INDUSTRIAL TECHNOLOGY RESEARCH v. PACIFIC BIOSCIENCES (Fed. Cir. 2016) (NP) – Common ownership of a prior art reference cannot be established by later filed assignment documents alone

Common ownership of a prior art reference at the time of invention cannot be established for the purposes of disqualifying that reference under § 103(c) by later filed assignment documents alone. Here, for example, an assignment of a prior art reference that occurred...