Alerts8.3.23
Estoppel Pursuant to Section 315(e)(1): Ongoing USPTO Developments

Two Salesforce ex parte reexamination decisions may reflect new treatment of real parties in interest considerations at the United States Patent and Trademark Office (USPTO)
In two related ex parte reexamination proceedings requested by Salesforce, the U.S. Patent and Trademark Office’s Central Reexamination Unit determined that estoppel under Section 315(e)(1) of the U.S. Code applied to Salesforce due to earlier inter partes review (IPR) proceedings initiated by another party, RPX Corporation.
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