Axonics, Inc., v. Medtronic, Inc. (Fed. Cir. 2023)

Establishing a prima facie case of obviousness based on a multiple prior art references generally requires that the references teach or suggest all claim elements and that one of ordinary skill in the art would be motivated to combine the references to achieve the invention as claimed.  During patent prosecution, rebutting an examiner’s motivation to combine is often considered to be more difficult than rebutting a contention that the references teach one or more specific claim elements….
By: McDonnell Boehnen Hulbert & Berghoff LLP