On April 3, 2023, in Ironburg Inventions Ltd. v. Valve Corp., Nos. 21-2296, 21-2297, 22-1070 (Fed. Cir. Apr. 3, 2023), the Federal Circuit for the first time defined the standard for determining the scope of estoppel set forth in 35 U.S.C. § 315(e)(2) for prior art that was not raised in an inter partes review (“IPR”) petition. Under […]
