Unified Patents LLC v. Inpria Corp

Case Overview and Background: Unified Patents LLC v. Inpria Corp (IPR2025-00267)

This Inter Partes Review (IPR) case, IPR2025-00267, involved Unified Patents LLC as the petitioner challenging the validity of US Patent 11673903, owned by Inpria Corp, before the Patent Trial and Appeal Board (PTAB). Unified Patents LLC is a member-based organization dedicated to deterring abusive patent assertions by non-practicing entities (NPEs) and improving patent quality across various technology sectors by filing IPRs against what they deem invalid patents. Inpria Corp, now a wholly-owned subsidiary of the Japanese multinational JSR Corporation since its $514 million acquisition in 2021, is a world leader in the design, development, and manufacturing of metal oxide photoresists for extreme ultraviolet (EUV) lithography. This technology is crucial for producing advanced, smaller, and more efficient semiconductor chips, particularly for sub-3nm patterning.

The patent at issue, US Patent 11673903, is titled "Organometallic Photoresist Compositions for EUV Lithography and Methods for Using Same." This patent covers specific photoresist compositions utilizing organometallic compounds and their application in extreme ultraviolet (EUV) lithography processes for manufacturing semiconductor devices. The core technology focuses on improving the patterning capabilities required for advanced chip fabrication. While there is no "accused product" in an IPR context, the patent generally pertains to Inpria's core business of developing and commercializing metal oxide photoresists for the semiconductor industry. The procedural posture of this case was an IPR filed in 2025 with the Patent Trial and Appeal Board (PTAB) of the U.S. Patent and Trademark Office. The case reached a settlement, indicating a resolution between the parties prior to a final decision by the Board. The PTAB is a specialized administrative court that provides an alternative, often faster and less expensive, forum for challenging patent validity compared to district court litigation.

This case is notable given Inpria's significant position in the critical Extreme Ultraviolet (EUV) lithography market, a foundational technology for next-generation semiconductor manufacturing. The high value of Inpria's acquisition by JSR Corporation underscores the strategic importance of its photoresist technology to the global chip industry. Unified Patents' decision to challenge a patent owned by a key operating company like Inpria, rather than solely a non-practicing entity, highlights its broad mission to improve patent quality across vital technology sectors. The settlement of this IPR suggests a strategic outcome, reflecting the dynamics between patent challengers seeking to invalidate patents and patent owners defending their intellectual property in a high-stakes technological arena.

Unified Patents LLC filed an Inter Partes Review (IPR) against Inpria Corp, challenging U.S. Patent 11,673,903 B2, identified as IPR2025-00267. The proceeding ultimately concluded with a settlement.

Here's a chronological summary of the key developments in IPR2025-00267:

1. Filing & Initial Pleadings:

• IPR Petition Filing: Unified Patents LLC filed its petition challenging U.S. Patent 11,673,903. The IPR case number is IPR2025-00267.
• Institution Decision: The Patent Trial and Appeal Board (PTAB) issued a decision on institution in IPR2025-00267 on January 27, 2026. The decision indicates that the PTAB authorized the review to proceed, noting that a decision to institute under § 314 typically institutes on all challenged claims and grounds.
  • Note on Director Review: The period surrounding this IPR saw significant changes in PTAB institution decisions. Effective October 20, 2025, the USPTO Director began personally determining whether to institute IPRs and PGRs, issuing summary notices. However, petitions referred under the discretionary considerations process before October 20, 2025, were still decided by three-member panels. The decision in IPR2025-00267, dated January 27, 2026, references a panel, suggesting it might have fallen under the earlier process or was one of the cases where the Director consulted with judges.

2. Claim Construction (Markman) Outcomes:

• The institution decision in IPR2025-00267 indicates the Board's approach to claim construction. It mentions that if the Board institutes trial, it will "institute... on all grounds in the petition" and refers to the PTAB Consolidated Trial Practice Guide regarding this. The document also discusses the general principles of claim construction within the context of the IPR.

3. Parallel PTAB/Litigation Proceedings and their Effect:

• The IPR petition was filed by Unified Patents, an organization known for filing IPRs to challenge patent threats to its members or to obtain licenses for them.
• The institution decision in IPR2025-00267 noted that a settlement had occurred between Patent Owner Inpria Corp. and Lam Research in a parallel district court lawsuit in Delaware, Inpria Corp. v. Lam Research (D. Del. 1:22-cv-01359). This district court case, which involved 8 organometallic photoresist patents, was resolved by a stipulated dismissal without prejudice on September 15, 2025. The PTAB decision in IPR2025-00267 explicitly discusses how the settlement between Inpria and Lam Research in the Delaware lawsuit, and the common interest between Lam and Petitioner Unified Patents in invalidating the '903 patent, distinguished it from prior discretionary denial cases.

4. Settlement:

• The IPR proceeding, IPR2025-00267, concluded with a settlement. This outcome is noted in various summaries of Unified Patents' PTAB cases. The specific date or terms of the settlement are not publicly detailed in the available search results, but the case is marked as "Settlement."

Based on the available information, the petitioner in IPR2025-00267, challenging U.S. Patent 11673903, is Entegris, Inc., not Unified Patents LLC, despite the initial case caption. Unified Patents LLC serves as a platform that tracks PTAB cases, and its listings confirm Entegris, Inc. as the petitioner in this IPR.

While the "Decision Granting Institution of Inter Partes Review" (Paper 33) for IPR2025-00267 mentions "Entegris, including inside and out[side] counsel", the specific external law firm and individual attorneys representing Entegris, Inc. in this particular IPR could not be definitively identified from the provided search results.

However, the following in-house counsel for Entegris, Inc. are involved in managing the company's intellectual property and legal affairs:

• Joe Colella

  • Role: Executive Vice President, General Counsel, and Secretary.
  • Firm: Entegris, Inc. (Billerica, MA).
  • Note: Responsible for managing Entegris's legal affairs, including intellectual property, compliance, corporate governance, and litigation. He joined Entegris in 2013 and previously worked as a corporate attorney at Bingham McCutchen LLP.

• Erika Singleton

  • Role: Vice President, Global Chief IP Counsel.
  • Firm: Entegris, Inc. (Billerica, MA).
  • Note: Oversees the worldwide capture, protection, and commercialization of Entegris's intellectual property. She has extensive experience in patent law, including successfully strategizing in an International Trade Commission case against DuPont de Nemours Inc. involving a CMC Materials Inc. patent, which Entegris acquired.

The specific external counsel of record for Entegris, Inc. in IPR2025-00267 are not publicly disclosed within the provided search results.

In IPR2025-00267, Unified Patents LLC v. Inpria Corp, Inpria Corp, as the patent owner, was represented by attorneys from Paul Hastings LLP. While a PTAB institution decision (Paper 33, January 27, 2026) initially contained a confusing reference to "Voith Patent GmbH" as Patent Owner, the document consistently refers to Inpria Corp as the Patent Owner throughout, and other related case information confirms Inpria Corp as the patent owner and defendant.

The following attorneys from Paul Hastings LLP appear to have represented Inpria Corp in PTAB proceedings, including related IPRs involving the same patent families, and are highly likely to have been counsel of record in IPR2025-00267:

• Naveen Modi

  • Role: Lead Counsel, Global Co-Chair of the Intellectual Property Practice.
  • Firm & Office Location: Paul Hastings LLP, Washington, D.C.
  • Relevant Patent Litigation Experience: Mr. Modi's practice covers all aspects of high-stakes IP-related legal work, including litigation before federal district courts, the U.S. International Trade Commission, federal appeals courts, and post-grant proceedings before the Patent Trial and Appeal Board (PTAB). He has been recognized for his appellate experience, leading over 100 appeals at the U.S. Court of Appeals for the Federal Circuit, and is considered an expert in challenging and defending patents before the USPTO under the America Invents Act. He also led the Paul Hastings team that secured a victory for Inpria Corporation and JSR Corporation in a multi-billion dollar inventorship and contract dispute concerning semiconductor technology.

• Eric W. Dittmann

  • Role: Lead Counsel, Global Co-Chair of the Intellectual Property Practice.
  • Firm & Office Location: Paul Hastings LLP, New York.
  • Relevant Patent Litigation Experience: Mr. Dittmann is recognized as a leading IP litigator with extensive first-chair experience in patent litigations, post-grant proceedings, arbitrations, and appellate disputes across various technologies, including semiconductors. He has spearheaded semiconductor litigation for Inpria, including defeating a preliminary injunction motion that threatened a $6.4 billion acquisition. He regularly appears before the Federal Circuit and PTAB.

• Joseph E. Palys

  • Role: Lead Counsel.
  • Firm & Office Location: Paul Hastings LLP, Washington, D.C.
  • Relevant Patent Litigation Experience: Mr. Palys is a partner in the Intellectual Property practice at Paul Hastings, focusing on IP litigation and post-grant proceedings, including IPRs and PGRs. He is a former USPTO supervisory patent examiner and has extensive experience coordinating federal court and post-grant proceedings. He has represented clients in over 200 IPRs and CBMs.

It is noted that Paul Hastings LLP attorneys Naveen Modi, Phillip Citroen, Eric Dittmann, Isaac Ashkenazi, and Paul Anderson were listed as counsel for Inpria Corporation in a related IPR proceeding, IPR2025-00256, in a PTAB filing dated April 15, 2025. Joseph E. Palys is also consistently mentioned alongside Modi and Dittmann in Inpria's patent litigation representation.