by Dennis Crouch
In Centripetal Networks, LLC v. Palo Alto Networks, Inc., No. 2023-2027 (Fed. Cir. Oct. 22, 2025), the Federal Circuit held that an administrative patent judge's stock ownership in petitioner did not required vacatur of the PTAB institution and final written decisions. The case is almost exactly parallel to a prior federal circuit decision vacating a $1.9 billion district court judgment -- with the court explaining the difference being that Article III judges are held to a different ethical standard than PTAB judges.
Although the patentee lost lost the recusal argument, it won on a separate argument -- that the PTAB failed to consider specific evidence of copying in its obviousness analysis. This part of the case thus reinforces the idea that secondary considerations evidence must always be evaluated if presented.
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