(June 15, 2016, 10:20 AM EDT) -- WASHINGTON, D.C. — The Patent Trial and Appeal Board does not need to address in a final written decision patent claims that were not instituted in an inter partes review (IPR), a divided panel of the Federal Circuit U.S. Court of Appeals ruled June 9 (SAS Institute Inc. v. ComplementSoft LLC, Nos. 15-1346, -1347, Fed. Cir.; 2016 U.S. App. LEXIS 10508)....