## Facts

- Cuozzo Speed Technologies, LLC owned U.S. Patent No. 6,778,074, covering a speed-limit indicator and display method.
- Garmin petitioned the Patent and Trademark Office (PTO) to institute inter partes review (IPR), asserting that multiple claims, including claim 17, were obvious over prior art.
- The Patent Trial and Appeal Board (PTAB) instituted IPR on claim 17 and also on claims 10 and 14 based on the same obviousness ground, treating them as sufficiently connected to the challenge to claim 17.
- Applying the PTO’s “broadest reasonable construction” (BRC) claim-construction regulation for IPR, the PTAB found claims 10, 14, and 17 unpatentable as obvious and canceled them.
- The PTAB denied Cuozzo’s motion to amend claims as futile.
- The Federal Circuit held that 35 U.S.C. § 314(d) barred appellate review of the institution decision and upheld the PTO’s use of BRC in IPR.
- The Supreme Court granted certiorari on (1) judicial review of IPR institution decisions and (2) the claim-construction standard in IPR.

## Issues

1. Whether 35 U.S.C. § 314(d) bars judicial review of a PTAB decision to institute IPR when the challenge argues the PTAB instituted review on claims or grounds not specifically raised in the petition.
2. Whether the PTO may require PTAB to construe patent claims in IPR using the “broadest reasonable construction” standard rather than the district-court “ordinary meaning” approach.

## Decision

- The Supreme Court affirmed the Federal Circuit in a 6–2 decision.
- The Court held that § 314(d) bars judicial review of PTAB’s institution decision at least as to challenges closely tied to the institution determination, including alleged error in instituting IPR on grounds not explicitly set out in the petition.
- The Court held the PTO permissibly required use of BRC in IPR through regulation as a reasonable exercise of authority delegated by 35 U.S.C. § 316(a)(4).
- The Court emphasized the limited reach of the nonappealability holding and did not decide whether constitutional challenges or other claims reaching beyond the institution framework might remain reviewable.

## Legal Principles

- Section 314(d)’s “final and nonappealable” language precludes appellate review of institution-related determinations when the challenge is tightly connected to the PTAB’s decision “whether to institute” IPR under the statutory institution provisions.
- The presumption favoring judicial review of agency action can be overcome by clear indications of congressional intent to bar review, which the IPR scheme supplies for institution-linked challenges.
- The PTO has statutory authority under § 316(a)(4) to issue rules “establishing and governing inter partes review,” including a claim-construction standard.
- The PTO’s BRC regulation for IPR is reasonable given longstanding agency practice and IPR’s public function of limiting patents to their legitimate scope, even though IPR has adjudicatory features similar to litigation.

## Conclusion

The Court held that § 314(d) generally prevents courts from reviewing PTAB’s IPR institution decisions when the objection is closely connected to the institution determination, and it upheld the PTO’s regulation requiring the broadest reasonable construction standard for claim interpretation in IPR.


Cuozzo Speed Techs., LLC v. Lee, 579 U.S. 261 (2016)