Collateral Estoppel Requires Same Grounds, Says PTAB, PTAB Litigation Blog
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The PTAB’s recent decision in TicketNetwork, Inc. v. CEATS, Inc. reminds litigants that collateral estoppel only applies when there is an identity of issues. In the decision, the PTAB refused to find that a claim limitation was disclosed by a prior art news articles describing an online ticketing system, despite a jury having previously found that a similar claim limitation was anticipated by the ticketing system itself. Case IPR2018-00245, Paper 50 (PTAB May 31, 2019).
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