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In Parallel Networks Licensing, LLC v. International Business
Machines Corporation, No. 1:13-cv-02072, Dkt. No. 366 (D. Del. Feb.
22, 2017) (Slip Op.), the court held IBM was estopped from
asserting obviousness under §103 based on prior art
combinations of which IBM was aware before its filed its IPR
petitions. Id. at 24-26.
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