The Federal Circuit's decision in Dolby Laboratories Licensing Corp. v. Unified Patents, LLC highlights that patent owners only have the right to identify real parties in interest (RPIs) during inter partes review (IPR) proceedings. Dolby's appeal was dismissed for lack of injury-in-fact needed for Article III standing. The court emphasized that disputes regarding RPIs were unnecessary without evidence of misconduct. This ruling clarifies that while patent owners can challenge RPIs during IPR, they do not possess an independent right to seek such identifications outside that context.
"Although patent owners might have the right to dispute unnamed real parties in interest (RPIs) during inter partes review (IPR) proceedings, the America Invents Act (AIA) does not give patent owners a freestanding right to identify RPIs."
"Demonstrating an injury-in-fact, or a concrete and particularized invasion of a legally protected interest, is one of the three requirements that must be met for a party to have Article III standing."
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