Inland Diamond Products v Cherry Optical (Fed. Cir., October 15, 2025) 2024-1106

This opinion from the United States Court of Appeals for the Federal Circuit, dated October 15, 2025, concerns the case of Inland Diamond Products Co. v. Cherry Optical Inc. The court addresses an appeal from the U.S. District Court for the Eastern District of Wisconsin, which had granted summary judgment that Inland’s asserted patent claims were invalid for obviousness based on the doctrine of issue preclusion following previous inter partes reviews (IPRs). The Federal Circuit determined that the district court erred by applying issue preclusion to facts found by the Patent Trial and Appeal Board (Board) under a lower standard of proof (preponderance) than the higher standard (clear and convincing evidence) required in district court invalidity proceedings, citing precedent from the ParkerVision and Kroy cases. Consequently, the appellate court vacates the district court's judgment and remands the case for proper analysis, emphasizing that any future summary judgment must be based on evidence presented in court under the clear and convincing standard, not on the Board’s prior findings.

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