Mealey's (April 20, 2018, 2:26 PM EDT) -- WASHINGTON, D.C. — Because a patent expressly claimed priority only to an immediately preceding application, and incorporated by reference a provisional application before that, the patent cannot claim the benefit of the earlier filing date, the Federal Circuit U.S. Court of Appeals ruled April 19, upholding a determination of obviousness by the Patent Trial and Appeal Board (Droplets Inc. v. E*Trade Bank, et al., Nos. 16-2504 & 16-2602, Fed. Cir., 2018 U.S. App. LEXIS 9895)....