CAPE TOWN, SOUTH AFRICA – A project to assess the impact of climate change on KhoiSan communities and the production of local level decision-making in rural communities is expected to contribute towards the guidelines and protections for indigenous kno…Continue Reading ...
But how could Einstein have foreseen the computerised processing of Big Data?Covent Garden, London-based Aistemos is one of a number of companies providing services and expertise in the field of patent analytics. Its objective is to organise …Continue Reading ...
The case –THE DOW CHEMICAL COMPANY v. NOVA CHEMICALS
CORPORATION — illustrates what can happen when there is an
intervening change in law. In law school, one learns of
the Schooner Peggy case in which the Chief Justice wrote that
appellate courts were obligated to apply the law as
it currently exists, including changes intervening between the time of trial and
final resolution of the appeal,
Judge Dyk noted in Dow:
The Dow Chemical Company (“Dow”) filed suit
against NOVA Chemicals Corporation (Canada) and
NOVA Chemicals Inc. (Delaware) (collectively, “NOVA”),
alleging infringement of claims of U.S. Patent No.
5,847,053 (the “’053 patent”) and U.S. Patent No.
6,111,023 (the “’023 patent”). A jury found the asserted
claims to be infringed and not invalid. NOVA appealed,
and we affirmed, holding, inter alia, that the asserted
claims were not indefinite. Our mandate issued, and
NOVA’s petition for certiorari was denied by the Supreme
Court, NOVA Chems. Corp. v. Dow Chem. Co., 133 S. Ct.
544 (2012). The district court subsequently conducted a
bench trial for the supplemental damages period through
the expiration date of both patents. The district court
granted supplemental damages in the form of lost profits
and reasonable royalties and denied Dow’s request for
enhanced damages. NOVA appealed, and Dow crossappealed.
We hold that the intervening change in the law of indefiniteness
resulting from Nautilus provides an exception
to the doctrine of law of the case or issue preclusion.
In our review of the supplemental damages award, we
therefore evaluate the indefiniteness of the claims under
the Nautilus standard. In reviewing the supplemental
damages award under the Nautilus standard, we hold
that the claims are indefinite and reverse the award of
On October 21, 2005, Dow filed suit against NOVA,
alleging infringement of claims of the ’053 patent and the
’023 patent. The asserted claims of both patents cover
ethylene polymer compositions (a type of plastic) with,
inter alia, improved modulus, yield strength, impact
strength, and tear strength. These polymers can be made
into films that can be down-gauged (made thinner) without
The issue here is subtle, concerning the fact that Dow
was looking for SUPPLEMENTAL damages:
order to prevail on a claim for supplemental damages, a
patentee must establish infringement for the supplemental
damages period. If “an act that would have been
an infringement or an inducement to infringe pertains to
a patent that is shown to be invalid, there is no patent to
be infringed.” Commil USA, LLC v. Cisco Sys., Inc., 135 S.
Ct. 1920, 1929 (2015).
This rule applies to patent infringement claims. As we
explained just last year,
traditional notions of claim preclusion do not apply
when a patentee accuses new acts of infringement,
i.e., post-final judgment, in a second suit—
even where the products are the same in both
suits. Such claims are barred under general preclusion
principles only to the extent they can be
barred by issue preclusion, with its attendant limitations.
Brain Life, LLC v Elekta Inc., 746 F.3d 1045, 1056 (Fed.
Cir. 2014); see Aspex Eyewear, Inc. v. Marchon Eyewear,
Inc., 672 F.3d 1335, 1342–44 (Fed. Cir. 2012); see also,
e.g., SynQor, Inc. v. Artesyn Techs., Inc., 709 F.3d 1365,
1385–86 (considering whether intent element of induced
infringement had been shown in the supplemental damages
Here, the bulk of the supplemental damages accrued
after the Rule 54(b) judgment, and it is clear that claim
preclusion also does not apply to damages accruing after
the filing of the complaint and not the subject of the first
judgment. See note 4, supra. All supplemental damages
here accrued after the filing of the complaint.
While claim preclusion does not apply, ordinarily issue
preclusion (or law of the case) would bar relitigation
in the supplemental damages period of issues (such as
validity) that were resolved as to the earlier time periods.
18 Charles Alan Wright, Arthur R. Miller & Edward H.
Cooper, Federal Practice and Procedure § 4409 (2d ed.
2002 (“[Although] claim preclusion often cannot apply in
settings of continuing . . . conduct, . . . it may be proper to
conclude that the issues precluded by the first litigation
embrace [issues in the second] . . . .”).
As to “law of the case,”
With respect to law of the case, “[p]erhaps the most
obvious justifications for departing . . . arise when there
has been an intervening change of law outside the confines
of the particular case.” 18B Charles Alan Wright,
Arthur R. Miller & Edward H. Cooper, Federal Practice
and Procedure § 4478; see Rose Acre Farms, Inc. v. United
States, 559 F.3d 1260, 1277–78 (Fed. Cir. 2009) (holding
that intervening Supreme Court decision issued after
prior appeal rendered prior decision “obsolete,” “[g]iven
the significant change in the law”); Wopsock v. Natchees,
454 F.3d 1327, 1333 (Fed. Cir. 2006) (finding that law of
the case did not apply because “this is a case in which
there has been a change in the law”). The exception
applies even if the issue was resolved on appeal in an
earlier stage of the proceeding. Indeed, the premise of the
exception in the appellate context is that there was such
an earlier resolution. See Litton Sys., Inc. v. Honeywell
Inc., 238 F.3d 1376, 1379–81 (Fed. Cir. 2001) (revisiting
prior holding on prosecution history estoppel because
intervening en banc authority adopted a contrary approach,
noting “[w]e are aware of no decision of this court
that has applied the law of the case in the face of a relevant
change in controlling legal authority”); M
The change in law exception applies whether the
change in law occurs while the case is before the district
court or while the case is on appeal. See Spiegla, 481 F.3d
at 964 (7th Cir. 2007) (holding that defendants had not
waived challenge to holding in first appeal where issue
not raised on remand in district court or initial briefing
because intervening decision was issued after appellate
briefing); Mendenhall, 26 F.3d at 1583 (law of the case did
not apply where new decision issued while case on appeal);
Morris v. Am. Nat’l Can Corp., 988 F.2d 50, 51–53
(8th Cir. 1993) (law of the case did not apply where, after
first appeal and decision on remand by district court,
Supreme Court case changed prevailing law); Wilson, 791
F.2d at 154, 157 (exception to issue preclusion applied
where intervening decision issued while case pending
before this court).
The technical issue impacted by the Nautilus decision
The claim term at issue here provides for “a slope of
strain hardening coefficient greater than or equal to 1.3.”
’053 patent col. 16 ll. 19–20; ’023 patent col. 16 ll. 29–30.
The patents provide that the “slope of strain hardening
coefficient” (“SHC”) is calculated according to the following
SHC = (slope of strain hardening)*(I2)0.25
where I2=melt index in grams/10 minutes. ’053 patent col.
6 ll. 45–50; ’023 patent col. 7 ll. 22–28. “The SHC coefficient
is a new Dow construct, not previously known in the
art . . . .” Dow, 458 F. App’x at 918.
Strain hardening is a property wherein a material becomes
harder as it is stretched. The ’053 and ’023 patents
teach that tensile properties, including strain hardening,
may be tested using a device called the Instron Tensile
Tester. The Instron Tensile Tester subjects a sample to an
increasing load, stretching it until it breaks. The machine
measures the force, or load, applied to the sample and the
length that the sample stretches.
The measurements taken by the Instron Tensile Tester
are then plotted on a graph. The resulting curve is
called the “tensile curve” or “stress/strain curve.” On the
stress/strain curve, the force (or load) applied to the
sample is plotted on the y-axis, and the resulting elongation
(or displacement) of the sample is plotted on the xaxis.
The behavior of the material claimed by the patent
changes as it is stretched, and those changes are shown
on the stress/strain curve. A figure from the prior art
utilized in Dow’s brief illustrates a typical stress/strain
NOVA argues that the term “slope of strain hardening
coefficient,” ’053 patent col. 16 l. 19, is indefinite because
the patent fails to teach with reasonable certainty where
and how the “slope of strain hardening” should be measured.
Although the patents state that “FIG. 1 shows the
various stages of the stress/strain curve used to calculate
the slope of strain hardening,” ’053 patent col. 6 ll. 40–41;
’023 patent col. 7 ll. 18–19, the patents do not contain the
FIG. 1 referenced in those passages. Nor do the patents
include any other figure showing the stress/strain curve.
The specification of the ’053 and ’023 patents teach that
“[t]he slope of strain hardening is calculated from the
resulting tensile curve by drawing a line parallel to the
strain hardening region of the . . . stress/strain curve.”
’053 patent col. 6 ll. 27–29; ’023 patent col. 7 ll. 5–7.
At trial, Dow’s expert Dr. Hsiao testified that “one of
ordinary skill in the art would know that the slope of the
hardening curve would have to be measured at its maximum
value, which reflects the best tensile performance of
the material.” Dow, 458 F. App’x at 919. We may assume
that, as Dr. Hsiao testified and as Dow repeatedly argues,
it was known that the maximum slope should be measured.
But three methods existed to determine the maximum
slope, each providing, as Dow admits, “simply a different
way of determining the maximum slope.” Appellee’s Br. 45
(emphasis added). Dow admitted that those three methods
“all typically occur at the same place—at the end of
the curve where the maximum slope is located.” Id. We
refer to these methods as the “10% secant tangent method,”
“final slope method,” and “most linear method.”
Neither the patent claims nor the specification here
discusses the four methods or provides any guidance as to
which method should be used or even whether the possible
universe of methods is limited to these four methods.
Nor does either party argue that the prosecution history
provides any guidance. Further, Dr. Hsiao did not testify
that one of ordinary skill in the art would choose his
method over the three known methods. Indeed, he was
not even aware of the other methods at the time he did
his analysis. He admitted that he applied only his judgment
of what a person of ordinary skill would believe and
did not interview anyone or cite any references discussing
how a person at the time of the patent application would
have calculated the slope of strain hardening.
The question is whether the existence of multiple
methods leading to different results without guidance in
the patent or the prosecution history as to which method
should be used renders the claims indefinite. Before
Nautilus, a claim was not indefinite if someone skilled in
the art could arrive at a method and practice that method.
Exxon, 265 F.3d at 1379. In our previous opinion, relying
on this standard, we held that the claims were not indefinite,
holding that “the mere fact that the slope may be
measured in more than one way does not make the claims
of the patent invalid.” Dow, 458 F. App’x at 920. This was
so because Dow’s expert Dr. Hsiao, a person skilled in the
art, had developed a method for measuring maximum
slope. See id. at 919–20.
Under Nautilus this is no longer sufficient.
There was an allusion to Sandoz v. Teva:
In this respect this case is quite similar to our recent
decision in Teva, decided under the Nautilus standard. In
Teva,9 the claim limitation at issue recited the term
“molecular weight.” 789 F.3d at 1338. But there were
three relevant measures for molecular weight—peak
average molecular weight (“Mp”), number average molecular
weight (“Mn”), and weight average molecular weight
(“Mw”)—where each was calculated in a different manner
and each typically had a different value
The claims here are even more clearly indefinite than
those in Teva. Here, Dr. Hsiao’s chosen method was not
even an established method but rather one developed for
this particular case. As we held in Interval Licensing, a
claim term is indefinite if it “leave[s] the skilled artisan to
consult the ‘unpredictable vagaries of any one person’s
opinion.’” 766 F.3d at 1374 (quoting Datamize, LLC v.
Plumtree Software, Inc., 417 F.3d 1342, 1350 (Fed. Cir.
2005)).10 The claims here are invalid as indefinite, and the
award of supplemental damages must be reversed. Under
these circumstances, we need not address the crossappeal
as to enhanced damages.
link to case: http://www.cafc.uscourts.gov/sites/default/files/opinions-orders/14-1431.Opinion.8-25-2015.1.PDF
***Of a different issue in retroactive application, note PatentlyO on
the Dickstein Shapiro malpractice case:
To put this in context: Because of a 2014 Supreme Court decision, the 2006 case would have been lost anyway because, in 1993, the claims were not eligible for patenting.
And the argument worked. The district court granted a motion to dismiss for failure to state a claim, finding the subject matter ineligible on the face of the patent.
I’ll leave the merits of that to others.
What is interesting is the court’s approach to retroactive application of Alice. The issue was whether in the 2006 case, even had the firm’s alleged malpractice not caused the invalidity judgment, the claims were “invalid” under 101 then. The district court held that Alice did not change the law, but merely stated what it had always been.
link: http://patentlyo.com/hricik/2015/09/dickstein-malpractice-ineligible.htmlContinue Reading ...
Takeaway: An understanding of claim language may be aided by the written description, but one cannot import into a claim, limitations that are not part of the claim. In its Final Written Decision, the Board held that claims 1-19 of … Continue reading →Continue Reading ...
Chris Versace (with a position at New Jersey City University (NJCU)) criticizes pharma industry proposals on IPRs, without mentioning the forays of Kyle Bass:
According to a Politico report, “The drug industry is circulating a sign-on letter to build support for exempting drugs from a streamlined patent challenge process, a key issue stalling the House’s Innovation Act.” Given the growing target market that is domestic aging population and the critical nature of drug patent life, it is hardly surprising to learn the pharmaceutical industry has deployed lobbyists to add a last minute provision that would scale back the Inter Partes Review (IPR), a process that allows an efficient way to challenge illegitimate patents.
Link from Newsmax.com http://www.newsmax.com/Finance/ChrisVersace/Health-Care-Lobbyists-Patent-Provision/2015/08/30/id/672679/#ixzz3kOvUv3cE
IAM covered the issue in July 2015, noting:
During mark-up of the PATENT Act last month, Senator Schumer admitted that work still needed to be done on the legislation to win the support of the life sciences community, as he insisted that “the IPR package will get further refinement”. But the AARP letter demonstrates the complex web of competing interests that has been woven around the subject. In its concluding remarks against the exemption the letter added: “We ask the Committee to fully consider the implications of any such exemption in terms of increased spending for payers, including Medicare and Medicaid, and higher prices for consumers. It would be unfortunate if this issue was to impede progress of the larger patent reform effort.”
As if to underline the point being made, earlier this month the Center for Economic and Policy Research produced a paper entitled The Impact of Exempting the Pharmaceutical Industry from Patent Reviews. It concluded:
… the failure to remove improperly awarded patents at an early date could lead to substantially higher drug costs. These costs will translate into higher payments from government run health insurance programs like Medicare and Medicaid.
The improper award of patents is also likely to lead to misdirected research, potentially wasting billions of dollars in spending in pursuit of patent rents based on the improperly awarded patents. In addition, these patents will provide incentives to mismarket drugs, a process that has led to substantial costs in the form of increased morbidity and increased mortality in the past. This analysis suggests that there could be substantial costs associated with exempting the pharmaceutical industry from the IPR process.
Undermining pharma’s ability to raise drug prices and bringing down the cost of medications overall is one of the motivations that Bass has claimed is behind his IPR strategy. Those arguments carry a lot more weight when they come from an organisation like AARP and take on tangible form for legislators when converted into dollar estimates of how much more consumers and government agencies might have to pay should a pharma IPR exemption be created. A vote on the Innovation Act in the House of Representatives might happen as early as this week. But it still looks like we’re some way from a reform package reaching the President’s desk.
link to the paper The Impact of Exempting the
from Patent Reviews by Dean Baker:
Yes the Baker paper mentions the Smucker patent: The ease of getting
a patent was famously demonstrated in 1997 when two inventors were able to get a patent on a
peanut butter and jelly sandwich
As to the impact on research:
The above discussion only dealt with the potential impact of improperly granted patents, due to the
pharmaceutical industry’s exemption from the IPR process, on higher drug prices. However, if a
pharmaceutical company is wrongly granted a patent which turns out to be central in the production
of a major selling drug, then it can be expected that it will also lead to a major distortion in research
spending. Other pharmaceutical companies will try to gain a share of the patent rents by attempting
to innovate around the wrongly issued patent. This can lead to large amounts of money being
To be clear, in the case where a pharmaceutical company has a valid patent, this sort of innovation is
beneficial since it can bring down the price of the drug before the patent expires and generics can
enter the market. This appears to be happening in the case of Sovaldi, the Hepatitis C drug. There
are several pharmaceutical companies developing comparable products which either have already
gained FDA approval or are likely to do so in the near future.
However, if the initial patent was wrongly granted, then this research will have been largely wasted.
The drug should have already have been available as a generic, and therefore there would be no
patent rents to be shared.19 This misdirection of research is an important cost associated with
improperly granted patents. If the pharmaceutical industry’s exemption from IPR increases the
probability of improperly awarded patents, then we should expect more misdirected research as a
One notes that the bulk of money to bring a drug to market is in running the trials, not in getting a patent on the drug.
Baker received his B.A. from Swarthmore College and his Ph.D. in Economics from the University of Michigan.Continue Reading ...
Protecting intellectual property rights in the fashion industry can be a tricky exercise in this fast-moving environment. Several avenues are possible for fashion designers in the United States, such as trademark, trade dress or design patents.Perkins Coie IP litigation partner Ann Schofield Baker, based in New York, participated in an interview with Intellectual Property Watch’s Catherine Saez on ways fashion designers can protect and enforce their rights in the US.Continue Reading ...
The Department of Justice and Constitutional Development invites the public to comment on the draft Cybercrimes and Cybersecurity Bill. A discussion document on the bill is contained here.According to The Department of Justice and Constitutional D…Continue Reading ...
Martha Teichner did the cover story on New Orleans afterKatrina. Ended with a “then and now” on threePeople.August 30, 1901. Vacuum cleaner.Hubert Cecil Booth.In 2002, Sunday Morning covered a vacuum cleaner collector convention with Bill Geist.As …Continue Reading ...
The Wall Street Journal noted:After working at a string of Chinese and U.S. technology jobs, Mr. Zeng landed at Machine Zone in late 2014, according to his LinkedIn profile. The Palo Alto, Calif., firm produces Game of War, an online medieval videogame…Continue Reading ...
From the Washington Times:
Ronald Reagan’s former attorney general Edwin Meese has joined a growing number of conservatives urging Congress not to pass proposed legislation changing America’s patent system.
link: http://www.washingtontimes.com/news/2015/aug/27/edwin-meese-reagans-ag-joins-fight-against-patent-/Continue Reading ...
Judge Newman began the opinion:
Inline Plastics Corporation sued EasyPak, LLC for infringement
of United States Patent No. 7,118,003 (the
’003 patent) and No. 7,073,680 (the ’680 patent), directed
to tamper-resistant plastic food containers. Following the
district court’s claim construction, Inline moved for entry
of final judgment of non-infringement of its ’003 patent,
on the premise that the claims as construed are not
infringed. Inline also granted EasyPak a covenant not to
sue on the ’680 patent. The district court then entered
final judgment of non-infringement of the ’003 patent,
dismissed without prejudice EasyPak’s declaratory judgment
counterclaims for invalidity, and dismissed Inline’s
count for infringement of the ’680 patent with prejudice.1
Inline appeals the district court’s construction of the
claims of the ’003 patent, stating that the terms “frangible
section” and “tamper evident bridge” were incorrectly
construed. We conclude that, on the facts and specification
of the ’003 patent, the district court erred in limiting
the claims to a specific embodiment, for the invention as
claimed is supported by the patent’s broader disclosure.
We vacate the judgment of non-infringement of the ’003
patent, and remand for determination of infringement in
accordance with the corrected claim construction.
The argument of Inline:
Applying these criteria, Inline argues that “frangible
section” was incorrectly construed as requiring at least
two score lines at the hinge. Inline states that “frangible
section” should be construed to mean a “section of material
that includes at least one score line or at least one
perforation line.” Inline points out that nothing in the
specification, the prosecution history, or the prior art
limits “frangible section” by the number of score lines by
which the frangible section is severed.
Despite this explicit disclosure of an alternative single
score line, the district court limited “frangible section” to
require at least two score lines. No prior art or prosecution
argument underlays this limitation. The district
court referred only to the frequency with which the specification
described the frangible section as having two
score lines that form a severable strip.
Here, the preferred embodiment is not described as
having certain unique characteristics of patentable distinction
from other disclosed embodiments. Nor are other
embodiments inadequately described in relation to the
principles of the invention. Absent such traditional
aspects of restrictive claim construction, the patentee is
entitled to claim scope commensurate with the invention
that is described in the specification. See Phillips v. AWH
Corp., 415 F.3d 1303, 1313 (Fed. Cir. 2005) (“[A]lthough
the specification often describes very specific embodiments
of the invention, we have repeatedly warned
against confining the claims to those embodiments.”).
The patent examiner placed no emphasis on the number
of severable lines. In allowing the claims, the examiner
explained: “The container also includes a tamper
evident feature, such as a tear strip, connecting the cover
portion to the base portion.” App. No. 10/895,687, Final
Rejection 2 (June 19, 2006). There is no discussion in the
specification or the prosecution history of any patentability
reliance on the number of score lines by which the
frangible section is severed
The bottom line
Thus we correct the district court’s claim construction,
and construe “frangible section” to mean “a section of
material that includes at least one score line or at least
one perforation line.”
We have corrected the claim construction, whereby
claims 1 and 2 are not restricted to the presence of at
least two score lines or perforation lines. On this claim
construction, the judgment of non-infringement of the ’003
patent cannot stand. We vacate that judgment,
link: http://www.cafc.uscourts.gov/sites/default/files/opinions-orders/14-1305.Opinion.8-24-2015.1.PDFContinue Reading ...
Indiana Wesleyan University has revoked the Ph.D. of former Little Rock schools superintendent Dexter Suggs, presumably related to the copying without attribution in the thesis of Suggs.See the report in the Washington Times:http://www.washingtontimes….Continue Reading ...
Takeaway: In absence of any evidence of prejudice, the Board may allow a party to correct a clerical error by filing a paper “out-of-time.” In its Order, the Board granted Petitioner’s Motion to Correct a Clerical Mistake Regarding Petition for … Continue reading →
The post Petitioner Allowed To Correct Clerical Mistake Of Submitting Unexecuted Declaration IPR2015-01332 appeared first on PTAB Trial Blog.Continue Reading ...
Takeaway: In determining whether to deny institution of an IPR petition under 35 U.S.C. § 325(d), the Board will focus on whether a later petition presents the same or substantially the same prior art or arguments, not whether the later … Continue reading →Continue Reading ...
In a story about Hyperloop Transportation Technologies, a firm founded by Tesla CEO Elon Musk, Forbes alludes to a 1799 patent:
The earliest example of a patent for a pneumatic transport system reaches all the way back to 1799. A patent for “conveyance of goods and passengers by air” was awarded to George Medhurst in the 18th century, laying the foundation for the work on the Hyperloop project.
link: http://www.forbes.com/sites/basilmoftah/2015/08/31/will-the-hyperloop-spark-a-patent-revolution/Continue Reading ...
An annual report on the digital economy from the economic organisation of the world’s richest countries measures innovation by how many patents, designs and trademarks were filed by businesses.Continue Reading ...
By: Robert R. Sachs In my July post, I noted that Section 101 court decisions were issuing fast and furious, with twelve decisions in just the first ten days. I predicted that "At this pace, we could see some twenty to thirty decisions this month." Sadly, I was spot on: there were 21 decisions, with 17 of those (81%) invalidating 36 patents. With those cases, and the cases through August 26, these are the current #AliceStorm numbers: Compared to the last numbers from July, the invalidity decision rate is up a tick, patent invalidity percentage is essentially unchanged, and claims…Continue Reading ...
A press release on August 7, 2014 noted: Intercontinental Exchange (NYSE:ICE), the leading global network of exchanges and clearing houses, announced today that it has acquired intellectual property rights that relate to computerized trading strategies. The acquired intellectual property rights include U.S. Patent Numbers 7,177,833; 7,251,629; 8,498,923; 8,478,687; 8,660,940; 8,732,048; 8,725,621 and various related pending U.S. Patent Applications. Terms of the transaction were not disclosed.
US 7,177,833, first assigned to Edge Capture, LLC (Woodstock, IL) , first inventor Marynowski
US 7,251,629, first assigned to Edge Capture
US 8,498,923, first assigned to Edge Capture
US 8,478,687, first assigned to Edge Capture
US 8,660,940, first assigned to Edge Capture
US 8,732,048, first assigned to Edge Capture
US 8,725,621, first assigned to DCFB LLC (Chicago, IL)
About one year later, Bloomberg reported
Intercontinental Exchange Inc., owner of the New York Stock Exchange and some of the world’s biggest derivatives markets, is setting up a clash with customers with its plan to generate income by licensing patents and boosting market-data fees.
The company has asked its biggest customers what they’re willing to pay for licenses to trading-technology patents it bought a year ago, according to executives at four different trading firms who asked not to be named because the discussions are private. ICE proposed to one company that it would waive the licensing fee if it directed stock transactions to the NYSE, which has seen its share of the equities business dwindle, instead of rival exchanges, an executive at the trading firm said.
**Continue Reading ...
Recall Edge Capture LLC et al. v. Lehman Brothers Holdings Inc. et al., case no. 1:08-cv-02412, in the U.S. District Court for the Northern District of Illinois.
The first published claim:An isolated bacterial cell of a photoautotrophic species, comprising a recombinant polynucleotide encoding a galactose transporter protein, wherein expression of the galactose transporter protein results in transport of glucos…Continue Reading ...