Dolby Labs. Licensing Corp. v. Unified Pats., LLC

Authored by: Jeremy J. Gustrowsky

The Federal Circuit recently dismissed an appeal by Dolby Laboratories Licensing Corporation, clarifying when a party can challenge a Patent Trial and Appeal Board (PTAB) decision in court. The case involved Dolby’s U.S. Patent No. 10,237,577, which had been challenged in an inter partes review (IPR) by Unified Patents, LLC. Interestingly, the PTAB ultimately sided with Dolby, finding the patent claims valid. However, Dolby still wanted the court to review the Board’s refusal to decide whether other companies should have been named as “real parties in interest” in the IPR.

Dolby argued that it had a right to know who was really behind the challenge to its patent, claiming that the America Invents Act (AIA) gives patent owners an “informational right” to this knowledge. The company also raised concerns about potential conflicts of interest and future legal issues if the identities of all interested parties weren’t revealed. But the Federal Circuit disagreed, holding that the AIA’s rules about naming real parties in interest are meant to make the patent system more efficient—not to guarantee patent owners a right to information for its own sake.

The court emphasized that, even though the AIA allows dissatisfied parties to appeal PTAB decisions, they still must show a concrete injury—something real and specific that affects them directly. Dolby’s worries about possible future disputes or hypothetical conflicts were too speculative to count as such an injury. Since Dolby actually won at the PTAB and couldn’t show any actual harm from the Board’s decision not to adjudicate the real party in interest issue, the court said it had no standing to appeal.

This decision is a reminder that the right to appeal in patent cases is not automatic. Even if a party disagrees with how the PTAB handled certain procedural questions, it must show a real, personal stake in the outcome—otherwise, the courts won’t step in.