The defendant in M2M Solutions LLC v. Sierra Wireless America, Inc., C.A. No. 14-1102-RGA (D. Del.), argued that the PTAB's previous invalidation of several claims of the plaintiff's patents in an IPR meant that the plaintiffs were collaterally estopped from asserting the validity of the remaining claims—the claims that were not invalidated—at the district court.
Defendant argued that:
- The Federal Circuit has held that collateral estoppel applies to IPR proceedings generally;
- The Supreme Court has held that agency decisions may have preclusive effects during later court proceedings; and
- The Federal Circuit has extended collateral estoppel effects to unajudicated claims when there were no material differences between those and …