In Liberty Mutual Insur. Co. v. Progressive Casualty Insur. Co., CBM2012-00002, Paper 66 (Jan. 23, 2014), the Patent Trial and Appeal Board (“PTAB”) affirmed that where at least one claim of a patent is directed to a covered business method (“CBM”), the PTAB has statutory authority to institute a CBM review as to any claim of that patent.
