Takeaway: The Board may exercise its discretion to deny institution of covered business method patent review where the petitioner cites different prior art references from another proceeding in which it is also a party, but the different prior art references … Continue reading →Continue Reading ...
Takeaway: The granting of an injunction in a related proceeding, without more, does not demonstrate a nexus between the claimed subject matter and the objective evidence of a secondary consideration of industry praise and acceptance. In its Final Written Decision, … Continue reading →
The post Insufficient Nexus Was Found for Secondary Considerations in Final Written Decision IPR2014-00679 appeared first on PTAB Trial Blog.Continue Reading ...
In IPR2014-00784 on US Patent 8,324,283, PTAB found claims 1–32 of US ‘283 unpatentable.
MS drugs are a big deal economically; the current market for MS drugs is worth an estimated $20 billion a year.
This oral drug for treating MS comprises a sphingosine-1
phosphate (S1P) receptor agonist and a sugar alcohol. Ex. 1001, 1:11–14,
1:33–35. “The sugar alcohol may act as a diluent, carrier, filler or bulking
agent, and may suitably be mannitol.”
We disagree, however, with Patent Owners’ argument that the
inventors’ mere discovery of a new reason to combine fingolimod and
mannitol renders nonobvious an invention that was known in the prior art.
Where the prior art teaches the claimed invention, a claim is not rendered
patentable by virtue of being motivated in the inventors’ minds by a newlydiscovered
advantage of the prior-art combination; allowing such a claim to
stand “would remove from the public that which is in the public domain.” In
re Wiseman, 596 F.2d 1019, 1022 (CCPA 1979); see also Cross Med.
Prods., Inc. v. Medtronic Sofamor Danek, Inc., 424 F.3d 1293, 1323 (Fed.
Cir. 2005) (“One of ordinary skill in the art need not see the identical
problem addressed in a prior art reference to be motivated to apply its
above, though, it does not matter that the prior art failed to recognize this
advantage of a fingolimod-mannitol combination. “[T]he motivation in the
prior art to combine the references does not have to be identical to that of the
[patentee] to establish obviousness.” In re Kemps, 97 F.3d 1427, 1430 (Fed.
Of long-felt need:
Next, Patent Owners argue that the invention claimed in claim 19
satisfied the long-felt but previously unmet need “for a solid oral [multiple
sclerosis] treatment.” PO Resp. 55 (citing Ex. 2044 ¶¶ 25–27). The
supporting evidence is a declaration stating that “some patients are resistant,
afraid, or even unwilling to use needles,” which caused some patients to
“drop the [multiple sclerosis] treatment”; that “parenteral medications were
universally inconvenient,” making patients less likely to take their
medication; and that “there were a number of side effects commonly
associated with parenteral [multiple sclerosis] treatments” that “discouraged
patients from continuing with their prescribed course[s] of treatment.”
Ex. 2044 ¶¶ 25–27. Although no other evidence is cited in Patent Owners’
briefing,21 additional record evidence shows that patients asked about the
availability of an oral medication as early as 1993, id. ¶ 34, and that the
introduction of the first oral medication in 2010 caused a “‘major shift in the
treatment landscape,’” with “‘many patients . . . switching to oral therapy,’”
id. ¶ 37 (quoting Ex. 2012, 1).
Petitioners argue, Reply 18–19, that there is no evidence that the longfelt
need was for claim 19’s combination of fingolimod and mannitol;
instead, as Patent Owners acknowledge, PO Resp. 55, the need was merely
“for a solid oral [multiple sclerosis] treatment.” According to Petitioners,
any need for a solid oral dosage form of a multiple sclerosis treatment was
satisfied by treatments that were known in the prior art but did not receive
FDA approval until after Patent Owners’ Gilenya product did. Reply 18–19.
Therefore, argue Petitioners, there was no longer any long-felt need by the
time of the invention claimed in the ’283 patent. Id
In 1999, Chiba itself suggested treating multiple
sclerosis using a solid oral form of fingolimod. Ex. 1006, 6:26–49, 8:19–26.
In addition, teriflunomide, marketed in solid tablet form as Aubagio®, was
known in the prior art at least by April 1, 2002, when it was disclosed to be
useful for treating multiple sclerosis when administered in tablets or
capsules. Ex. 1037, at , 1:19–30, 2:60–3:2, 5:1–21; Ex. 2045 ¶ 63.22
Similarly, a capsule form of dimethyl fumarate for the treatment of multiple
sclerosis, marketed as Tecfidera™, Ex. 1070, 2, was disclosed in U.S. Patent
No. 6,509,376 B1, issued January 21, 2003. Ex. 1097, at , 2:64–67,
Industry praise must be linked to the patented invention. Power-One,
Inc. v. Artesyn Techs., Inc., 599 F.3d 1343, 1352 (Fed. Cir. 2010). Again, if
objective indicia of nonobviousness are “due to an element in the prior art,
no nexus exists.” Tokai Corp., 632 F.3d at 1369. Here, the evidence shows
that what was praised about Gilenya was not the specific formulation recited
in claim 19, but rather the general fact that Gilenya was a solid oral multiple
sclerosis medication. As discussed above, however, a solid oral multiple
sclerosis formulation was known in the prior art, so there is no nexus
between the claimed invention and the industry praise.
Tysabri (natalizumab ) is mentioned
In either case, Dr. Blackburn excluded
from his analysis any data regarding sales of Tysabri, id. ¶ 20 n.24,24
multiple sclerosis drug that generates more than $1 billion in annual sales,
Ex. 1041 ¶ 38; Ex. 1057, 5–6; Ex. 1058, 37. Dr. Blackburn’s evidence of
Gilenya’s market share is biased towards more significant sales of Gilenya
by this exclusion and, thus, is unreliable as evidence that Gilenya’s sales are
significant in relation to the relevant market as a whole.
As to amendment:
Because we find each of claims 1–32 unpatentable, we next address
Patent Owners’ motion to amend, in which claims 33–64 are proposed.
Motions to amend are permitted by 35 U.S.C. § 316(d) and 37 C.F.R.
§ 42.121. In moving to amend their claims, as the moving the party, Patent
Owners have the burden to show entitlement to the relief requested. 37
C.F.R. § 42.20(c). “The burden is not on the petitioner to show [the]
unpatentability [of the proposed claims], but on the patent owner to show
patentable distinction over the prior art of record and also [the] prior art
known to the patent owner.” Idle Free Sys., Inc. v. Bergstrom, Inc., Case
IPR2012-00027, slip op. at 7 (PTAB June 11, 2013) (Paper 26)
(representative). The “prior art of record” includes “any material in the
prosecution history of the patent,” “any material art of record in the current
proceeding, including art asserted in grounds on which the Board did not
institute review,” and “any material art of record in any other proceeding
before the Office involving the patent.” MasterImage 3D, Inc. v. RealD
Inc., Case IPR2015-00040, slip op. at 2 (PTAB July 15, 2015) (Paper 42)
***Gilyena is for relapsing remitting MS [“RRMS”]. Forbes noted a possible
game changer as to primary progressive MS, with new results on ocrelizumab [by Roche / Biogen], which
is a humanized anti-CD20 monoclonal antibody, which targets mature B lymphocytes:
On Monday [28 Sept 2015], the company disclosed that its experimental multiple sclerosis treatment ocrelizumab has become the first therapy to hit the main endpoint in a large Phase III study for primary progressive MS. This form of the disease accounts for between 10% and 15% of all MS patients, but is devoid of effective therapies.
As such, ocrelizumab is looking like an increasingly significant future sales growth driver for Roche, capable of generating multi-billion dollar sales on a global basis. In June, the company announced that two Phase III studies in the more common form of relapsing remitting MS had hit their primary and key secondary endpoints. Full data from each of the late-stage trials will be presented at next month’s annual meeting of the European Committee for Treatment and Research in Multiple Sclerosis (ECTRIMS).
CD-20 immune cells are thought to be a key contributor to myelin and axonal damage in MS.
Forbes noted that ocrelizumab might compete against Tysabri in the RRMS market :
In the larger RRMS market, there is a growing consensus that ocrelizumab will gain an initial foothold in second-line patients and compete primarily with Biogen’s Tysabri. Roche’s drug offers comparable efficacy, but what appears to be a notably superior safety profile. Furthermore, while Tysabri is dosed once a month, ocrelizumab is administered twice a year.
Another monoclonal antibody for MS is alemtuzumab (Lemtrada) which binds to CD52, a protein present on the surface of mature lymphocytes,
See the story from 14 Nov. 2014 Sanofi’s Lemtrada Wins U.S. Approval to Treat MS which includes the text:
There are about 10 treatments for relapsing-remitting MS, in a market estimated at $16 billion, including Avonex made by Biogen Idec Inc. and Copaxone from Teva Pharmaceutical Industries Ltd. Multiple sclerosis, a neurological disease that can cause severe disability, affects as many as 350,000 people in the U.S. and is twice as likely to occur in women, according to the National Institute of Neurological Disorders and Stroke.
Patients receive five infusions of Lemtrada in the first year, followed by three more a year later. Data presented at a meeting in September showed that 70 percent of those involved in the key clinical trials of the drug didn’t require any additional treatment after the first two years. The drug will cost $158,000 over the two years, compared with about $135,000 for Merck KGaA’s Rebif, Sibold said.
“We could see that this would become the most cost-effective, least-expensive, highest-value product over time,” he said.Continue Reading ...
1. How much has Microsoft really changed?Fortune brings up the past use by Microsoft of third party mercenaries amounting to proxy attacks by privateers and trolls.2. Will Google still play nice with its big patent pile?Is Google now like mature comp…Continue Reading ...
The issue in In re Steed:
The principal issue on appeal is whether Steed antedated
the Evans reference in accordance with the requirements
and law implemented by Rule 131, for Steed
bears the burden to establish “facts . . . in character and
weight, as to establish reduction to practice prior to the
effective date of the reference, or conception of the invention
prior to the effective date of the reference coupled
with due diligence from prior to said date to a subsequent
reduction to practice or to the filing of the application.”
37 C.F.R. § 1.131(b). Steed argues that the Declaration
and exhibits meet the requirements of either actual
reduction to practice or conception plus diligence.
There was no waiver:
The Board held that “assertions that the claimed invention
was actually reduced to practice in December of
1997, and at the latest by August of 2000 are not set forth
in the Appeal Brief or the Reply Brief, and are thus
considered waived.” Bd. Op. at 6. We discern no such
waiver. To the contrary, the appeal briefs included well
over a hundred pages of exhibits and arguments, all
directed to actual reduction to practice. Although the
Board concluded that the evidence did not establish an
actual reduction to practice, the issue was not omitted
from the appeal briefs.
Steed’s briefs before the Board are clear that Steed
was attempting to establish conception, diligence, and
actual reduction to practice. The flaw in Steed’s proofs
was in the content of the documentary evidence, not in
any purported waiver. It is beyond debate that Steed was
attempting to swear back of Evans, and that this was the
focus of the evidence and argument presented to the
Examiner and the additional documents and affidavits
presented to the Board.
We agree that the exhibits are not self-explanatory,
and the Examiner had adequately warned the applicant,
stating in the Final Office Action that “most of the notes
included for the [year] 2000 are all notes to call people
without actually including what phone calls were being
made about and what was being accomplished with
reference to the invention” and “there are 57 months of
time unaccounted for in applicant’s attempt to show due
diligence,” among other things. Office Action, Paper No.
34 at 5–6 (March 3, 2011). In an earlier Office Action, the
Examiner stated that “Appendix A . . . does not include
any specifics of the actual invention” and “there are
significant gaps of time between each of the Appendices
A-D that amount to entire years of diligence being omitted.”
Office Action, Paper No. 17 at 3–4 (Dec. 9, 2009).
We agree with the PTO argument, on this appeal,
[T]he Board cannot be faulted for not reviewing
evidence that was not presented to it or to the Examiner.
To the extent Appellants have better
proof of an earlier actual reduction to practice or
conception date, the proper remedy is to file a continuation
application and present the evidence to
the Examiner in the first instance.
PTO Br. 24. We conclude that substantial evidence
supports the Board’s findings, and the ruling that Steed
did not establish an actual reduction to practice before the
Evans effective date of December 23, 2002. That ruling is
As to conception:
An inventor can antedate a Section 103 reference by
showing that the invention was conceived before the
effective date of the reference, with diligence to actual or
constructive reduction to practice. 37 C.F.R. § 131(b).
Conception is “the formation, in the mind of the inventor,
of a definite and permanent idea of the complete
and operative invention, as it is thereafter to be applied in
practice.” Mergenthaler v. Scudder, 11 App. D.C. 264, 276
(D.C. Cir. 1897); see Coleman v. Dines, 754 F.2d 353, 359
(Fed. Cir. 1985). The Board found that the evidence that
Steed provided did not establish conception before the
Evans effective date, and that Steed did not adequately
explain the exhibits and how they showed conception of
the claimed subject matter, or when such conception
occurred. The Board recognized that the Table “identifies
that a piece of evidence corresponds to a certain date” but
criticized the absence of evidence to “explain what fact
that piece of evidence is meant to support as having
occurred on that date.” Bd. Op. at 15.
Link: http://www.cafc.uscourts.gov/sites/default/files/opinions-orders/14-1458.Opinion.9-29-2015.1.PDFContinue Reading ...
The ratification of an international convention to fight counterfeit of medical products by Guinea has unlocked the entry into force of the instrument, now set to happen on 1 January 2016.Continue Reading ...
Various news reports discuss the unauthorized access (and likely disclosure) by Secret Service employees of an unsuccessful employment application to the Secret Service by Republican congressman Jason Chaffetz of Utah, who recently has been investigating bad acts by the Secret Service.
There are at least two aspects of the disclosure.
@1. The implication that Chaffetz is somehow “inferior” because his application was turned down.
@2. The implication that the investigations by Chaffetz of the Secret Service are payback for being turned down, and thus are not objectively based.
Both aspects are captured in the Washington Post text:
One official told The Post that the material included a parody poster that pictured Chaffetz leading a hearing on the Secret Service from his congressional dais, with the headline “Got BQA from the Service in 2003.” Within the Secret Service, “BQA” is an acronym meaning that a “better qualified applicant” was available.
Chaffetz told the AP that Homeland Security Secretary Jeh Johnson personally apologized to him. Chaffetz called the experience “intimidating,” saying: “It’s what it was supposed to be.”
As to disclosure of unsuccessful job applications, such disclosure can occur in unexpected ways.
This author learned in 2001 of a disclosure which had happened in 1987, because of an employment action taken by someone else.
Startup Act 2.0: are you turning up your nose at $150K/year jobs?
Apart from recounting the story of the Dickakian matter [ In the Matter of Exxon Chemical Company (on behalf of Dickakian), 87-INA-615 ], the post mentioned issues with a data breach at LinkedIn:
“In this job market, I’m just happy the Russians who hacked LinkedIn have my resume,” one guy tweeted.
“Okay, maybe it’s just me, but if my LinkedIn was hacked… who cares? More people will see my resume?” someone else said.
In passing, as to Chaffetz, it appears that a number of people have underestimated Chaffetz in the past. It might be that the Secret Service is the one who got it wrong in 2003.Continue Reading ...
The smartphone is one of the most ubiquitous inventions in contemporary life. Ask anyone from teenagers to senior citizens – in industrialized countries, as well as emerging markets – about the wireless ways of their life, and they will tell you this. But what is the economic impact of mobile? That is not as obvious, writes Antonio Varas.Continue Reading ...
How to Manage Intellectual Property and Patent Law By Ralf Boscheck* — International intellectual property regulations are doing serious damage to the pharmaceutical industry and, by extension, to the health of people around the world. The core of the…Continue Reading ...
Author: Shawn S. Chang Editor: Aaron Gleaton Clay In SCA Hygiene Products Aktiebolag v. First Quality Baby Products, LLC, No. 13-1564 (Fed. Cir. Sept. 18, 2015), a divided en banc Federal Circuit held in a 6-5 decision that laches remains a defense to legal relief in a patent infringement suit, notwithstanding the Supreme Court’s recent […]Continue Reading ...
The annual World Trade Organization Public Forum opened today with a plenary session on making trade work more inclusively. The Doha Round, agriculture, and environmental technologies were part of the conversation.Continue Reading ...
Takeaway: At the institution phase of a proceeding, the Board may accept the presence of a copyright notice, together with the listing of the reference in an IDS, as some evidence of public accessibility as of a particular date. In … Continue reading →Continue Reading ...
As to Congressman Chaffetz, Investors Business Daily noted:
a group of congressional Democrats sent a letter to Rep. Jason Chaffetz, chair of the House Committee on Oversight and Government Reform, requesting a subpoena to make Valeant turn over documents related to last February’s triple-digit price increases on two heart drugs, Nitropress and Isuprel.
Link to Investor’s Business Daily article, Valeant Defended After Politics-Induced Sell-Off: http://news.investors.com/technology/092915-773226-valeant-stock-seen-as-buying-opportunity.htm#ixzz3nM3pMhli
IBD was somewhat cool on the idea of Chaffetz favorably responding to Democrats, but IPBiz notes Chaffetz is a different type of chairman.
From realclearpolitics :
When Chaffetz campaigned to run the committee in the new Congress – Issa was forced to leave because of Republican term limits on chairmanships – the Utah lawmaker ran partially on a platform of taking the committee in a new, less fiery direction, promising improved relationships with Democrats. And in the first six months, the reviews of Chaffetz’s nascent tenure are positive across the board, and across the aisle.
And Chaffetz gets along well with Elijah Cummings.Continue Reading ...
The key point:
Achates contends that the Board’s decisions
were outside of the Board’s statutory authority because
the underlying petitions for IPR were time-barred under
35 U.S.C. § 315(b). As part of its appeal, Achates also
challenges the Board’s denial of Achates’ motion for
discovery. See Apple Inc. v. Achates Reference Publ’g, Inc.,
2013 WL 6514049 (P.T.A.B. Apr. 3, 2013) (“Discovery
Decision”). Because the Board’s determinations to institute
IPRs in this case are final and nonappealable under
35 U.S.C. § 314(d), this court lacks jurisdiction and dismisses
The CAFC discussed the relevant law:
Both IPR and CBMR proceed in two stages. In the
first stage, the Director determines whether to institute
IPR or CBMR. By regulation, “[t]he Board institutes the
trial on behalf of the Director.” 37 C.F.R. § 42.4; see also
37 C.F.R. §§ 42.100(a) (explaining that IPR proceedings
are subject to these trial procedures); 42.300(a) (same for
CBMR). In the second phase, the Board conducts the IPR
or CBMR proceedings on the merits and issues a final
Based on the petitions and any responses, the Board
decides whether there are sufficient grounds to institute
the proceedings—in IPR petitions there must be a “reasonable
likelihood” that the petition will prevail, 35
U.S.C. § 314(a), and in CBMR petitions it must be “more
likely than not,” 35 U.S.C. § 324(a). An IPR proceeding
“may not be instituted if the petition requesting the
proceeding is filed more than 1 year after the date on
which the petitioner, real party in interest, or privy of the
petitioner is served with a complaint alleging infringement
of the patent.” § 315(b). No analogous time-bar
exists for CBMR proceedings. IPR proceedings are not
limited to specific types of patents. On the other hand,
CBMR proceedings are only permitted “for a patent that
is a covered business method patent.” AIA § 18(a)(1)(E).
Importantly, identically worded statutory provisions
make explicit that “[t]he determination by the Director
whether to institute [IPR or CBMR] under th[ese] section[s]
shall be final and nonappealable.” See § 314(d)
and § 324(e), respectively.
If a proceeding is instituted, the Board considers the
merits and “issue[s] a final written decision with respect
to the patentability of any patent claim challenged by the
petitioner and any new claim added” during the proceedings.
35 U.S.C. §§ 318(a) (IPR), 328(a) (CBMR).
“[P]art[ies] dissatisfied with the final written decision of
the Patent Trial and Appeal Board under section[s]
[318(a) or 328(a)] may appeal the decision pursuant to
sections 141 through 144.” Id. §§ 319 (IPR), 329 (CBMR).
Sections 141 through 144 of title 35 generally explain that
Board decisions are appealable to this court. Of particular
relevance, 35 U.S.C. § 141(c) states, with emphasis
A party to an inter partes review or a post-grant
review who is dissatisfied with the final written
decision of the Patent Trial and Appeal Board under
section 318(a) or 328(a) (as the case may be)
may appeal the Board’s decision only to the United
States Court of Appeals for the Federal Circuit.
The Cuozzo case was mentioned:
This court also has considered whether the Director’s
institution decision is subject to review after a final
written decision by the Board. In In re Cuozzo Speed
Techs., LLC, 793 F.3d 1268 (Fed. Cir. 2015), the Director
instituted an IPR of certain claims relying in part on
references not cited in the petition. On appeal, Cuozzo
argued that the IPR was improperly instituted because
the petition-as-filed did not provide “a reasonable likelihood
that the petition would prevail” as required
by § 314(a). Id. at 1273. Cuozzo argued that the reviewability
prohibition of § 314(d) applied only to interlocutory
appeals, and that the initiation decision becomes available
for review once the Board issues a final written decision.
The court disagreed with Cuozzo and declined to
review the initiation decision, remarking that § 314(d) “is
not directed to precluding review only before a final
decision” and cannot be directed only to precluding interlocutory
appeals because §§ 319 and 141(c) already serve
that role. Id. The court then recognized that “the IPR
statute [does not] expressly limit the Board’s authority at
the final decision stage to the grounds alleged in the IPR
petition” and that “the failure to cite those references in
the petition provides no ground for setting aside the final
decision.” Id. at 1273 and 1274.
As to CBM review
The court first recognized the distinction between the
final merits decision and the initiation decision: “institution
and invalidation are two distinct actions.” Id. at
1319. “[I]t is the merits of the final written decision that
are on appeal; we are not here called upon to review the
determination by the [Board] whether to institute a CBM
review, and indeed [35 U.S.C. § 324(e)] expressly instructs
that we may not.” Id. at 1315. The court went on to
point out that although the issue of whether a patent is a
CBM was first determined by the Director at the initiation
stage, the same issue was necessarily implicated in
the final merits determination and was appropriate for
review because of the fundamental limitation of the
Board’s “ultimate invalidation authority” in a CBMR to
those patents that meet the CBM definition:
[O]ne of the limits on § 18 invalidation authority
is that the patent at issue be a CBM patent. . . . If
a particular patent is not a CBM patent, there is
no proper pleading that could be filed to bring it
within the [Board’s] § 18 authority.
Id. at 1320. Compare Cuozzo, 793 F.3d at 1274 (“The fact
that the petition was defective is irrelevant because a
proper petition could have been drafted.”)
Cuozzo-like arguments appear:
Just as the pleading in Cuozzo could have been sufficient by
the inclusion of the missing prior art reference, see 793
F.3d at 1274 (“The fact that the petition was defective is
irrelevant because a proper petition could have been
drafted.”), the timeliness issue here could have been
avoided if Apple’s petition had been filed a year earlier or
if a petition identical to Apple’s were filed by another
party. This is in contrast to the issue in Versata II, where
“no proper pleading  could be filed to bring it within the
[Board’s] § 18 authority.” 793 F.3d at 1320.
The words “too crabbed” appear:
Continue Reading ...
Finally, Achates also contends that § 314(d) does not
limit this court’s review of the timeliness of Apple’s petition
under § 315, because § 314(d) says “[t]he determination
by the Director whether to institute an inter partes
review under this section shall be final and nonappealable”
(emphasis added). Achates’ reading is too crabbed
and is contradicted by this court’s precedent. The words
“under this section” in § 314 modify the word “institute”
and proscribe review of the institution determination for
Takeaway: Evidence that a petition was filed for purely profit motivation and that that the petitioner does not have a competitive interest in the challenged patents is not enough to meet the burden required to grant a motion for sanctions … Continue reading →Continue Reading ...
At a panel at the World Trade Organization organised by the United States Chamber of Commerce, proponents of strong intellectual property protection explained why this protection is key in international trade, even if some might consider the minimum st…Continue Reading ...
On 29 September, the Parliamentary Assembly of the Council of Europe adopted a resolution on how to safeguard the public interest against the interests of the pharmaceutical industry.Continue Reading ...
Recent jurisprudence on the issue of divided infringement has arisen in the context of computer-related technologies, where a user or customer performs one or more steps of a patented method. Now the issue has arisen in the pharmaceutical context, where a patient self-administers a drug. In Eli Lilly and Company v. Teva Parenteral Medicines, Inc., … Continue reading this entryContinue Reading ...
Authored by K. Patrick Herman, Barry M. Greenbaum, and Brent T. Hagen Digest of Achates Reference Publ’g, Inc. v. Apple Inc., No. 2014-1767, -1788 (Fed. Cir. Sept. 30, 2015) (precedential). On appeal from P.T.A.B. Before Prost, Lourie, and Linn. Procedural … Continue reading →
The post Federal Circuit: PTAB Determination of The Timeliness of an IPR Petition is Not Appealable appeared first on CAFCBlog.com.Continue Reading ...
As government negotiators dig into perhaps the final round of the Trans-Pacific Partnership trade negotiations this week in Atlanta, they may take comfort in knowing that nothing they are doing has to be shared with the public they represent until year…Continue Reading ...
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