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Apportionment of Trade Secret Damages: Will Phillips 66 Ask A Six Hundred Million Dollar Question?

In a trade secret misappropriation action, a complainant is required to prove the amount of its damages with reasonable certainty and that this amount has been caused by the misappropriation. Therefore, the trade secret...more

FDA Expands Practice of Permitting Population-Based Skinny Label “Carve-Ins”

FDA recently doubled down on its approach of allowing new language in an ANDA label as the result of a section viii statement – a so-called “carve-in.” Section viii statements assert that an ANDA does not seek approval for...more

Preliminarily Enjoin Alleged Trade Secret Misappropriation Without Addressing A Time Bar Defense under the DTSA?

A trade secret owner must file a civil action under the Defend Trade Secrets Act (“DTSA”) within three years of when the alleged trade secret misappropriation “is discovered or by the exercise of reasonable diligence should...more

Re-Evaluating Trade Secret Policies After FTC Adopts Rule Banning Non-Compete Agreements

Today, the U.S. Federal Trade Commission (“FTC”) adopted a final rule (3-2) banning new non-compete agreements for both senior executives and non-senior executives. Companies may continue to enforce existing non-compete...more

Vanda Strikes Out at the Supreme Court

Two weeks ago we discussed Vanda Pharmaceuticals’ ambitious cert petition asking the Supreme Court to discontinue the “reasonable expectation of success” standard for patent obviousness that for decades has been a mainstay of...more

Vanda Swings for the Fences and Asks the Supreme Court to Heighten the Standard for Obviousness

Among the most established standards in patent law is that obviousness requires a motivation to combine the prior art with “a reasonable expectation of success.” The Federal Circuit alone has employed the “reasonable...more

A Rare Bird? TriZetto Collects $14.5M in Attorneys' Fees but No Trade Secret Damages

A claimant's recovery of attorneys' fees in a trade secret action ordinarily reflects an overwhelming success at trial. The claimant would have necessarily proved (at least under federal law) that its trade secret had been...more

Puma and the Pitfalls of the “Narrow” Exclusive License

8 Puma Biotechnology is the latest victim of standing requirements in patent cases that continue to wreak havoc on plaintiffs’ ability to recover a full measure of damages. In Puma Biotechnology, Inc. v. AstraZeneca...more

Over-Sweetening the Pot? When Selling a Product Bars Patenting the Manufacturing Process Under the AIA

The America Invents Act ("AIA") bars a person from obtaining a patent when the “claimed invention” had been “on sale” more than one year before the filing date of the patent. 35 U.S.C. § 102(a)(1). Acesulfame potassium...more

Recognizing Risk: When Pursuing A Competitive Edge Creates Exposure to Trade Secret Claims

A well-known idiom - widely credited to Ben Franklin in the 1700s - is that an ounce of prevention is worth a pound of cure. Yet, few companies actively train their personnel to recognize the risk of a trade secret...more

Reading Tea Leaves: Oral Arguments in Motorola v. Hytera and the Extraterritorial Reach of the DTSA

Last week, the Seventh Circuit heard arguments in Motorola Solutions, Inc. v. Hytera Communications Corp. concerning when, if at all, civil claims under the Defend Trade Secrets Act (“DTSA”) may extend to extraterritorial...more

Motorola v. Hytera: Seventh Circuit Set to Hear Arguments on the Extraterritorial Reach of DTSA

On December 5, the Seventh Circuit in Motorola Solutions, Inc. v. Hytera Communications Corp. will hear high-stakes arguments concerning the application of the federal Defend Trade Secrets Act (“DTSA”) to trade secrets taken...more

The Federal Circuit Spins a Yarn

The Federal Circuit's decision on claim construction, Barrday, Inc. v. Lincoln Fabrics, Inc., 2023-1903, 2023 WL 7871688 (Fed. Cir. Nov. 16, 2023), takes a dizzy dive into the age-old question of when a claim should be...more

Trade Secrets, ET, and the ITC

The U.S. International Trade Commission (ITC) has broad power to issue exclusion orders blocking the importation of goods determined to have infringed or misappropriated complainants' IP rights. Moreover, the ITC’s in rem...more

No Voluntarily Delistings or Disputes in FDA's Orange Book Update

FTC recently placed improper Orange Book patent listings squarely in its crosshairs. In its September 2023 policy statement, FTC announced that it would “scrutinize improper Orange Book listings” and “use its full legal...more

A Mirage or An Oasis? Avoided R&D Costs Under The DTSA

The U.S. Supreme Court recently denied a trade secret owner's petition for certiorari in Trizetto Group, Inc. v. Syntel Sterling Best Shores Mauritius Limited. This leaves unresolved a question of when a wrongdoer's avoided...more

Failing the Litmus Test? Weighing the Extrinsic Evidence in Construing "a pH of 13 or higher"

The Federal Circuit's claim construction gospel set forth in Phillips has been entrenched in the minds of patent litigators for nearly 20 years.1 The intrinsic evidence - the claims, specification, and prosecution history -...more

Appian Reimagines The High-Low to Preserve $500M-$2B in Trade Secret Damages

As the calendar turns to November, a “high-low” (at least here in the basketball capital of the world) usually refers to a basketball play where one player at the high post passes the ball to a second player at the low post...more

The Five Eyes Stare Down Trade Secret Theft

On Sunday evening, CBS's 60 Minutes aired a segment featuring “The Five Eyes” and the critical issue of state-sponsored intellectual property ("IP") and trade secret theft. While geopolitics and national security issues might...more

Axinn IP Update: Federal Circuit Applies Lead Compound Analysis and Confirms Obviousness of Deuterated Derivatives of Ruxolitinib

On August 22, 2023, the Federal Circuit affirmed an IPR Final Written Decision holding claims to deuterated derivatives of ruxolitinib unpatentable as obvious and rejected the patentee’s argument that a skilled artisan would...more

Axinn IP Update: District of Delaware Magistrate Judge Recommends Dismissal of Claims of Induced Infringement in Skinny Label Case

In the first decision to issue following the Supreme Court’s denial of certiorari in Teva Pharms. USA, Inc. v. GlaxoSmithKline, LLC, 22-37, Magistrate Judge Sherry R. Fallon of the United States District Court for the...more

Axinn IP Update: Supreme Court Denies Cert. in Skinny Label Case, but the Impacts from GSK v. Teva Continue

Yesterday, the Supreme Court denied certiorari in Teva Pharms. USA, Inc. v. GlaxoSmithKline, LLC, 22-37, locking in the Federal Circuit’s second panel decision (hereafter “GSK v. Teva”), which held that Teva’s attempted...more

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