In Novartis Pharmaceuticals Corp. v. Torrent Pharma Inc., the US Court of Appeals for the Federal Circuit reversed the US District Court for the District of Delaware’s judgement of invalidity, holding that Section 112’s written description does not require an inventor to show possession of and describe unclaimed, after-arising technology.
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Section 112 Written Description Does Not Require Possession of Unclaimed, After-Arising Technology: Federal Circuit
