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## Overview The U.S. Court of Appeals for the Federal Circuit (CAFC) issued a precedential decision in *Definitive Holdings, LLC v. Powerteq LLC*, affirming the District of Utah's grant of summary judgment of invalidity of Definitive Holdings' controller patent, according to IPWatchdog (April 15, 2026). The opinion was authored by Judge Cunningham and joined by Chief Judge Moore and Judge Dyk. ## Invalidity Basis The district court found the asserted patent claims invalid under the pre-America Invents Act (AIA) version of 35 U.S.C. § 102(b), the statutory bar provision addressing prior art published or patented more than one year before the patent application's filing date (IPWatchdog, April 15, 2026). The CAFC affirmed this finding on appeal. ## Significance of Pre-AIA § 102(b) Pre-AIA § 102(b) invalidity grounds remain relevant for patents with priority dates before March 16, 2013 (the AIA transition date). The provision creates an absolute bar based on prior public disclosure or commercial activity, without the grace period exceptions available under AIA § 102(b)(1). Patents in industrial control, automotive, and legacy electronics sectors frequently have pre-AIA priority dates. ## Strategic Significance - **Controller technology patents**: Decisions in this space affect automotive ECU, industrial automation, and consumer electronics patent portfolios. - **Pre-AIA invalidity strategy**: The affirmance reinforces the utility of pre-AIA § 102(b) as a summary judgment invalidity tool against older patents, potentially accelerating patent challenge success rates in this category. - **Precedential weight**: The CAFC designated this a precedential opinion, meaning it binds future panels and district courts within the circuit. - **NPE litigation exposure**: Definitive Holdings appears to be a patent assertion entity; the ruling limits a category of controller patent claims that might otherwise be asserted against implementers. ## Judicial Panel Chief Judge Moore and Judge Dyk are both influential voices on patent validity doctrine. Judge Dyk in particular has a long record of skepticism toward overbroad patent claims. Their joinder in the affirmance signals panel consensus. ## Anticipated Developments Petition for rehearing en banc is possible. The opinion may be cited in pending district court summary judgment motions involving pre-AIA controller patents.