Ariad Pharmaceuticals, Inc. v. Eli Lilly & Co.
United States Court of Appeals for the Federal Circuit
598 F.3d 1336 (2010)
- Written by Angela Patrick, JD
Facts
Ariad Pharmaceuticals, Inc. (Ariad) (plaintiff) obtained a patent containing a genus claim, which is a claim covering a broad category of inventions. This patent hypothesized that artificially reducing a naturally occurring molecule called NF-kB could alleviate the symptoms of certain human diseases. The patent’s claims covered any materials that reduced NF-kB activity using a certain function: reducing NF-kB binding at NF-kB recognition sites. The patent focused entirely on this result and did not describe a material or class of materials that performed this function. At most, Ariad hypothesized that three general categories of molecules might help achieve the binding-reduction result. Eli Lilly & Co. (Eli Lilly) (defendant) manufactured two drugs that reduced NF-kB activity. Ariad sued Eli Lilly, alleging patent infringement. The district court entered judgment for Ariad. A panel of the United States Court of Appeals for the Federal Circuit reversed, holding that Ariad’s patent was invalid because it lacked an adequate written description. Ariad complained that a patent claim needed to provide only an enabling description, which Ariad’s patent claim provided, and not a written description of the invention itself. The Federal Circuit agreed to rehear the matter en banc.
Rule of Law
Issue
Holding and Reasoning (Lourie, J.)
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