MICROSOFT CORPORATION v. PROXYCONN, INC. (Fed. Cir. 2015) (P) – Substitute claims submitted during IPR must be shown patentable over all the prior art of record

A patentee may be required to show that substitute claims submitted during IPR are patentable over the prior art of record, including prior art that was not part of the original bases of unpatentability for which review of the claims being substituted was instituted....