On August 19, 2009, the Federal Circuit, sitting en banc, limited the reach of 35 U.S.C. § 271(f), holding that the statute does not apply to method claims. The Federal Circuit’s decision in Cardiac Pacemakers, Inc. v. St. Jude Medical, Inc., _F.3d_ (Fed. Cir. 2009) (en banc in part) (Lourie, J.), reversed its earlier holding in Union Carbide Chemicals Plastics Technology Corp. v. Shell Oil Co., 425 F.3d 1366 (Fed. Cir. 2005). In overturning a relatively new precedent, the Federal Circuit explained that the language and legislative history of Section 271(f), as well as the presumption against extraterritorial application of U.S. law, militated against applying the statute to method and process claims.