Google LLC v. Parus Holdings, Inc.
Patent Trial and Appeal Board
Holding
The Federal Circuit held that the Board erred by analyzing Burrows in isolation rather than the asserted obviousness combinations, adopted a construction of “unexpected response” without giving Google adequate APA notice and opportunity to respond, and failed to address Google’s inconsistency argument based on related IPR decisions. The court vacated and remanded.
Why It Matters
The decision reinforces that the PTAB must evaluate the petitioner’s actual combination theory, give notice before relying on a new claim construction, and explain apparently inconsistent treatment of related IPR records.
Full Summary
Key Points
- The challenged claims cover a voice-browsing system that ranks websites and adjusts rankings based on polling results, including no response, unexpected response, and relative response time.
- For both Kovatch-Burrows and Wise-Burrows, the Federal Circuit found the Board improperly focused on whether Burrows alone disclosed the ranking limitations instead of whether Burrows would have motivated modifications to Kovatch or Wise.
- The Board effectively construed “unexpected response” to exclude changed webpages by relying on the specification and extrinsic evidence, but the parties had not litigated that term as a claim-construction issue.
- For the Wise-Burrows ground, the Board also failed to address Google’s argument that rejecting unpatentability conflicted with earlier PTAB findings in related IPRs involving the ’941 and ’402 patents.
- The Federal Circuit did not decide obviousness; it remanded for the Board to reconsider the asserted combinations and, if necessary, explain any different treatment of the related IPR decisions.
How this summary was made: Drafted with AI from the court's opinion or order. Read the document itself before relying on the summary. Editorial policy
New to Patent prosecution? See our Patent prosecution page
- Fed. Cir. · Oct. 19, 2026Google LLC v. Valtrus Innovations Ltd.
- PTAB Director Review · Oct. 19, 2026Tesla, Inc. v. Intellectual Ventures II
- ITC · Oct. 16, 2026Certain Storage Containers and Toolboxes, Organizers, Component Boxes, Coolers, and Accessories Used Therewith; Inv. No. 337-TA-1409 (Violation)
- Fed. Cir. · Oct. 14, 2026Syngenta Crop Protection AG v. UPL Ltd.
- Fed. Cir. · Oct. 1, 2026In re Satius Holding, Inc.
