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, the Federal Circuit determination as to whether a reference is analogous art to a claimed invention requires, in part, an identification and comparison of the purposes or problems to which the reference and the invention relate, from the perspective of a person having ordinary skill in the art (“PHOSITA”). Donner requested IPR of a patent owned by Pro Stage relating to a mounting board for guitar effects pedals. In its IPR request, Donner asserted that the patent was obvious, in part, in view of a prior art reference related to electrical relay structures (“Mullen”). The PTAB rejected Donner’s obviousness challenges on the ground that Donner failed to demonstrate that Mullen was analogous art. Donner appealed.

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