"Unlike in reissue and reexamination proceedings where applicants have an unfettered right to amend their claims to avoid cited prior art,16 in PGR, IPR, and CBM proceedings patent owners do not have the right to freely amend their patent claims – they must either stand as issued or be cancelled and abandoned. While patent owners do have the right to propose substitute claims for any that have been cancelled, they are afforded a single opportunity to file a motion to submit one substitute claim for each challenged claim (and must “show the patentable distinction of the proposed amended claim over all prior art”17). Finally, a patent owner has no right to amend the patent’s claims to meet any new arguments or evidence advanced by a challenger against the proposed substitute claims, nor, as noted above, any right to amend the proposed substitute claims after learning what the USPTO’s position is on their patentability."