’s claim construction arguments for the ’043 patent.
With respect to the ’951 patent, the Court rejected an argument by Evenflo that controlling precedent establishes a presumption that components “connected to” one another are physically distinct and determined that the intrinsic evidence supported the district court’s construction of “connected to.” The Court also rejected Evenflo’s substantial evidence challenge for the “backrest” limitation in the ’951 patent.
The Court concluded that the district court abused its discretion in granting permanent injunctive relief for both the ’951 and ’043 patents. For the ’951 patent, “it [wa]s an abuse of discretion to grant such an extraordinary remedy whe[re] a party did not request it.” For the ’043 patent, the district court “relied solely on speculative and conclusory evidence” of irreparable harm.
In the cross-appeal, the Court reversed the district court’s denial of a new trial on willful infringement of the ’043 patent because it found that the district court abused its discretion by excluding trial evidence of Evenflo’s subjective intent under Federal Rule of Evidence 403. According to the majority, the excluded evidence included portions that were highly probative of willfulness, and “the district court should have managed any risk of prejudice and confusion through jury instructions or redactions.” The majority also concluded that “excluding … the email chain … impaired Wonderland’s substantial rights to effectively prove its case of willfulness.”
Judge Reyna dissented in part as to the Court’s reversal of the district court’s denial of a new trial on willful infringement because, in Judge Reyna’s view, the district court’s exclusion of the email chain “was neither arbitrary nor irrational but instead reflected a careful and comprehensive balancing of the weight of the evidence’s probative value against the risk of prejudice and jury confusion.” In Judge Reyna’s view, “the majority substitute[d] its judgment for that of the district court,” contrary to the law of the regional circuit (here, the Third Circuit), which “require[es] broad deference to a district court’s [Rule] 403 ruling.”
2. INTERNATIONAL BUSINESS MACHINES CORP. v. ZILLOW GROUP INC. [OPINION] (2024-1170, 2024-1274, 12/9/2025) (Taranto, Chen, Stoll)
Chen, J. In cross appeals by IBM and Zillow Group, Inc., the Court affirmed the Patent Trial and Appeal Board’s determination finding certain claims unpatentable in an inter partes review (“IPR”) proceeding and affirmed the Board’s determination finding other claims not unpatentable. The patent claims were generally directed to methods and systems that “allow[] a user to create (and, subsequently, log into) several accounts using only a single set of login credentials.”
IBM argued that the Board’s analysis of the “protected resources” limitation “relied on an obviousness theory … never advanced in [the IPR] petition,” which raised only an anticipation analysis for that limitation. The Court first rejected Zillow’s argument that the Court is barred, under 35 U.S.C. § 314(d), from reviewing IBM’s challenge, and explained that it “routinely examine[s] whether the Board’s final written decision departed from the petition.” The Court then determined that “the Board’s analysis [] tracked the petitioner’s anticipation-based theory” because the Board “determin[ed] that a skilled artisan would understand [the] prior art reference’s express teaching to disclose [the] particular claim limitation.” The Court also determined that substantial evidence supported the Board’s findings that the prior art disclosed a separate limitation.
3. In Re CAMBRIDGE INDUSTRIES USA INC. [OPINION] (2026-101, 12/9/2025) (Prost, Chen, Hughes) (per curiam) (nonprecedential)
The Court denied petitions for a writ of mandamus directing the U.S. Patent and Trademark Office (“PTO”) to reconsider its non-institution decisions in two IPR proceedings. The PTO discretionarily denied two IPR petitions based on the Patent Owner’s settled expectations because the two patents had been in force for nine and seven years. The Court explained that “mandamus is ordinarily unavailable for review of institution decisions” “[g]iven [that] Congress committed institution decisions to the [PTO] Director’s discretion … and protected exercise of that discretion from judicial review by making such determinations ‘final and nonappealable,’ 35 U.S.C. § 314(d).” Although the Court explained that it has “noted possible exceptions for ‘colorable constitutional claims’ … and certain statutory challenges,” it determined that no such claims were presented here.
4. CODA DEVELOPMENT S.R.O. v. GOODYEAR TIRE & RUBBER CO. [OPINION] (2023-1880, 12/8/2025) (Lourie, Dyk, Cunningham)
Cunningham, J. The Court affirmed the district court’s grant of judgment as a matter of law of no trade secret misappropriation and denial of Coda’s correction of inventorship claim regarding Goodyear’s patent. Both the asserted trade secrets and Goodyear’s patent related to self-inflating tire technology.
Following trial, the jury found that Goodyear had misappropriated five of Coda’s alleged trade secrets. The district court then granted Goodyear’s motion for judgment as a matter of law, concluding that each alleged trade secret was not entitled to trade secret status because each trade secret was not sufficiently definite, not secret, and/or not used or disclosed by Goodyear. The district court also denied Coda’s correction of inventorship claim.
The Court concluded that the district court correctly determined that the alleged trade secrets had been publicly disclosed, were not identified with sufficient particularity, and/or were not used by Goodyear. “Coda’s sole argument supporting reversal of the district court’s denial of correction of inventorship w[as] that the district court improperly granted judgment as a matter of law with respect to Coda’s trade secret claims.” Because the Court affirmed the district court’s judgment with respect to the trade secret claims, it also affirmed with respect to the correction of inventorship claims.
5. ADNEXUS INC. v. META PLATFORMS, INC. [OPINION] (2024-1551, 12/5/2025) (Prost, Taranto, Stark)
Stark, J. The Court vacated and remanded the district court’s dismissal of Adnexus’ Amended Complaint for patent infringement for failure to state a claim. Adnexus’ patent related generally to “a system and method of online advertising.”
The district court dismissed Adnexus’ Amended Complaint because “it failed to plausibly allege that Meta’s Lead Ads practices limitation [1f], which requires retrieval of a ‘user profile compris[ing] at least delivery method preferences’ for delivery of online ads to a user.” The Court determined that the district court erred by “implicitly construing” the “delivery method preferences” claim term against Adnexus, “without first giving [the non-moving party] Adnexus the opportunity it requested to be heard on the issue of the proper construction of this term.” Further, the Court determined that the Amended Complaint stated a plausible claim by including claim charts that expressly mapped Meta’s Lead Ads to limitation [1f].
6. SEAGEN INC. v. DAIICHI SANKYO COMPANY, LTD. [OPINION] (2023-2424, 2024-1176, 12/2/2025) (Lourie, Reyna, Chen)
Lourie, J. The Court reversed the district court’s denial of judgment as a matter of law that the asserted ’039 patent was not invalid for failure to meet the written description and enablement requirements. The case concerned a type of cancer treatment—an antibody-drug conjugate (“ADC”)—that includes a linker protein component that can further include different subcomponents including a peptide unit. Following trial, a jury found that Daiichi had not proved that the asserted ’039 patent claims were invalid for lack of written description or enablement and that Seagen had proved that Daiichi’s Enhertu® cancer drug infringed the ’039 patent. The district court denied Daichii’s motion for judgment as a matter of law.
The asserted ’039 patent claims were directed to the chemical structure of an ADC and included a “Ww” limitation corresponding to the peptide unit of the linker protein component. The “Ww” limitation required that the claimed peptide unit is a glycine (“Gly”)/phenylalanine (“Phe”)-only tetrapeptide, that is, “a four-amino-acid-long unit” (i.e., tetrapeptide) “in which each amino acid is either glycine or phenylalanine.” “[P]henylalanine can exist in either of two different stereoisomers (spatial arrangements) in addition to glycine’s one.” As a result, “there are three different options for each amino acid of the claimed Gly/Phe-only tetrapeptide.” “[T]he subgenus of peptide units claimed in the ’039 patent [thus] encompasses 81 (i.e., 34) different species.”
The ’039 patent claimed priority to a 2004 application, which “d[id] not explicitly disclose a Gly/Phe-only tetrapeptide.” As the Court explained, “[t]he 2004 application only broadly outline[d] the possible structures of the Ww peptide unit that are included in the linker protein” by stating that the linker protein may contain a peptide unit, which is “anywhere from two to twelve amino acids” and by describing 39 potential different amino acids. “When different isomers of the identified amino acids are included, there are 83 unique options for each,” meaning that “with respect to just tetrapeptides, over 47 million different tetrapeptide units (i.e., 834)” were “encompassed in the 2004 application.”
The Court explained that “a patent’s disclosure of a ‘broad genus,’ without more is inadequate to satisfy the written description requirement for claims directed to a ‘particular subgenus or species contained therein.’” Although the “81 claimed Gly/Phe-only tetrapeptides are ‘encompassed’ within these 47 million” different tetrapeptide units, the Court found that “they are merely an infinitesimal fraction of those peptide units generally included,” that “the 2004 application’s broad disclosure of effectively countless options for the peptide unit fails to show the subgenus of Gly/Phe-only tetrapeptides claimed in the ’039 patent,” and that there were “no adequate blaze marks in the 2004 application that would lead a skilled artisan to the 81-member Gly/Phe-only tetrapeptide subgenus or any species within it.” Accordingly, the Court concluded that there was not sufficient evidence for a reasonable jury to find adequate written description support for what the ’039 patent claimed.
The Court concluded that the ’039 patent also failed to “enable[] a skilled artisan to make and use the full scope of the claimed ADCs without undue experimentation.” The ’039 patent claims covered “an ADC containing any drug moiety with the recited function of cleaving in a patient.” But the Court found that the specification did not disclose “a quality common to every functional embodiment” of the patent, and it was “undisputed that ADC science was so unpredictable that a skilled artisan would need to test whether any given ADC with a given drug moiety met the functional limitation.”
