Hafeman v. Google & Microsoft: Federal Circuit Dismisses in Part, Affirms in Part
Individual inventor Carolyn W. Hafeman appealed against Google LLC and Microsoft Corporation at the Federal Circuit, asserting three patents covering computer recovery and return technology. After 801 days, the court issued a split ruling — dismissing part of the appeal and affirming part — leaving the patentability challenge partially resolved.
Three computer recovery patents, two tech giants, one split Federal Circuit ruling
Carolyn W. Hafeman, an individual inventor, filed this appeal at the Court of Appeals for the Federal Circuit on 26 March 2024, bringing patentability challenges concerning three US patents — US9892287B2, US10789393B2, and US10325122B2 — all directed to computer recovery or return technology. The defendants are Google LLC and Microsoft Corporation, represented by Smith Baluch LLP. The underlying verdict cause is recorded as an invalidity/cancellation action.
The Federal Circuit closed the case on 5 June 2026, issuing an order that the appeal be 'dismissed in part, affirmed in part.' The recorded basis of termination is 'Appeal Dismissed in Part.' The docket order states the cause was considered and adjudged as dismissed-in-part and affirmed-in-part, meaning some aspects of the appeal did not proceed on the merits while others were upheld at the appellate level. The specific terms and scope of each part are not further detailed in the available record.
The 801-day duration is consistent with a substantive Federal Circuit appeal involving multiple patents and two major technology defendants. What drove the partial dismissal — whether procedural standing issues, jurisdictional defects, or voluntary withdrawal on certain claims — is not disclosed in the public record. The specific patents or issues corresponding to the dismissed portion versus the affirmed portion are not identified in the available case data.
See Complete Case & Patent Analysis →Filing to Appeal Dismissed in Part in 801 days
801 days from filing to close — a substantial Federal Circuit appeal timeline
US9892287B2, US10789393B2 & US10325122B2 — Computer Recovery or Return Technology
Any company developing computer recovery, remote device management, asset return, or data wipe functionality should treat this patent family as a live FTO consideration. The partial Federal Circuit affirmance confirms that at least some patentability findings stand — but the scope of surviving claims is not fully determinable from the public record alone. Product teams deploying cloud-based recovery, lost-device return workflows, or enterprise device management platforms should assess exposure before scaling.
Official order — verbatim text
The Federal Circuit's order — 'dismissed-in-part, affirmed-in-part' — reflects a split disposition in which at least one portion of Hafeman's appeal was not adjudicated on the merits (dismissed) while at least one portion received substantive appellate review and the lower tribunal's decision was upheld (affirmed). The affirmance standard at the Federal Circuit requires that no reversible error be found in the decision below; the dismissal component indicates a separate, non-merits barrier to review on those issues. The precise allocation between the three patents is not specified in the available record.
Federal Circuit split ruling: what dismissed-in-part, affirmed-in-part means
What 'dismissed in part, affirmed in part' means at the Federal Circuit
A split Federal Circuit disposition means the court declined to reach the merits on at least one portion of the appeal — dismissing it for procedural, jurisdictional, or standing reasons — while separately affirming a lower tribunal's decision on at least one other portion, finding no reversible error there. The two parts of the ruling operate independently. The specific allocation of dismissed versus affirmed issues is not detailed in the available record.
Split appellate dispositionHafeman's position after a partial affirmance
For the portion of the appeal that was affirmed, the lower tribunal's decision stands against Hafeman — suggesting at least some patentability findings adverse to the patent holder were upheld. The dismissed portion means the Federal Circuit did not adjudicate those issues on the merits, leaving the underlying status of those specific claims or patents uncertain from the public record alone. The specific patents or claims affected by each part are not disclosed.
Partial adverse outcome for appellantGoogle and Microsoft secure at least a partial appellate win
The affirmance component of the ruling is consistent with a favorable result for Google LLC and Microsoft Corporation on at least part of the patentability challenge — the lower decision in their favour was not disturbed on those issues. The dismissed portion does not constitute a merits win or loss for either defendant. The overall effect on enforceability of the three asserted patents against these defendants is not fully determinable from the available record.
Partial appellate win for defendantsComputer recovery IP: what a split ruling signals for the sector
A split Federal Circuit ruling on computer recovery and return patents suggests the asserted technology touches on legally contested ground — some claims or proceedings survived appellate scrutiny while others did not reach a merits ruling. Companies developing or commercialising device recovery, remote wipe, or return-technology products should monitor the specific claim scope of US9892287B2, US10789393B2, and US10325122B2 in light of this outcome and any subsequent proceedings.
Contested computer recovery IPFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Carolyn W. Hafeman | Individual | /Search in Eureka ↗ |
| Defendant | Google, LLC | Company | /Search in Eureka ↗ |
| Co-Defendant | Microsoft Corporation | Company | Search in Eureka ↗ |
| Plaintiff counsel | Stephen Underwood | Attorney | Counsel for Carolyn W. HafemanSearch in Eureka ↗ |
| Plaintiff law firm | Glaser Weil Fink Howard Jordan & Shapiro LLP | Law Firm | Representing Carolyn W. HafemanSearch in Eureka ↗ |
| Defendant counsel | Matthew A. Smith | Attorney | Counsel for Google, LLCSearch in Eureka ↗ |
| Defendant law firm | Smith Baluch LLP | Law Firm | Representing Google, LLCSearch in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Court of Appeals for the Federal CircuitSearch in Eureka ↗ |
R&D signals in the computer recovery and device management patent space
Forward-looking patent and R&D intelligence derived from the Hafeman v. Google & Microsoft dispute — covering portfolio activity, filing trends, and white-space opportunities in device recovery technology.
Hafeman's computer recovery patent family: continuation depth and filing strategy
The three asserted patents share sequential application numbers suggesting a deliberate continuation filing strategy around core computer recovery inventions. Understanding the full depth of Hafeman's portfolio — including any pending continuations, divisionals, or related applications — is critical for competitors and licensees assessing long-term exposure in the device recovery space.
Continuation family depthFiling trends in computer recovery, remote wipe, and device return technology
The computer recovery and device return domain is attracting filings from a range of players as enterprise device management and BYOD policies scale globally. Tracking claim-level filing trends in remote recovery, asset identification, and return-workflow patents can surface competitive positioning signals and highlight areas where the patent landscape is densifying or opening up.
Device recovery filing trendsGoogle and Microsoft's own IP in device recovery and management
Google LLC and Microsoft Corporation both maintain substantial patent portfolios in device management, security, and recovery workflows. Analysing their own filings in this space — and how those filings relate to the claimed inventions in the Hafeman family — can reveal defensive patent strategies, potential cross-licensing leverage, and areas where their proprietary approaches diverge from the asserted claims.
Big Tech defensive IPAdjacent innovation opportunities near computer recovery IP
The contested claim space around computer recovery and return technology — particularly following a split Federal Circuit ruling — may create white-space opportunities in adjacent areas such as hardware-assisted recovery, blockchain-based device identity, or AI-driven asset return workflows. These adjacent domains may offer innovation runway with reduced freedom-to-operate friction relative to the core disputed claims.
Adjacent R&D white spaceSimilar Federal Circuit patentability appeals in computer recovery and device management IP
Explore Federal Circuit appeals involving patentability challenges to computer recovery, device management, and remote access patents — cases with comparable invalidity/cancellation postures.
What this case signals for the computer recovery patent IP landscape
A split Federal Circuit ruling across three patents and two major defendants highlights the complexity of enforcing device recovery IP at the appellate level.
Individual inventors face structural challenges appealing against large tech defendants
Hafeman's position as an individual inventor asserting three patents against Google and Microsoft at the Federal Circuit is resource-intensive. The split outcome — with part of the appeal dismissed without a merits ruling — suggests procedural or standing hurdles that smaller patentees should anticipate when pursuing invalidity or enforcement appeals against well-resourced defendants.
Computer recovery patents remain an active battleground at the Federal Circuit
The patentability challenge across three related computer recovery patents in a single appeal signals that this technology cluster is under sustained scrutiny. Teams building device management, remote recovery, or asset return platforms should assess whether their own implementations or patent portfolios overlap with the US9892287, US10789393, and US10325122 family before engaging in this space.
Hafeman v Google — key questions answered
The Federal Circuit issued a split disposition: the appeal was dismissed in part and affirmed in part. The recorded basis of termination is 'Appeal Dismissed in Part.' The docket order states the cause was adjudged as dismissed-in-part, affirmed-in-part. The specific issues or patents corresponding to each part are not detailed in the available public record.
Hafeman asserted three US patents directed to computer recovery or return technology: US9892287B2 (application US15/601645), US10789393B2 (application US16/377768), and US10325122B2 (application US15/864749). The sequential application numbers suggest a continuation or related-filing family.
A dismissed-in-part ruling means the Federal Circuit declined to adjudicate at least one portion of the appeal on the merits — typically due to procedural, jurisdictional, or standing grounds. The affirmed-in-part component means the court reviewed the merits of at least one other portion and found no reversible error in the lower tribunal's decision, leaving that decision standing.
The verdict cause is recorded as an invalidity/cancellation action — meaning the proceedings involved a challenge to the validity or patentability of Hafeman's three computer recovery patents. The specific grounds of invalidity (e.g., prior art, obviousness, subject matter eligibility) are not detailed in the available case record.
The appeal was filed on 26 March 2024 and closed on 5 June 2026, a duration of 801 days. This timeline is consistent with a substantive Federal Circuit appeal involving multiple patents, patentability challenges, and two major technology company defendants.
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