The Federal Circuit held that the Patent Trial and Appeal Board (PTAB) cannot institute inter partes review on a ground not advanced in Google's petition.
The court also held that the claims can be found obvious by relying on general knowledge of a person of ordinary skill in the art (POSITA) to supply a limitation missing from the prior art. The court noted in this case that the PTAB did not rely merely on conclusory statements and unspecific expert testimony but rather relied on expert testimony corroborrated by a prior art reference in order to conclude that a missing limitation is within a POSITA's general knowledge.
Read the case here.