New Cambridge Mobile PTAB Ruling Highlights Critical IPR Petition Requirements: Consistency Between PTAB and District Court Proceedings

The United States Patent and Trademark Office (USPTO) recently designated a significant Patent Trial and Appeal Board (PTAB) decision as "informative," providing crucial guidance for patent practitioners navigating inter partes review (IPR) proceedings. The decision in Cambridge Mobile Telematics, Inc. v. Sfara, Inc. (IPR2024-00952, Paper 12) emphasizes the importance of consistent claim construction positions across different forums and proper treatment of means-plus-function limitations under 35 U.S.C. §112(f).

This newly designated informative decision represents a pivotal development in PTAB practice, particularly for parties involved in parallel litigation in district courts. By denying institution of the IPR petition, the Board has signaled a heightened scrutiny of procedural requirements and sent a clear message about the consequences of taking contradictory positions across different forums.

The decision's informative status means that patent practitioners should view it as guidance on recurring issues and Board norms—specifically, the proper handling of means-plus-function claim terms and the importance of consistency between IPR petitions and parallel district court litigation. While not binding precedent, informative decisions provide valuable insights into the Board's thinking and approach to common issues.