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No. 25-1049October Term 2025Dismissed

Docket 25-1049October Term 2025 (2025–2026)

Gilbert P. Hyatt, Petitioner v. John A. Squires, Under Secretary of Commerce for Intellectual Property and Director, United States Patent and Trademark Office

from the United States Court of Appeals for the Federal Circuit.

Case status

Current stage
Dismissed
Latest event
Dismissed
Decision timing
No window until argument is scheduled.
Case Accepted
Arguments
Decision Released
What it's about

from the United States Court of Appeals for the Federal Circuit.

Question presented

Whether the USPTO may invoke prosecution laches as a defense to a disappointed patent applicant’s suit under 35 U.S.C. 145.

Case path

United States Court of Appeals for the Federal Circuit / Dismissed

Area

Dismissed Supreme Court case

Briefing

What it's about

Gilbert Hyatt is asking the Supreme Court to review whether the U.S. Patent and Trademark Office can use prosecution laches (a judge-made rule about unreasonable delay) to defeat his Section 145 case, a district court suit after a patent denial. Hyatt says Congress already set detailed timing rules for patent examination, so the agency should not add this extra barrier.

Argument

No oral argument is scheduled, and the Court has not yet decided whether to hear the case. Hyatt argues this delay doctrine is a limited "gap-filling doctrine" that cannot override Congress's patent timelines.

Impact

The answer could shape how the Patent Office handles long-running applications. For example, an inventor who met the statutory deadlines could still lose a patent if the agency may rely on this delay-based doctrine.

What is the main issue in Hyatt v. Squires?

The petition asks whether the USPTO can use a delay-based fairness doctrine to defeat Hyatt's district court suit after a patent denial.

Who is affected if the USPTO can use this delay doctrine?

Patent applicants with long-running cases could lose patents even when they followed Congress's timing rules. The agency would keep a stronger tool to reject some delayed applications.

What happens next in Hyatt v. Squires?

The justices first will decide whether to grant certiorari (hear the case). No oral argument is scheduled yet.

Grounding

Grounding
Primary materials plus reporting.
Note
Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
Checked
Jul 25, 2026
Primary materials5
Context reporting3