Apple Inc. v. Smart Mobile Technologies LLC

Apple Inc. v. Smart Mobile Technologies LLC The Federal Circuit affirmed the Board's construction of "multiplexing signals" as "combining multiple signal streams into one." Applying that construction, substantial evidence supported the Board's finding that Apple failed to prove the asserted prior art disclosed the limitation, so Apple did not establish obviousness. The decision reinforces that a narrowing construction of a preamble term can be dispositive in an IPR obviousness challenge where the asserted art shows switching or multiple paths but not combining signal streams. Affirmed. The challenged independent claim recited an IP-enabled communication device for "multiplexing signals" with multiple wireless communication units and network paths. The Board expressly construed "multiplexing signals" to mean "combining multiple signal streams into one," rejecting Apple's broader construction that would encompass switching. The Federal Circuit adopted the same construction, relying on its companion decision issued the same day involving related Smart Mobile patents with a common specification. Substantial evidence supported the Board's finding that Yegoshin and Bernard, alone or in combination, did not disclose "multiplexing signals" under that construction. Because Apple failed to prove the disputed limitation in the prior art, the court affirmed the Board's decision that claims 1-3 and 5 were not shown unpatentable for obviousness. § 103 claim construction non-precedential § 103 claim construction non-precedential § 103 claim construction non-precedential