In Microsoft Corp. v. Secure Web Conference Corp., case number IPR2014-00745, the PTAB  denied trial because the Petitioner failed to adequately establish obviousness. The “general contention that if anything is missing from [one reference] it can be found in [the others] leaves us to speculate how the references are combined, and does not sufficiently explain how the claimed subject matter is unpatentable,” the board said.

It is becoming clear that the PTAB will not accept conclusory arguments for establishing obviousness.  The rationale/motivation to combine references, and the manner in which they are combined, must be clearly articulated and should be supported by expert testimony.