The U.S. Court of Appeals for the Federal Circuit affirmed a Patent Trial and Appeal Board decision favoring Google LLC in a patent dispute with IPA Technologies Inc., issuing a brief judgment on January 14, 2026, that provides no detailed reasoning for the court's decision.
The Federal Circuit issued a summary affirmance under Rule 36, which allows the court to affirm lower tribunal decisions without a written opinion when the court determines that a written opinion would have no precedential value. The three-judge panel consisting of Chief Judge Kimberly Moore and Circuit Judges Timothy Dyk and Raymond Taranto disposed of the case with a single-page order stating simply "AFFIRMED."
The case stems from two inter partes review proceedings filed with the Patent Trial and Appeal Board in 2019, designated as IPR2019-00728 and IPR2019-00731. Inter partes review is a trial proceeding conducted at the PTAB to review the patentability of one or more claims in a patent only on grounds that could be raised under sections 102 or 103 of the Patent Act, which address novelty and obviousness requirements.
IPA Technologies Inc. served as the appellant in the Federal Circuit proceedings, represented by a legal team from Skiermont Derby LLP including Steven Wayne Hartsell, who argued the case, along with Jaime Olin and Paul Skiermont from the Dallas office, and Mieke K. Malmberg from Los Angeles. Google LLC, as the appellee, was represented by attorneys from Paul Hastings LLP, with Daniel Zeilberger arguing the case and support from Naveen Modi, Joseph Palys, and Vladimir J. Semendyai from the Washington, D.C. office.
The Federal Circuit noted explicitly that the disposition is nonprecedential, meaning the decision cannot be cited as binding authority in future cases. This designation is significant because it limits the ruling's impact on patent law jurisprudence and indicates the court viewed the issues as routine applications of established legal principles rather than novel questions requiring detailed analysis.
Rule 36 affirmances have become increasingly common at the Federal Circuit as a means of managing caseload while disposing of appeals that do not present complex legal issues or require extensive written explanation. The rule permits the court to enter judgment without opinion when the court determines that none of the issues presented warrant discussion in a written opinion and the judgment of the lower tribunal should be affirmed.
The underlying PTAB proceedings likely involved challenges to the validity of patents held by IPA Technologies, with Google seeking to invalidate patent claims through the inter partes review process. The PTAB, which was established as part of the America Invents Act reforms in 2012, provides an alternative to federal district court litigation for challenging patent validity and has become a popular forum for defendants seeking to invalidate patents asserted against them.
While the Federal Circuit's brief order provides no insight into the specific patents or technology at issue, the involvement of Google suggests the dispute likely concerned technology relevant to the company's various products and services. IPA Technologies' decision to appeal the PTAB's adverse decisions indicates the company viewed the patent claims as valuable intellectual property worth defending through appellate review.
The Federal Circuit's jurisdiction over appeals from PTAB decisions makes it the exclusive appellate forum for inter partes review outcomes, regardless of where the underlying patents might be litigated in district court proceedings. This centralized review system was designed to promote consistency in patent law application and reduce forum shopping in patent disputes.
For patent practitioners, Rule 36 affirmances present challenges in understanding the Federal Circuit's reasoning and predicting outcomes in similar cases. The lack of written explanation means parties and their attorneys cannot glean insights into how the court viewed specific arguments or evidence presented during the appeal process.
The timing of the decision, coming more than a year after the appeals were docketed in 2024, suggests the court took time to review the record and briefs before determining that affirmance without opinion was appropriate. The consolidation of two related appeal numbers indicates the cases involved related patents or common legal issues that warranted joint consideration.
This outcome represents a complete victory for Google in the patent dispute, as the Federal Circuit's affirmance leaves the PTAB's decisions undisturbed. For IPA Technologies, the ruling exhausts the appellate options within the federal court system, though the company could theoretically seek Supreme Court review through a petition for certiorari, though such petitions are rarely granted in patent cases absent significant legal conflicts between circuits or issues of national importance.
The case adds to the substantial body of PTAB decisions that have been upheld on appeal, reinforcing the validity of the post-grant review system established by the America Invents Act as an effective mechanism for challenging questionable patents outside of expensive federal court litigation.