Slingshot Printing LLC v. Canon U.S.A., Inc.

Slingshot Printing LLC v. Canon U.S.A., Inc. The Federal Circuit affirmed the Board’s construction of “physically separated proximal to the bondpad” as measured relative to the end of the trace, not the heater arrays. Substantial evidence supported the Board’s obviousness findings, including its reliance on prior-art figures, related references, and expert testimony to identify bondpad location and trace separation. The decision reinforces that the PTAB may use a common-sense visual reading of patent drawings for relative positioning, so long as it is not extracting precise dimensions from non-scale figures. Affirmed. No costs. The challenged claims concerned a reduced-bondpad heater chip for printing devices; dependent claims 3 and 9 required power traces “physically separated proximal to the bondpad.” The court agreed with the Board that proximity was measured along the trace relative to the bondpad and the end of the trace, because neither the claims nor specification required comparison to heater arrays. For obviousness, the Board relied on Benjamin144, Benjamin703, Childers, and expert testimony; the Federal Circuit found substantial evidence for the finding that a skilled artisan would locate the bondpad at the edge of the heater chip. The court rejected Slingshot’s argument that the Board improperly relied on a not-to-scale figure, distinguishing impermissible extraction of precise dimensions from permissible visual assessment of general relative distances. The nonprecedential opinion affirmed the Board’s § 103 determination for all challenged claims. § 103 claim construction non-precedential § 103 claim construction non-precedential § 103 claim construction non-precedential