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A Published Patent Application Is IPR Prior Art as of Its Filing Date

Before Lourie, Prost, and Stark - Summary: In an IPR, a patent application is considered a “printed publication” as of the application’s filing date, not its publication date. Samsung filed a petition for IPR of a Lynk Labs...more

Allergan v. MSN Laboratories: Federal Circuit Places Limits on Obviousness-Type Double Patenting

On August 13, 2024, the Federal Circuit issued its decision in Allergan USA, Inc. v. MSN Laboratories Private Ltd., No. 24-1061, which limits the scope of obviousness-type double patenting for patents in the same family. The...more

FDA Panel Votes Against MDMA-Assisted Talk Therapy

On June 4, 2024, a panel of experts advising the Food and Drug Administration (FDA) on the use of the psychedelic midomafetamine (MDMA) for post-traumatic stress disorder (PTSD) voted 9-2 that MDMA in combination with talk...more

Medicare Drug Price Negotiation Program Steadily Progressing Despite Lawsuits

The Biden Administration’s Inflation Reduction Act (IRA)’s Medicare drug price negotiation program, which allows Medicare to directly negotiate prices with drugmakers, has faced several legal challenges....more

District Court Finds Mylan (Viatris) Infringes Regeneron’s Eylea Patent

On December 27, 2023, Judge Thomas S. Kleeh of the United States District Court for the Northern District of West Virginia issued an order finding that Mylan (Viatris) infringed claims 4, 7, 9, 11, and 14-17 of Regeneron’s...more

Federal Circuit Says Extrinsic Evidence Should Have Been Considered in Claim Construction

In a recent precedential opinion, the Court of Appeals for the Federal Circuit vacated an infringement judgement against Mylan (Actelion Pharmaceuticals Ltd. v. Mylan Pharmaceuticals Inc., No. 2022-1889, Fed. Cir. Nov. 6,...more

IPR Decision Based on a Barely Mentioned Typo Violated the APA Notice Requirement

APPLE INC. v. COREPHOTONICS, LTD. Before Stoll, Linn, and Stark. Appeal from the Patent Trial and Appeal Board. Summary: An IPR final written decision based on a party’s brief mention of an error in an expert...more

Merck Sues Federal Government Over Medicare Drug Price Negotiation Program

On June 6, 2023, Merck & Co. filed a lawsuit against the U.S. government in federal court over the Inflation Reduction Act (IRA)’s Medicare drug price negotiation program, which allows Medicare to directly negotiate prices...more

Expert Testimony Inconsistent With Agreed-Upon Claim Construction Is Properly Stricken

TREEHOUSE AVATAR LLC v. VALVE CORPORATION - Before Lourie, Reyna, and Stoll. Appeal from the U.S. District Court for the Western District of Washington. Summary: The district court did not abuse its discretion in...more

The Patent Office Need Not Consider Requests for Director Review of IPR Institution Decisions

Summary: The USPTO policy of refusing to consider Requests for Director Rehearing of decisions denying institution of IPR and PGR does not violate the Appointments Clause of the Constitution....more

Claim Limitation Not Disclosed by Any Reference but Disclosed by “Proposed Combination” of References Is Obvious

HOYT AUGUSTUS FLEMING V. CIRRUS DESIGN CORPORATION - Before Lourie, Hughes, and Stoll. Appeal from the Patent Trial and Appeal Board. Summary: A claim is obvious where “the proposed combination of [the...more

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