Our Patent Case Summaries provide a weekly summary of the precedential patent-related opinions issued by the Court of Appeals for the Federal Circuit and the opinions designated precedential or informative by the Patent Trial and Appeal Board.
Coda Development S.R.O., et al., v. Goodyear Tire & Rubber Co., et al.
No. 2023-1880 (Fed. Cir. (N.D. Ohio) Dec. 8, 2025). Opinion by Cunningham, joined by Lourie and Dyk.
Coda sued Goodyear for trade secret misappropriation under Ohio state law and for correction of inventorship of a Goodyear patent related to self-inflating tire technology.
At a trial on Coda’s trade secret claims, the jury found that Goodyear misappropriated five of Coda’s alleged trade secrets and awarded Coda $2.8 million in compensatory damages and $61.2 million in punitive damages. After trial, however, the district court granted Goodyear’s motion for judgment as a matter of law of no trade secret misappropriation, concluding that the five trade secrets were either not sufficiently definite, not “secret,” not used or disclosed by Goodyear, or never conveyed by Coda to Goodyear. The district court also denied correction of inventorship of Goodyear’s patent. Coda appealed.
The Federal Circuit affirmed. On the trade secret claims, the Federal Circuit agreed with the district court “that no reasonable jury could find that all elements of a trade secret misappropriation claim were satisfied for each asserted trade secret.” For example, for one of the alleged trade secrets, Coda had publicly disclosed the information in a PCT application and an industry article. For other alleged trade secrets, Coda did not define them with sufficient particularity, and one of them was not used by Goodyear.
As to the district court’s refusal to correct inventorship of the Goodyear patent, the Federal Circuit ruled that Coda’s inventorship challenges rose and fell together with Coda’s trade secret claims. Thus, the Federal Circuit ruled that the district court’s denial of Coda’s correction of inventorship claim was not erroneous.
International Business Machines Corp. v. Zillow Group, Inc., et al.
Nos. 2024-1170, -1274 (Fed. Cir. (PTAB) Dec. 9, 2025). Opinion by Chen, joined by Taranto and Stoll.
IBM owns a patent related to systems and methods for single sign-on operations, which allow a user to create several accounts using a single set of login credentials. Rakuten initiated an IPR proceeding challenging IBM’s patent, and Zillow joined the IPR after institution. The Patent Trial and Appeal Board found some claims unpatentable, which IBM appealed, and other claims not unpatentable, which Zillow cross-appealed.
IBM raised two arguments on appeal. First, IBM argued that the Board’s analysis impermissibly strayed from the theories presented in the petition. According to IBM, the petition asserted that the prior art “discloses” the claimed “protected resources” limitation, while the Board instead considered what the prior art “suggests” or “strongly suggests.”
Zillow responded that IBM’s argument is barred under 35 U.S.C. § 314(d) because, according to Zillow, IBM’s challenge is “closely tied” to the Board’s institution decision such that § 314(d)’s bar on reviewability applies. The Federal Circuit disagreed and held that § 314(d) “does not prevent us from examining whether the inter partes review proceeds in accordance with the law’s demands.” The court noted that it “routinely examine[s] whether the Board’s final written decision departed from the petition.” Here, IBM did not seek to “undo” institution; IBM “simply ask[ed] to ensure the Board’s final written decision stayed within the confines of [the] petition.”
Turning to the merits of IBM’s argument, the Federal Circuit reasoned that while the Board may have used the terms “suggests” and “strongly suggests,” the Board never proposed modifying the prior art. The Board’s “line of inquiry—determining that a skilled artisan would understand a prior art reference’s express teachings to disclose a particular claim limitation—comports with a § 102 anticipation analysis and does not require turning to § 103 to modify a reference to satisfy a particular limitation.”
Second, IBM raised a merits-based substantial evidence challenge. The Federal Circuit concluded that in the context of the prior art’s disclosures, the Board’s inferences regarding the prior art were reasonable.
With respect to Zillow’s cross-appeal, the Federal Circuit rejected Zillow’s argument that the Board’s findings were inconsistent for two of the challenged claims. The Federal Circuit held that a key distinction between the claims “makes all the difference as to [the prior art reference],” and “the Board’s opposing conclusions on patentability for the two claims thus make good sense.”
The Federal Circuit therefore affirmed the Board’s final written decision as to both IBM’s appeal and Zillow’s cross-appeal.