In Integrated Global Concepts, Inc. v. Advanced Messaging Technologies, Inc., 2014-01027, Paper 16, (December 22, 2014) the Board declined to institute inter partes review of claims 13–20, 25, and 36 (the “challenged claims”) of U.S. Patent No. 6,020,980.  In addressing the merits of the petition the Board quoted the Petition that the references “are clearly properly combinable and are representative of the obvious body of knowledge well within the grasp of the person of ordinary skill in the art in the field of the ’980 Patent.” The Board, observed that “This statement, by itself, does not provide any rationale for combining the cited teachings and certainly does not provide a sufficiently “articulated reasoning with some rational underpinning to support the legal conclusion of obviousness.” The Board complained that “Petitioner does not explain persuasively how or why a person of ordinary skill would have combined the cited teachings. The Board acknowledged that the Petition was supported by an expert declaration, but said the declaration, like the Petition, “only offers conclusions that it would have been obvious to combine certain teachings from each of the references” and does not provide any support for the conclusions with persuasive explanation or citation to objective evidence.