Amsted Rail Company, Inc. v. Squires

Amsted Rail Company, Inc. v. Squires The Federal Circuit held that the Board did not err in construing claim 1 to impose no required order between sensing/measuring accelerations and filtering them. Substantial evidence supported the Board's obviousness findings for both the challenged claims and the proposed substitute claims. The decision reinforces that dependent claims can strongly undercut a proposed sequencing limitation and that substantial-evidence review gives the Board meaningful latitude on motivation-to-combine and motion-to-amend obviousness findings. Affirmed. The court affirmed the Board's construction of claim 1, rejecting Amsted's argument that accelerations had to be sensed or measured before filtering. Dependent claim 23 supported the Board's reading because it recited filters removing undesirable accelerations before they reach the acceleration sensors. Substantial evidence supported the motivation to combine Armitage with Barone based on applying Barone's unwanted-data filtering principle to improve Armitage's data processing. For claim 25, the court upheld the Board's finding that a skilled artisan would have implemented Barone's filtering principle as a software filter executed on Armitage's firmware, despite Barone's analog disclosure. The court also affirmed denial of the motion to amend because substantial evidence supported the Board's findings that Armitage's 3-D accelerometer and routine duplication of filters and detectors rendered the substitute claims obvious. § 103 claim construction non-precedential § 103 claim construction non-precedential § 103 claim construction