Edmonds Institute v. Bruce Babbitt, Secretary of the Interior
United States District Court for the District of Columbia
93 F. Supp. 2d 63 (2000)

- Written by Kelli Lanski, JD
Facts
The United States entered into a cooperative research and development agreement (CRADA) with Diversa Corporation. The CRADA allowed Diversa to conduct bioprospecting research at Yellowstone National Park (Yellowstone) in exchange for paying an annual fee and royalties from any commercial use derived from the bioprospecting activities. The Edmonds Institute (Edmonds) (plaintiff) was a nonprofit public-interest organization that advocated for the protection of biodiversity. Edmonds and two other organizations sued Secretary of the Interior Bruce Babbitt (defendant) and the director of the United States National Park Service. Edmonds alleged that the CRADA violated the Federal Technology Transfer Act of 1986 (FTTA), a law created to improve access to federal laboratories by nonfederal organizations, including for research supporting commercial activities. Edmonds argued that Yellowstone was not a laboratory as defined under the FTTA and therefore the act prohibited the CRADA’s commercial activities and royalty structure. Babbitt argued that a substantial portion of Yellowstone’s work and employee base was devoted to research, with over 40 employees focused on research specifically, and that the FTTA did not require that an entire facility be devoted to research to be considered a laboratory. Both parties filed motions for summary judgment.
Rule of Law
Issue
Holding and Reasoning (Lamberth, J.)
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