Gilbert Hyatt's long-running application disputes returned to the Federal Circuit in a 2025 prosecution-laches decision.
The appeal concerned several older applications connected to the pre-GATT filing period. The court affirmed judgment for the PTO on prosecution laches and also addressed Article III jurisdiction over certain pending claims.
For prosecution practice, Hyatt remains an outlier on the facts but not irrelevant. It shows that extraordinary delay, claim volume, and examination history can become litigation issues rather than mere docket management.
The case belongs in the archive as a prosecution-governance story: it is about the limits of applicant control over long-lived patent applications.