In re Bogese, 303 F.3d 1362, 1369, 64 USPQ2d 1448, 1453 (Fed. Cir. 2002)

Applicant filed twelve continuation applications over an eight-year period and applicant did not advance prosecution when the PTO gave the applicant an opportunity to advance prosecution.  In Borgese the Federal Circuit ruled that applicant had forfeited their right to a patent under the doctrine of prosecution history laches for unreasonable and undue delay in prosecution.  Prosecution history laches is not a hard and fast rule but the court ruled that where “multiple examples of repetitive filings that demonstrate a pattern of unjustified delayed prosecution,” laches may apply. Symbol Tech. Inc. v. Lemelson Med., Educ., & Research Found., 422 F.3d 1378, 1385, 76 USPQ2d 1354, 1360 (Fed. Cir. 2005)