Obviousness – What is Required to Show a Proper Motivation to Combine?

While the nonprecedential decision in Google v. Sonos, CAFC Appeal No. 2023-1259, May 23, 2024, is not itself groundbreaking.  It provides a useful backdrop to consider how the Federal Circuit analyzes whether a patent challenger has identified a proper motivation to combine references in an obviousness analysis. The Federal Circuit analyzed obviousness in the context…