PTAB: Informal Delivery of Complaint Does Not Start One-Year Clock for Filing IPR

Aug 1, 2019

Reading Time : 3 min

On January 23, 2018, Aristocrat Technologies, Inc. (“Petitioner”) filed an inter partes review (IPR) challenging claims of U.S. Patent No. 9,022,852 (the “’852 Patent”), which is directed to a method of operating a slot machine. The owner of the ’852 Patent, High 5 Games, LLC (“Patent Owner”), had previously asserted the ’852 Patent against several defendants in district court, including Petitioner. Patent Owner first included claims alleging infringement of the ’852 Patent in its second amended complaint. Notably, before Patent Owner sought leave to file its second amended complaint, the Magistrate Judge recommended that Patent Owner send a redline version of its proposed amendments to the defendants, including Petitioner, to see if they would consent to the amendments. Pursuant to that recommendation, on December 1, 2016, Patent Owner circulated, via email, a redline version of its second amended complaint to the defendants. The defendants did not consent to the amendments and on December 23, 2016, Patent Owner sought leave from the court to file the second amended complaint. The district court granted leave and Patent Owner formally filed and served the second amended complaint on January 30, 2017.

Patent Owner argued in the IPR that the petition was time-barred under § 315(b) because Petitioner was served with a complaint on December 1, 2016, which is more than one year before the January 23, 2018, filing date of the petition. Relying on the Board’s precedential analysis in LG Electronics, Inc. v. Mondis Technology Ltd., IPR2015-00937, Paper 8 (PTAB Sept. 17, 2015), Patent Owner contended that the express language of § 315(b) requires only that the petitioner be served with “a” complaint, as happened here when Patent Owner emailed the proposed second amended complaint to Petitioner. The Board disagreed and distinguished LG Electronics by explaining that the factual situations and questions presented there were different. Specifically, the Board noted that in LG Electronics there was no dispute that there was valid service of the complaint. Moreover, rather than considering the present issue—namely, whether email delivery constituted “service of a complaint” at all—the Board in LG Electronics addressed whether a prior valid service can be obviated by a subsequent complaint or partial dismissal of a complaint. Because of these fundamental differences, the Board concluded that Patent Owner’s reliance on LG Electronics was misplaced.

The Board next considered the language of § 315(b) and determined that emailing a document styled as a proposed amended complaint, without authorization from the district court, was not “service” under the plain meaning of that term. In reaching its conclusion, the Board noted that the Federal Circuit has held that the plain meaning of the phrase “served with a complaint” in § 315(b) is “‘presented with a complaint’ or ‘delivered a complaint’ in a manner prescribed by law.Click-to-Call Techs., LP v. Ingenio, Inc., 899 F.3d 1321 (Fed. Cir. 2018) (emphasis added). The Board also referenced the Supreme Court’s “bedrock principle” that “a defendant is not obligated to engage in litigation unless . . . brought under a court’s authority by formal process.” Murphy Bros. v. Michetti Pipe Stringing, 526 U.S. 344, 347 (1999). Here, Petitioner did not receive formal process and was not officially a defendant in relation to the ’852 Patent by virtue of receiving Patent Owner’s email containing its proposed amended complaint. As such, Petitioner was not obligated to engage in litigation related to the ’852 Patent. Thus, Petitioner was not “served with a complaint” in a manner prescribed by law and its petition was not time-barred.

Practice Tip: When calculating the statutory one-year deadline to file an IPR under 35 U.S.C. § 315(b), parties should carefully scrutinize the specific circumstances surrounding service of a complaint. Presenting a complaint to a defendant in a lesser manner than that “prescribed by law” may not constitute service under the statute.

Case: Aristocrat Techs., Inc. v. High 5 Games, LLC, IPR2018-00529, Paper 26 (PTAB July 29, 2019)

Share This Insight

Previous Entries

IP Newsflash

March 4, 2025

On February 28, 2025, the USPTO announced that it was rescinding former Director Vidal’s 2022 memorandum on discretionary denials by the Patent Trial and Appeal Board. The 2022 memorandum effectively narrowed the application of discretionary denials in cases with parallel district court litigation by specifying instances where discretionary denial could not be issued. With the withdrawal of the memorandum, individual PTAB panels will regain flexibility in weighing discretionary denials. While the long-term effect of that increased flexibility is not yet known, the immediate effect is likely to be a shift towards the discretionary analysis applied by PTAB panels before the issuance of the memorandum.

...

Read More

IP Newsflash

March 3, 2025

A District of Delaware judge recently granted a defendant’s motion to include a patent prosecution bar in its proposed protective order after determining that litigation counsel’s ability to practice before the Patent Office—without ever having represented the plaintiffs at the Patent Office in the past—weighed heavily in favor of the bar.

...

Read More

IP Newsflash

February 12, 2025

The Federal Circuit recently reversed a district court decision that found a patent that did not describe after-arising technology failed to satisfy the written description requirement. In so doing, the Federal Circuit explained that written description and enablement are evaluated based on the subject matter that is claimed, not the products that practice those claims. As a result, the patentee was not required to describe unclaimed, later-discovered features of the accused products despite the broad language in the claims that undisputedly covered the products.

...

Read More

IP Newsflash

January 24, 2025

The District of Delaware recently rejected a patentee’s argument that non-production of an opinion letter from counsel, combined with knowledge of the patent, warranted a finding that defendant induced infringement.

...

Read More

IP Newsflash

January 17, 2025

The District of Delaware recently denied a motion to dismiss a patent infringement complaint involving gene editing technology that sought relief under the Safe Harbor Provision of the Hatch-Waxman Act. Specifically, the court found the patentee’s complaint sufficiently alleged at least some uses of the claimed technology that, when taken as true, were not solely uses of a “patented invention” that were “reasonably related” to an FDA submission.

...

Read More

IP Newsflash

January 17, 2025

The District of Arizona recently held that a plaintiff’s failure to mark patented products during the time period that marking was required barred it from recovering all pre-notice damages, including for a period of time when there was no obligation to mark.

...

Read More

IP Newsflash

January 16, 2025

The Unified Patent Court (UPC) aims to provide expeditious decisions for its litigants. That means that there is a higher bar for obtaining extensions of time. As exemplified in BMW v. ITCiCo, the UPC’s reluctance to grant extensions can have serious consequences, including revocation of the patent.

...

Read More

IP Newsflash

January 15, 2025

The Patent Trial and Appeal Board granted institution of inter partes review of a patent directed to delivery of targeted television advertisements. The board rejected patent owner’s argument that a lack of particularity as to the asserted grounds justified denial under 35 U.S.C. § 312(a), holding that “simply including a significant amount of testimony and a number of supporting references is not, by itself, a reason to find that the particularity requirement is not met.”

...

Read More

© 2025 Akin Gump Strauss Hauer & Feld LLP. All rights reserved. Attorney advertising. This document is distributed for informational use only; it does not constitute legal advice and should not be used as such. Prior results do not guarantee a similar outcome. Akin is the practicing name of Akin Gump LLP, a New York limited liability partnership authorized and regulated by the Solicitors Regulation Authority under number 267321. A list of the partners is available for inspection at Eighth Floor, Ten Bishops Square, London E1 6EG. For more information about Akin Gump LLP, Akin Gump Strauss Hauer & Feld LLP and other associated entities under which the Akin Gump network operates worldwide, please see our Legal Notices page.