In Tech. Consumer Prods. v. Lighting Sci.
The PTAB found that a reference cited by IPR petitioner (
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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