Ariad Pharmaceuticals v. Eli Lilly — Federal Circuit En Banc Reaffirms Written Description as Separate Patent Requirement
The Federal Circuit sitting en banc held that 35 U.S.C. § 112 contains a written description requirement that is distinct from the enablement requirement, and invalidated a broad genus patent covering all substances that inhibit NF-κB activity because the patent described the goal but not the means.