Qualcomm and Apple returned to the Federal Circuit in an IPR dispute over the role of applicant-admitted prior art.
The court addressed the PTO's interpretation that admissions may be used in combination with patents or printed publications in an obviousness analysis, so long as those admissions do not themselves become the statutory basis for the IPR ground.
For PTAB practitioners, the decision is highly practical. Patent-owner admissions in the specification can help explain what a skilled artisan knew, but petitioners must still anchor the IPR ground in qualifying prior art.
The case belongs in the 2025 IPR playbook because it affects petition drafting, expert declarations, and how prosecution statements are mined for obviousness theories.