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Court Denies Review in Lynk Labs Prior Art Dispute

Case: Lynk Labs, Inc. v. Samsung Electronics Co., Ltd., et al., No. 25-308

Lower Court: Federal Circuit

Docketed: 2025-09-16

Status: Denied

Question Presented: Whether patent applications that became publicly accessible only after the challenged patent's critical date are "prior art * * * printed publications" within the meaning of 35 U.S.C. § 311(b).

On March 9, 2026, the Supreme Court denied certiorari in Lynk Labs, Inc. v. Samsung Electronics Co., Ltd., ending the company’s effort to narrow the category of prior art available in inter partes review proceedings. The denial came after full briefing from both Samsung and the federal government, each urging the Court to leave the Federal Circuit’s decision undisturbed.

The dispute arose from an IPR petition in which Samsung challenged Lynk Labs’ LED lighting patents using patent applications as prior art. The central question was whether such applications qualify as “printed publications” under 35 U.S.C. § 311(b) even when they became publicly accessible only after the challenged patent’s critical date.

The legal question had real stakes for IPR practice. Section 311(b) limits IPR challenges to prior art consisting of patents or printed publications. Five amicus briefs were filed, reflecting genuine interest from the patent community. The Solicitor General’s opposition brief was filed February 2, 2026, alongside Samsung’s brief in opposition.

With denial, the Federal Circuit’s interpretation stands as controlling law. The full docket is available for those tracking the development of IPR prior art doctrine.