Opinions — Tuesday, February 3, 2026

The Federal Circuit affirmed two inter partes review decisions finding claims of Eagle View Technologies' U.S. Patents Nos. 8,670,961 and 8,078,436—both directed to systems for remotely generating roof estimation reports by analyzing aerial images to determine roof pitch, area, and shape—unpatentable as obvious over a combination of prior art references. Eagle View challenged the Board's claim construction of "calculate a pitch" and "determining a pitch," arguing these terms required a threshold level of accuracy that the prior art did not meet, and also contested the Board's combination rationale.

The court's analysis turned on whether the specification imposed implicit accuracy requirements on computational claim terms. Reviewing claim construction de novo and finding no preservation issue fatal, the panel held that neither "calculate" nor "determining" inherently required any particular accuracy threshold, noting the specification's own use of phrases like "closely estimat[ing]" and "accurately determin[ing]" (the latter suggesting accuracy was an optional modifier rather than inherent). On obviousness, the court applied the substantial evidence standard to uphold the Board's finding that a skilled artisan would understand the prior art's generation of a three-dimensional pitched roof model as necessarily involving pitch calculation, and that combining references teaching control point correlation methods with overlapping (but not necessarily stereoscopic-pair) images was reasonable under established KSR principles.