Mazed v. Brent: Federal Circuit Affirms USPTO Unpatentability of Cancer Biology Patent
Mohammad A. Mazed appealed the USPTO’s rejection of patent application US16/602403 — a molecular system for cancer biology — to the Federal Circuit. The court affirmed the unpatentability ruling in January 2025, ending an appeal resolved in 255 days.
Federal Circuit closes the door on Mazed’s cancer biology patent claim
Filed on 30 April 2024, Case No. 24-1756 involves pro se appellant Mohammad A. Mazed challenging the United States Patent and Trademark Office’s determination that his patent application — US20200123575A1 (application number US16/602403), directed to a molecular system for cancer biology — was unpatentable. The respondent is Derrick Brent, Acting Under Secretary of Commerce for Intellectual Property and Acting Director of the USPTO, defended by a four-attorney government team.
The Court of Appeals for the Federal Circuit issued an affirmance on 10 January 2025, sustaining the USPTO’s invalidity and cancellation finding. An affirmance at this level means the appellate panel reviewed the record and found no reversible legal or factual error in the agency’s unpatentability determination. For Mazed, the patent application remains rejected; for the USPTO, its examination and Board-level analysis was upheld as legally sound.
The 255-day resolution is consistent with a straightforward appellate review on a written record rather than a remand or protracted briefing dispute. The pro se posture of the appellant — Mazed appeared and is identified as his own agent — may have limited the scope of appellate argumentation. What drove the underlying unpatentability finding (e.g., §101 subject-matter eligibility, §102 anticipation, or §103 obviousness) is not specified in the public record, leaving the precise doctrinal basis unclear.
Filing to Unpatentable in 255 days
255-day appeal — resolved faster than the median Federal Circuit disposition
Federal Circuit affirms: what the ruling means for both parties
Affirmance: the lower decision stands in full
An ‘AFFIRMED’ disposition at the Federal Circuit means the appellate panel reviewed the USPTO’s unpatentability ruling and found no reversible error — legal or factual. The agency’s rejection of US16/602403 is now confirmed by the appellate court. This does not create new law, but it validates the USPTO’s analytical framework as applied to this application.
No reversible error foundApplication remains rejected — patent rights extinguished at this level
For Mazed, the affirmance closes the Federal Circuit avenue for securing patent protection on this molecular cancer biology application. The claims as presented were deemed unpatentable, and that finding now carries appellate imprimatur. Further pursuit would require a petition to the Supreme Court — a rare and discretionary path — or continuation filing strategies, if prosecution options remain open.
Patent application rejectedUSPTO’s rejection withstands appellate scrutiny
The USPTO prevails at the appellate level, with its unpatentability determination affirmed in full. The government’s four-attorney team successfully defended the agency’s examination record. This outcome reinforces the deference appellate courts extend to USPTO patentability findings when the record supports them, consistent with established Federal Circuit review standards.
USPTO position upheldMolecular cancer biology space: patent bar remains high
This affirmance suggests the USPTO’s patentability standards for molecular cancer biology systems are being applied and upheld consistently at the appellate level. Innovators in oncology and molecular diagnostics should treat this as a signal that applications in this domain require robust claim differentiation and supporting disclosure to clear examination. The absence of granted claims here leaves the competitive landscape unchanged.
High patentability bar confirmedFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | MOHAMMAD A. MAZED | Individual | Pro se inventor-applicant — holder of application US16/602403 for a molecular cancer biology systemSearch in Eureka ↗ |
| Defendant | DERRICK BRENT, Acting Under Secretary of Commerce for Intellectual Property and Acting Director of the United States Patent and Trademark Office | Individual | Acting Director of the USPTO, representing the agency’s unpatentability determinationSearch in Eureka ↗ |
| Plaintiff counsel | Mohammad A. Mazed | Attorney | Counsel for MOHAMMAD A. MAZEDSearch in Eureka ↗ |
| Defendant counsel | Amy J. Nelson | Attorney | Counsel for DERRICK BRENT, Acting Under Secretary of Commerce for Intellectual Property and Acting Director of the United States Patent and Trademark OfficeSearch in Eureka ↗ |
| Defendant counsel | Farheena Yasmeen Rasheed | Attorney | Counsel for DERRICK BRENT, Acting Under Secretary of Commerce for Intellectual Property and Acting Director of the United States Patent and Trademark OfficeSearch in Eureka ↗ |
| Defendant counsel | Maureen Donovan Queler | Attorney | Counsel for DERRICK BRENT, Acting Under Secretary of Commerce for Intellectual Property and Acting Director of the United States Patent and Trademark OfficeSearch in Eureka ↗ |
| Defendant counsel | Shehla Wynne | Attorney | Counsel for DERRICK BRENT, Acting Under Secretary of Commerce for Intellectual Property and Acting Director of the United States Patent and Trademark OfficeSearch in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Court of Appeals for the Federal CircuitSearch in Eureka ↗ |
Official order — verbatim text
The single-word disposition ‘AFFIRMED’ is the Federal Circuit’s most deferential outcome — it signals the panel found no legal error warranting reversal, vacatur, or remand. In USPTO unpatentability appeals, the court applies substantial evidence review to factual findings and de novo review to legal conclusions. An affirmance across both standards, combined with the Basis of Termination recorded as ‘Unpatentable,’ confirms the agency’s rejection is now final at this judicial level.
US20200123575A1 — Molecular system for cancer biology
US20200123575A1, filed under application number US16/602403, is directed to a molecular system for cancer biology. The application’s publication number suggests a filing or PCT entry date consistent with late 2019 national-phase or direct US filing activity. The precise technical claims — whether directed to a diagnostic method, therapeutic mechanism, or research tool — are not enumerated in the case record, but the subject matter places it within the highly scrutinised domain of biological and molecular patent applications.
Cancer biology patents occupy contested IP territory at the USPTO and Federal Circuit, where § 101 eligibility challenges and § 103 obviousness rejections are common. A molecular system patent in this space, if granted, could provide significant exclusivity over research tools or therapeutic pathways. The affirmed rejection means competitors and research institutions currently face no enforcement risk from this specific application, though the underlying inventive concept may still surface in related filings or continuation attempts.
Should you run an FTO against US20200123575A1?
Biotech R&D teams, oncology platform developers, and molecular diagnostics companies working in cancer biology should note that US20200123575A1 is now confirmed unpatentable at the Federal Circuit level. This application no longer presents a direct infringement risk. However, teams should verify whether Mohammad A. Mazed holds any related granted patents or co-pending applications in the same technical family before treating the FTO landscape as fully clear.
PatSnap Eureka’s FTO Search Agent can map the full patent family around US16/602403, identify any granted siblings or continuations, and benchmark the claim language against your product’s technical architecture. Given the ambiguity around the specific rejection basis, Eureka can also flag analogous applications in molecular oncology that may cover overlapping territory — giving your team a defensible clearance record before product launch.
Run a freedom-to-operate analysis on US20200123575A1 to assess your product’s exposure
Run FTO in Eureka →Similar Federal Circuit appeals: molecular biology unpatentability rulings
Cases where the Federal Circuit affirmed USPTO unpatentability findings in molecular biology and oncology-related patent applications, including § 101 and § 103 rejections.
What this case signals for the molecular oncology IP landscape
Federal Circuit affirmance of USPTO rejections in cancer biology reinforces examination rigour and narrows the margin for underprepared applications.
Pro se appeals at the Federal Circuit face steep structural disadvantages
With Mazed appearing as his own representative against a four-attorney USPTO team, the procedural and substantive asymmetry was significant. Patent attorneys advising inventor-clients in similar situations should weigh the risk of an unguided appellate record cementing an unfavourable prosecution history — which can affect continuation and divisional strategy.
Unpatentability affirmances in molecular biology reflect § 101 and § 103 scrutiny
While the specific rejection basis is not identified in the public record, Federal Circuit affirmances of USPTO unpatentability rulings in molecular biology systems frequently involve § 101 subject-matter eligibility or § 103 obviousness over prior art. R&D teams building patent strategies around cancer biology platforms should ensure claim architecture anticipates both grounds from the outset.
MAZED v DERRICK — key questions answered
The Federal Circuit affirmed the USPTO’s unpatentability ruling on 10 January 2025. Patent application US20200123575A1 (US16/602403), covering a molecular system for cancer biology, was found unpatentable, and the appellate court found no reversible error in the USPTO’s determination.
The patent in dispute is US20200123575A1, application number US16/602403, described as covering a molecular system for cancer biology. The application was rejected by the USPTO as unpatentable, a finding subsequently affirmed by the Court of Appeals for the Federal Circuit.
An affirmance means the Federal Circuit reviewed the USPTO’s record and found no reversible legal or factual error. For the applicant, the patent application remains definitively rejected. The agency’s unpatentability determination carries appellate validation, making further challenge at this level unavailable without a Supreme Court petition.
After a Federal Circuit affirmance, the primary remaining judicial option is a petition for certiorari to the Supreme Court, which is rarely granted. Within prosecution, if any continuation or divisional applications remain pending and within statutory timelines, those may offer alternative paths — but the affirmed application itself is foreclosed.
The USPTO was represented by four government attorneys: Amy J. Nelson, Farheena Yasmeen Rasheed, Maureen Donovan Queler, and Shehla Wynne. The verdict cause is listed as ‘Patentability — Invalidity/Cancellation Action,’ with the basis of termination recorded as ‘Unpatentable.’ The specific statutory ground (e.g., § 101, § 102, or § 103) is not identified in the public case record.
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