Federal Circuit Vacates PTAB Obviousness Determination and Holds Real Party in Interest Challenge Unreviewable

Federal Circuit vacated PTAB's obviousness determination in Federal Express v. Qualcomm, finding PTAB failed to consider Federal Express's arguments regarding patent claims. Court held that challenges to PTAB's real party in interest determination are unreviewable under § 314(d). Case involves Federal Express's U.S. Patent No. 8,766,797 for shipment tracking systems. Qualcomm filed IPR petition without listing Roambee as real party in interest. Case remanded for PTAB to properly consider patentability arguments.