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MCM Portfolio LLC v. Hewlett-Packard Co.

812 F.3d 1284, 117 U.S.P.Q.2d 1284 (2015)

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MCM Portfolio LLC v. Hewlett-Packard Co.

United States Court of Appeals for the Federal Circuit
812 F.3d 1284, 117 U.S.P.Q.2d 1284 (2015)

Facts

Hewlett-Packard Company (HP) petitioned for inter partes review—a procedure for challenging the validity of a patent through a United States Patent and Trademark Office (PTO) hearing—of several claims in a patent held by MCM Portfolio LLC (MCM). The PTO Patent Trial and Appeal Board found the claims invalid on the ground of obviousness. MCM appealed to the United States Court of Appeals for the Federal Circuit, arguing that the inter partes proceeding violated Article III of the U.S. Constitution by occurring outside of the federal court system. MCM also argued that the proceeding violated the Seventh Amendment, which guarantees the right to a jury trial in federal civil actions.

Rule of Law

Issue

Holding and Reasoning (Dyk, J.)

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