The U.S. Court of Appeals for the Federal Circuit vacated and remanded a Patent Trial and Appeal Board decision involving Apple Inc. and Smart Mobile Technologies LLC, marking a partial victory for the tech giant in its ongoing patent challenges.
In a nonprecedential opinion filed January 13, 2026, the Federal Circuit addressed Apple's appeal of the Patent Trial and Appeal Board's final written decision regarding U.S. Patent No. 9,191,083. The Board had previously determined that Apple failed to prove by a preponderance of the evidence that the challenged patent claims were unpatentable under 35 U.S.C. § 103.
Circuit Judge Stoll, writing for the panel that included Judges Dyk and Chen, identified two primary issues with the Board's decision that warranted reversal. The court found fault with the Board's construction of the term "plurality of antennas," which required the inclusion of at least some bidirectional antennas. Additionally, the Federal Circuit determined that the Board erred by failing to address Apple's alternative arguments that were made in response to Smart Mobile Technologies' claim construction proposal submitted after the inter partes review proceedings had been instituted.
The case originated as an inter partes review challenge filed by Apple in 2022, designated as IPR2022-01002 before the Patent Trial and Appeal Board. Inter partes review is a post-grant proceeding that allows parties to challenge the validity of issued patents before the Patent and Trademark Office, providing an alternative to federal court litigation for resolving patent validity disputes.
Apple was represented by a substantial legal team from multiple firms, including lead counsel Nitika Gupta Fiorella from Fish & Richardson P.C. in Wilmington, Delaware, who argued the case before the Federal Circuit. The appellant's legal representation also included attorneys Alexander Michael Pechette from Boston, Daniel Haran Wade from New York, Debra Janece McComas from Haynes and Boone LLP in Dallas, Angela M. Oliver from Washington D.C., and Laura Vu from San Francisco.
Smart Mobile Technologies was represented by Philip Graves from Graves & Shaw LLP in Los Angeles, who argued for the appellee, alongside co-counsel Greer N. Shaw from the same firm.
The Federal Circuit's jurisdiction over this appeal stems from 28 U.S.C. § 1295(a)(4)(A), which grants the court exclusive jurisdiction over appeals from final decisions of the Patent Trial and Appeal Board. This jurisdictional provision ensures that all patent validity determinations from the USPTO's appellate body receive uniform treatment under Federal Circuit precedent.
The patent at issue, U.S. Patent No. 9,191,083, appears to relate to mobile device antenna technology, though the specific technical details of the patented invention were not fully elaborated in the available portion of the court's opinion. The dispute centered on claim construction issues, particularly the interpretation of antenna-related terminology that could significantly impact the scope of patent protection.
Claim construction represents a critical aspect of patent litigation and administrative proceedings, as the proper interpretation of patent claim language determines the scope of protection afforded to the patent holder. In this case, the Board's construction of "plurality of antennas" became a pivotal issue, with Apple challenging the requirement that this term necessarily include bidirectional antennas.
The Federal Circuit's decision to vacate and remand indicates that the case will return to the Patent Trial and Appeal Board for further proceedings consistent with the appellate court's guidance. This procedural outcome means that the validity of Smart Mobile Technologies' patent claims remains unresolved, with the Board required to reconsider its analysis in light of the Federal Circuit's identified errors.
For Apple, the vacatur represents a procedural victory that provides another opportunity to challenge the patent's validity. The company has been increasingly active in post-grant proceedings as part of its broader intellectual property strategy, using inter partes review and other USPTO proceedings to challenge patents that may pose licensing or litigation risks.
The nonprecedential nature of the Federal Circuit's opinion, as noted in the court's designation, means that while the decision resolves the immediate dispute between the parties, it does not establish binding precedent for future cases. However, the reasoning may still provide guidance for practitioners handling similar claim construction issues in patent proceedings.
This case reflects the ongoing importance of precise claim construction in patent disputes, particularly in technology sectors where antenna design and wireless communication patents play crucial roles. The Federal Circuit's attention to procedural requirements also underscores the importance of comprehensive briefing and argument development in administrative patent proceedings.
The remand to the Patent Trial and Appeal Board will require that tribunal to address Apple's alternative arguments and reconsider its claim construction methodology, potentially leading to a different outcome on the ultimate question of patent validity under the obviousness standard of 35 U.S.C. § 103.