# Word file metadata corroborated an inventor’s conception.

On October 19, 2026, the U.S. Court of Appeals for the Federal Circuit affirmed a Patent Trial and Appeal Board decision for Valtrus in an inter partes review (IPR). In a precedential opinion, the court held that automatic Word metadata independently corroborated the inventor’s conception testimony.

Sources checked October 29, 2026

**Affirmed** the Board’s decision for the patent owner, after Word metadata corroborated the inventor’s conception testimony.

## What the court held

Google petitioned for inter partes review of claims 1–23 of Patent 6,728,704 (IPR2022-01545). The Board held that Google hadn’t shown any claim unpatentable, and the Federal Circuit affirmed. Google v. Valtrus

The word-processor software generated the metadata automatically. The inventor didn’t author it. The court held that this metadata independently corroborated the inventor’s conception testimony. Google v. Valtrus

The patent owner showed corroborated conception and diligence up to the filing date. It thus antedated Bushee, which Google had asserted as prior art under § 102(e) as it read before the America Invents Act. Google v. Valtrus

## Read the limits

The antedating issue arises for patents under the law before the America Invents Act.

The holding is about metadata that the software made automatically, not text that the inventor wrote. The court assumed, without deciding, that the metadata was authentic. Google v. Valtrus

In our review of Federal Circuit opinions through October 29, 2026, it is the only precedential opinion this month in an appeal from the USPTO.

## The takeaway

Keep the original files. Automatic metadata can corroborate an inventor’s conception testimony.

## Related stories

- [Proving it existed isn’t proving it was public.](https://postgrantproceeding.com/insights/d10-proving-it-existed-isnt-proving-it-was-public)
- [One repeated expert paragraph blocked review of 16 claims.](https://postgrantproceeding.com/insights/d09-said-twice-supported-zero-times)
- [Win § 101 in court, and the IPR ends.](https://postgrantproceeding.com/insights/d07-win-101-in-court)

## Sources

- S100. Google LLC v. Valtrus Innovations Ltd., No. 2024-1945 (Fed. Cir. Oct. 19, 2026) (precedential). https://www.cafc.uscourts.gov/opinions-orders/24-1945.OPINION.10-19-2026_2772810.pdf

Precedential decisions bind the Board within their designated scope. Informative decisions show the Office’s reasoning but do not bind the Board. Court opinions are cited for what they decided; later history was checked on the date shown above.

General information about published decisions, not legal advice. Reading it does not create an attorney-client relationship.