Ingenico-IOENGINE decision clarifies IPR estoppel and public-use proof

Ingenico v. IOENGINE gave patent litigators a 2025 decision at the intersection of IPR estoppel and district-court trial proof.

The Federal Circuit addressed whether jury instructions on conception, diligence, public use, on sale activity, and validity presumptions created reversible error, while also reviewing Ingenico's ability to rely on prior art at trial.

The case is especially useful because IPR estoppel disputes often appear abstract until trial strategy depends on which references and theories remain available.

For defendants, the opinion belongs in the playbook for coordinating PTAB challenges with invalidity cases that may still reach a jury.