Although there are no formal limits on the number of grounds a petition may raise, the PTAB often eliminates alternative grounds challenging the same patent claims as “redundant,” even if the redundant grounds would establish unpatentability. See, e.g., Liberty Mutual Insurance Co. v. Progressive Casualty Insurance Co., CBM2012-00003, Paper 7 (Oct. 25, 2012). The PTAB cites its statutory 12-month deadline for completing proceedings as making it necessary to eliminate redundant grounds and run trials efficiently. On November 2, 2015, the Court of the Appeals for the Federal Circuit heard a case that may change the PTAB’s redundancy practice. Shaw Indus. Group, Inc. v. Automated Creel Sys’s, Inc., Nos. 15-1116, -1119 (Fed. Cir.).
