The court vacated and remanded the decision of the Board of Patent Appeals and Interferences in an ex parte reexamination affirming the rejection of claims as being anticipated. In a co-pending litigation involving the same patent, the district court agreed with the patentee Power Integrations that the claim term “coupled” merely required that two circuits be connected in a manner “such that voltage, current, or control signals pass from one to another” but there was no requirement of a direct connection and the use of intermediate circuit elements was not precluded. The Board came up with its own construction of “coupled” as to “join[] devices into a single circuit,” and, in so construing the term, failed to acknowledge the district court’s claim construction or to assess whether its interpretation of the term “coupled” was consistent with the broadest reasonable construction of the term. While the Board focused on the issue of whether “coupled” precluded the presence of intervening components, it failed to adequately evaluate Power Integrations’ contention regarding “coupled” with respect to whether the “counter” itself, rather than the counter and memory together, drove the converter to perform certain functions. Thus, because the board’s opinion provided the court with an inadequate predicate upon which to evaluate its decision to reject the claims as anticipated, the court vacated and remanded to the Board. The court made clear, however, that it was not holding that the board must in all cases assess a previous judicial interpretation of a disputed claim term.
Power Integrations, Inc. v. Lee., Case No. 2014-1123 (August 12, 2015); Opinion by: Mayer, joined by Moore and Linn; Appealed From: District Court for the District of Columbia, Rothstein, J. Read the full opinion here.
