Guthrie v. Espiau, Int. 105,393 (April 18, 2007) Paper 94 [Interferences – amending priority statement; derivation, raising in priority statement]•Guthrie v. Espiau
Guthrie v. Espiau
Guthrie v. Espiau, Int. 105,393 (April 18, 2007) Paper 94 [Interferences – amending priority statement; derivation, raising in priority statement]Ptab Interferences
Gesamter Gesetzestext
BoxInterferences@uspto.gov Paper 94 Telephone: 571-272-9797 Filed: April 18, 2007 UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE BOARD OF PATENT APPEALS AND INTERFERENCES CHARLES GUTHRIE, EDMUND SANDBERG, DONALD WILSON, GREGORY PRIOR, and DAVID SMOLER Junior Party (Application 09/818,092), v. FREDERICK M. ESPIAU, CHANDRASHEKHAR J. JOSHI, and YIAN CHANG Senior Party (Patent 6,737,809). _______________ Patent Interference No. 105,393 (SCM) (Technology Center 2800) _________________ Before: LEE, LANE, and MEDLEY, Administrative Patent Judges. MEDLEY, Administrative Patent Judge. Decision - Rehearing –Bd.R. 127(d) 1 2 A. Introduction 3 On 22 March 2007, Espiau filed “ESPIAU MISCELLANEOUS MOTION 6 4 (Request for Rehearing of Espiau’s Request for Leave to Prove Derivation by 5 Guthrie)” (Paper 90). Espiau seeks rehearing of the “Decision – Interlocutory 6 Motions – Bd.R. 125(b),” (“Decision”), specifically requesting that a panel rehear 7 the Board’s decision denying Espiau’s request to amend its priority statement and 8
-2- to include derivation with its priority motion. On 3 April 2007, Guthrie filed an 1 opposition (Paper 92). 2 For the reasons that follow, Espiau’s request for rehearing is granted-in-part. 3 B. Discussion 4 A request for rehearing must specifically identify all matters the party 5 believes to have been overlooked, and the place where the matter was previously 6 addressed. Bd.R. 127(d). 7 Espiau argues that Bd.R. 204(a) is limited to priority, that priority and 8 derivation are separate, and that since derivation is a ‘distinct concept,’ Bd.R. 9 204(a) does not prohibit the submission of evidence of derivation without prior 10 notice in a priority statement (Paper 90 at 5-8). 11 In essence, Espiau is in disagreement with the Board’s interpretation of the 12 Board’s Rule 204(a). In the Decision, the Board explained that per Bd.R. 204(a), 13 “a party seeking to raise derivation must include, in its priority statement, a 14 statement that the party intends to establish derivation …” (Paper 86 at 6-7). 15 Bd.R. 204(a)(1) states: 16 A party may not submit evidence of its priority in addition to its 17 accorded benefit unless it files a statement setting forth all bases on 18 which the party intends to establish its entitlement to judgment on 19 priority. (Emphasis added). 20 21 We reaffirm that “[d]erivation is included in the ‘all bases’ provision of priority” 22 (Paper 86 at 6). As also explained in the Decision, the Board’s interpretation is 23 buttressed by the comment to Bd.R. 204(a), which explains that Bd.R. 204(a) “still 24 requires the party to state the bases on which it believes that it is entitled to relief” 25 and that “[s]uch bases might include an intent to prove derivation … .” Federal 26
-3- Register/Vol. 69, No. 155/Thursday, August 12, 2004/Rules and Regulations, 1 49993. 2 Espiau’s argument that the comments provide contradictory guidance to the 3 requirements of Bd.R. 204 is not persuasive. The comment quoted above directly 4 and clearly states that Bd.R. 204(a) still requires the party to state the bases on 5 which it is entitled to relief and that such bases might include an intent to prove 6 derivation. Nothing identified by Espiau can stand against the weight of that direct 7 instruction. Moreover, while derivation from a third party not involved in the 8 interference may be properly regarded as a patentability issue, and not a priority 9 issue between the two parties in an interference, derivation from the opposing party 10 in an interference is as much a priority issue as any priority issue can be, i.e., 11 between the two parties who was first? For these reasons, we perceive no 12 ambiguity in the rule, and we will not change that portion of the Decision 13 explaining the requirements of Bd.R. 204(a). 14 Espiau also argues that in its Motion 2, filed on the same day as its priority 15 statement, Espiau provided notice to Guthrie of its intent to prove derivation (Paper 16 90 at 3). Espiau Motion 2, page 2, lines 2-3 states that “[o]n 20 April 2000, two of 17 the Espiau inventors described their invention to three of the individuals named as 18 inventors on the Guthrie ‘092 application” (Paper 34). It is apparent that Guthrie 19 was aware of that statement, since Guthrie responded directly to the quote on page 20 1, lines 9-10 of its Opposition 2 (Paper 50). The statement made in Espiau Motion 21 2, if made in a priority statement and if made along with an alleged date and 22 location of Espiau’s earliest corroborated conception, would be sufficient notice of 23 intent to prove derivation. 24
-4- We have considered Guthrie’s opposition (Paper 92). Guthrie does not 1 dispute that it was made aware of the date alleged in Espiau Motion 2 regarding 2 derivation. Guthrie has failed to articulate any specific and meaningful prejudice if 3 Espiau is authorized to pursue derivation during the priority phase. Guthrie’s 4 arguments go to the merits of Espiau’s derivation case (Paper 92 at 6-10). The 5 parties’ priority motions (including derivation) are not due yet. Thus, Guthrie’s 6 arguments regarding the merits of Espiau’s derivation case are premature, since 7 Espiau’s derivation case has not been made by way of arguments and supporting 8 evidence. Guthrie will have full opportunity to oppose Espiau’s case for derivation 9 if one is made. 10 The “Decision – Interlocutory Motions – Bd.R. 125(b)” (Paper 86) has been 11 reconsidered. Espiau’s request to prove derivation during the priority phase of the 12 interference is granted. The request for rehearing is otherwise denied as explained 13 above. 14 Ordinarily, Espiau may need to amend its priority statement. In this case, 15 Espiau’s priority statement already includes its date of its alleged conception. The 16 sole purpose of amending its priority statement would be for Espiau to include its 17 alleged date of the communication of the invention to Guthrie. However, that date 18 was provided in Espiau Motion 2 as 20 April 2000. Under the circumstances of 19 this case, the statement made in Espiau Motion 2 will be given the same effect as if 20 it were made in Espiau’s priority statement, and therefore, Espiau is bound by that 21 date and cannot prove an earlier date of a corroborated communication of the 22 invention. Therefore, in this particular case, Espiau will not be required to amend 23 its priority statement. 24 25
-5- Accordingly, it is 1 ORDERED that Espiau’s miscellaneous motion 6 is granted-in-part as 2 provided in this decision; 3 FURTHER ORDERED that Espiau’s 20 April 2000 alleged date of 4 communication of the invention to Guthrie made in Espiau Motion 2 will be given 5 the same effect as if it were made in Espiau’s priority statement; and 6 FURTHER ORDERED that Espiau is authorized to include in its motion 7 for priority, its case for derivation. 8 /Jameson Lee/ ) JAMESON LEE ) Administrative Patent Judge ) ) /Sally G. Lane/ )BOARD OF PATENT SALLY G. LANE ) APPEALS AND Administrative Patent Judge ) INTERFERENCES ) /Sally C. Medley/ ) SALLY C. MEDLEY ) Administrative Patent Judge ) cc (via e-mail): rneifeld@neifeld.com napisano@JonesDay.com
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