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Claim Construction: Printed Matter Doctrine

CAFC: "Encrypted communications" and "program code" are not "printed matter"

In a precedential opinion, the CAFC, in IOENGINE, LLC v. Ingenico Inc., reversed PTAB's invalidation of claims related to portable data processing devices due to improper application of the Printed Matter Doctrine. Specifically, “Encrypted communications” and “program code” are not claimed for the content they are communicating, therefore they are not “printed matter” and the printed matter doctrine does not apply.

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