The USPTO has invalidated Apple's (NASDAQ:AAPL) "rubber-banding" patent, citing prior art. The patent, which covers a software feature that indicates a user has scrolled to the end of a list, was successfully used in Apple's California win against Samsung (OTC:SSNLF), as well as against Motorola Mobility in Germany. Apple can, and likely will, request the decision be reconsidered. Regardless, Google (NASDAQ:GOOG) has already come up with a workaround for Android.