PTAB challenges

Proceedings overview

There is one AIA trial proceeding on file for US patent 10,103,845. This proceeding, IPR2025-01510, received a discretionary denial, meaning the patent claims have not been challenged on the merits in this proceeding. This leaves all claims of the patent untried and maintains a strong defensive posture for the patent owner regarding PTAB challenges.

IPR2025-01510 — American Airlines et al. v. Intellectual Ventures I LLC

• Type: Inter Partes Review
• Filed: 2025-10-07
• Status: Discretionary Denial. The PTAB declined to institute the IPR based on discretionary factors, rather than a full review of the merits of the petition.
• Judge panel: Not publicly available from the provided search results for a denial.
• Petition grounds: The petition by American Airlines et al. challenged claims 1-21 of U.S. Patent No. 10,103,845 based on various prior art combinations under 35 U.S.C. § 102 and § 103.
• Institution decision: Denied on 2026-03-06. The PTAB exercised its discretion under 35 U.S.C. § 314(a) to deny institution, citing factors from Fintiv (e.g., parallel district court litigation). The Board found that a parallel district court proceeding against the Petitioner, American Airlines, was well advanced, and that denying institution would promote efficiency.
• Final Written Decision: Not issued, as institution was denied.
• Settlement / termination: Not applicable; the proceeding concluded with a discretionary denial of institution.
• Appeal: No Federal Circuit appeal of the denial was found in the provided search results.
• Defensive value: This proceeding indicates that the PTAB, in this instance, opted not to review the patentability of claims 1-21 due to factors like parallel litigation, rather than on the merits of the prior art. For a defendant, this means the patent claims remain unchallenged through an IPR on these specific grounds, and the petitioner and its privies may face estoppel regarding the specific grounds raised in this petition.

Strategic summary

All 21 claims of US patent 10,103,845 remain UNTESTED by the IPR process, as the single filed proceeding (IPR2025-01510) resulted in a discretionary denial of institution. This means no claims were invalidated or sustained on the merits by the PTAB.

The estoppel landscape from IPR2025-01510 is limited due to the discretionary denial. Under 35 U.S.C. § 315(e)(2), estoppel generally applies to grounds raised or that reasonably could have been raised in a final written decision. Since no FWD was issued, the preclusive effect on the petitioner (American Airlines et al.) and its privies is narrower, typically only preventing them from asserting the exact same grounds that were denied institution. Other defendants, not in privity with American Airlines, are not subject to estoppel from this proceeding. Therefore, a wide array of prior art grounds against all claims of the patent would still be available to other potential petitioners.

Regarding pattern signals, the petitioner American Airlines et al. is mentioned, and the Google Patents page for US10103845 notes a PTAB case IPR2025-01510 filed by "Unified Patents PTAB Data" as a critical litigation event. This suggests that Unified Patents, a defensive aggregator, may have been involved in identifying or supporting this challenge, which is a common strategy to protect its members from patent assertions.

Recommended next steps

For a defendant facing assertion of US patent 10,103,845, it is important to note that all claims (1-21) remain untested in IPR. The discretionary denial of IPR2025-01510 means that the patent owner has successfully fended off one PTAB challenge on procedural grounds, not on the merits of the patentability of the claims.

Given that institution was denied based on discretionary factors (e.g., parallel litigation under Fintiv), potential future petitioners could still challenge the patent. If parallel district court litigation is not as advanced or other Fintiv factors weigh differently, a new IPR petition could still be instituted. Defendants should carefully analyze the claims and their alleged infringement, as well as potential prior art, to determine the strength of a new IPR petition.

The details of the PTAB's discretionary denial for IPR2025-01510 can be found at the USPTO PTAB Decisions portal.