• By Michael Borella

    Federal Circuit SealUniloc, owner of U.S. Patent No. 6,993,049, brought an action for infringement of that patent against LG in the Northern District of California.  The District Court granted LG's motion to dismiss on the pleadings, agreeing with LG that the claims were directed to patent-ineligible subject matter under 35 U.S.C. § 101.  Uniloc appealed.

    The patented technology relates to Bluetooth-enabled and similar networks.  These networks involve a primary station and at least one secondary station that form ad hoc networks (piconets) with one another.  Joining such a network involves an inquiry procedure, in which primary stations identify secondary stations and the secondary stations can request to join the piconet, and a page procedure, in which a primary station can invite the secondary stations to join the piconet.  According to the patent, "it can take several tens of seconds to complete the inquiry and page procedures so that a device joins a piconet and is able to transfer user input to the primary station."

    Further, secondary stations can be battery operated, and may enter a low-power "park" mode by stopping active communication with the primary station.  A parked station must be polled in order to restore its ability to communicate with the primary station.  This polling process may also take several tens of seconds.

    The patent explains that this delay can be reduced by adding a data field for polling as part of the inquiry message.  This allows inquiries and polls to occur simultaneously for a parked station, thereby reducing the polling delays.

    At issue was claim 2 of the patent, which recites:

    A primary station for use in a communications system comprising at least one secondary station, wherein means are provided
        for broadcasting a series of inquiry messages, each in the form of a plurality of predetermined data fields arranged according to a first communications protocol, and
        for adding to each inquiry message prior to transmission an additional data field for polling at least one secondary station.

    In Alice Corp. v. CLS Bank Int'l, the Supreme Court set forth a two-part test to determine whether claims are directed to patent-eligible subject matter under § 101.  One must first decide whether the claim at hand involves a judicially-excluded law of nature, a natural phenomenon, or an abstract idea.  If so, then one must further decide whether any element or combination of elements in the claim is sufficient to ensure that the claim amounts to significantly more than the judicial exclusion.  But elements or combinations of elements that are well-understood, routine, and conventional will not lift the claim over the § 101 hurdle.  While this inquiry is generally carried out as a matter of law, factual issues can come into play when determining whether something is well-understood, routine, and conventional.

    Notably, the proper application of this test has been inconsistently defined and is confusing in practice.  A potentially more workable definition is that a claim is directed to an abstract idea if all of its elements are either non-specific, address a non-technical problem, or known in the art.  Thus, in order for a claim to be successful under § 101, it should have three qualities:  specificity, a technical problem that it solves, and some degree of novelty.

    In any event, the District Court found claim 2 ineligible because of its allegedly being "directed to the abstract idea of additional polling in a wireless communication system."  The District Court found the claim to be analogous to those that failed the § 101 test in Two-Way Media Ltd. v. Comcast Cable Communications and Digitech Image Technologies, LLC v. Electronics for Imaging, Inc.

    The Federal Circuit began its analysis by observing that the § 101 inquiry "often turns on whether the claims focus on specific asserted improvements in computer capabilities or . . . an abstract idea for which computers are invoked merely as a tool."  The Court went on to reiterate a point that it has made in a number of previous cases, that software claims can be eligible when "they are directed to improvements to the functionality of a computer or network platform itself."

    Here, the Court rapidly concluded that this was the case for claim 2, as the claimed invention involves "the reduction of latency experienced by parked secondary stations in communication systems."  Notably, the additional data field facilitates this improvement and changes the normal operation of the communication itself "to overcome a problem specifically arising in the realm of computer networks."

    LG did not dispute that the invention provided this improvement.  Instead, it contended that the claims did not focus specifically enough on the improvement, and instead used "result-based functional language."  LG also relied on the aforementioned Two-Way Media and Digitech cases.

    The Federal Circuit disagreed.  It explained that the claims in Two-Way Media and Digitech were found lacking because the claim language did not include the purported technical advances described in their respective specifications.  In contrast, the Court found that claim 2 changed "the manner of transmitting data [to result] in reduced response time by peripheral devices which are part of the claimed system."

    The Court also stated that:

    To the extent LG argues that the claims themselves must expressly mention the reduced latency achieved by the claimed system, LG is in error.  Claims need not articulate the advantages of the claimed combinations to be eligible.

    Further, the Court also made some general statements about software patent eligibility:

    The claimed invention's compatibility with conventional communication systems does not render it abstract.  Nor does the fact that the improvement is not defined by reference to "physical" components.  . . .  Our precedent is clear that software can make patent-eligible improvements to computer technology, and related claims are eligible as long as they are directed to non-abstract improvements to the functionality of a computer or network platform itself.

    For these reasons, the Federal Circuit ruled that claim 2 met the requirements of § 101 and passed the first part of the Alice test.  Therefore, the second part of the test need not be carried out.

    Uniloc USA, Inc. v. LG Electronics USA, Inc. (Fed. Cir. 2020)
    Panel: Circuit Judges Moore, Reyna, and Taranto
    Opinion by Circuit Judge Moore

  • By Kevin E. Noonan

    Federal Circuit SealThe Federal Circuit continued its explication of the standing issue for unsuccessful petitioners in inter partes review (see "Argentum Pharmaceuticals LLC v. Novartis Pharmaceuticals Corp. (Fed. Cir. 2020)") in Pfizer Inc. v. Chugai Pharmaceuticals Co.

    The case arose over IPRs initiated by Pfizer against Chugai's U.S. Patent Nos. 7,332,289 and 7,927,815.  The patents were directed to protein purification methods that removed nucleic acid (DNA) contaminants.  Pfizer successfully petitioned, but the Patent Trial and Appeal Board (PTAB) in a Final Written Decision held that the challenger had not proved any of the '289 (1-8 and 13) or '815 (1-7, 12, and 13) claims had been improvidently granted.

    The Federal Circuit dismissed Pfizer's appeal based on lack of Article III standing, in an opinion by Judge Bryson, joined by Chief Judge Prost and Judge Dyk.  The opinion sets forth the uneven playing field in IPRs, where anyone (but the patent holder) has standing to file a petition to initiate an IPR (even if the challenger fails to have Article III standing), citing JTEKT Corp. v. GKN Auto. LTD., 898 F.3d 1217, 1219 (Fed. Cir. 2018), and Fisher & Paykel Healthcare Ltd. v. ResMed Ltd., 789 F. App'x 877, 878 (Fed. Cir. 2019).  However, an unsuccessful challenger, as Pfizer here, must satisfy the requirements for Article III standing in order to be able to bring an appeal, the court relying on JTEKT Corp. and Consumer Watchdog v. Wisconsin Alumni Research Foundation.

    The opinion sets forth the requirements for standing:  that the putative appellant has "(1) suffered an injury in fact, (2) that is fairly traceable to the challenged conduct of the defendant, and (3) that is likely to be redressed by a favorable judicial decision," citing Spokeo, Inc. v. Robins, 136 S. Ct. 1540, 1547 (2016).  The panel notes, however, that Congress can accord a procedural right to appeal an administrative agency decision, and in those cases "certain requirements of standing—namely immediacy and redressability, as well as prudential aspects that are not part of Article III—may be relaxed," citing, via Consumer WatchdogMassachusetts v. EPA, 549 U.S. 497, 517–18 (2007).

    Regardless, however, "[a] party invoking federal jurisdiction must have 'a personal stake in the outcome'" in order to meet the injury in fact requirement, the opinion citing (again via Consumer Watchdog), City of Los Angeles v. Lyons, 461 U.S. 95, 101 (1983).  Important to the panel's decision, this personal interest must exist "at all stages of review," inter alia at the time an appeal is brought and an adjudication commences under Vanda Pharm. Inc. v. W. Ward Pharm. Int'l Ltd., 887 F.3d 1117, 1125 (Fed. Cir. 2018), and Momenta Pharm., Inc. v. Bristol-Myers Squibb Co., 915 F.3d 764, 770 (Fed. Cir. 2019).  And where an appellant is not currently practicing activities that could raise infringement liability, standing can still be had if the party shows "that it has concrete plans for future activity that creates a substantial risk of future infringement or would likely cause the patentee to assert a claim of infringement," citing JTEKT.  Finally, with regard to the legal requirements for establishing standing, the party seeking judicial review bears the burden, citing Phigenix, Inc. v. Immunogen, Inc.

    In this case, the Court held that Pfizer had not met this burden.  Pfizer argued that its required "concrete and particularized injury-in-fact" was its "purported" launch of the rituximab biosimilar Ruxience®.  Relevant to this appeal, Pfizer asserted that Genentech, owner of the rituximab biologic drug, was a wholly-owned subsidiary of the Roche Group and F. Hoffman LaRoche Ltd. was the majority owner of patent holder Chugai.  Pfizer had obtained a license from Genentech to sell its biosimilar to rituximab from Genentech in a settlement agreement, to which Chugai was not a party; accordingly, Pfizer did not get a license to Chugai's '289 or '815 patents as part of the settlement agreement.

    The panel was satisfied that Pfizer had raised the possibility of litigation under the challenged patents, but the Court notes that Pfizer had not included in any of its pleadings when the risk of infringement liability had arisen.  Pfizer filed a notice of appeal on January 30, 2019, according to the Court, but "the only evidence of standing that Pfizer has provided to this court relates to events that occurred much later in 2019" (citing specifically FDA approval of the biosimilar in July 2019 and an announcement by Pfizer in October that it would begin selling the drug in January 2020).  Because, inter alia, Pfizer could not have begun selling its product before FDA approval in July, it could not have established (because it did not yet exist) an injury-in-fact when the appeal was filed in January.  Moreover, the panel faults Pfizer for failing to "offer[] evidence that would allow us to evaluate whether it practices or intends to practice the patented methods in the course of making its biosimilar product."

    Assertions at oral argument by Pfizer's counsel that it was "self-evident to the parties" which product was at issue were unavailing, the opinion stating that "[i]t is not self-evident to the court, however, that there was standing at the outset of the appeal, or even later."  It being Pfizer's burden to establish standing, this bald assertion did not pass muster.  Pfizer relied on the e-mail address (rituximabIPR@win-ston.com), somewhat incredibly, for it quantum of self-evidence and on Chugai's use of Genentech's e-mail address on its IPR papers that its rituximab biosimilar was at issue.  Whatever significance this may have had for the parties, the Court states that it does not "tell the court anything useful about Pfizer's plans for its biosimilar, Ruxience®, as of the beginning of 2019, when this appeal began."  Almost as an aside, the opinion also states that these e-mail addresses do not "establish with sufficient likelihood that the processes used to prepare Pfizer's product would infringe Chugai's patents."

    Finally, the opinion addresses Pfizer's alleged harm by application of the IPR estoppel provisions of 35 U.S.C. § 315(e).  The Court rejected these on the grounds that the provisions cannot amount to injury-in-fact when the Court has no evidence that Pfizer "was or is engaged in any activity that would give rise to a possible infringement suit," citing AVX Corp. v. Presidio Components, Inc., 923 F.3d 1357, 1362–63 (Fed. Cir. 2019); Gen. Elec. Co. v. United Techs. Corp., 928 F.3d 1349, 1355 (Fed. Cir. 2019); and Argentum Pharm. v. Novartis Pharm. Corp., Case No. 2018-2273 (Fed. Cir. 2020).

    The Court having found no standing, it dismissed the appeal.

    Pfizer Inc. v. Chugai Pharmaceuticals Co. (Fed. Cir. 2020)
    Nonprecedential disposition
    Panel: Chief Judge Prost and Circuit Judges Bryson and Dyk
    Opinion by Circuit Judge Bryson

  • Claims Directed to Selecting Fishing Hooks for Use Are Not Patentable

    By Joseph Herndon

    Federal Circuit SealChristopher John Rudy, represented pro se, appealed from a decision of the Patent Trial and Appeal Board ("Board") affirming the rejection of claims 34, 35, 37, 38, 40, and 45–49 of U.S. Patent Application No. 07/425,360 ("the '360 application") as ineligible for patenting under 35 U.S.C. § 101.  On April 24, 2020, the U.S. Court of Appeals for the Federal Circuit issued a decision affirming the Board's conclusion.

    Mr. Rudy originally filed the '360 application on October 21, 1989, and so, somehow, it has been pending for almost 31 years!

    The application, entitled "Eyeless, Knotless, Colorable and/or Translucent/Transparent Fishing Hooks with Associatable Apparatus and Methods," has undergone a lengthy prosecution, including numerous amendments and petitions, four Board appeals, and a previous trip to the Federal Circuit, in which the Court affirmed the obviousness of all claims then on appeal.  In re Rudy, 558 F. App'x. 1011 (Fed. Cir. 2014).

    Now, claims 34, 35, 37, 38, 40, and 45–49 of the '360 application stand rejected as ineligible for patenting under 35 U.S.C. § 101.  Claims 26–33 and 54–60 stand allowed and all remaining claims of the '360 application have been cancelled by the applicant.

    Of the rejected claims, claim 34 is illustrative and recites the following:

    34.  A method for fishing comprising steps of
        (1) observing clarity of water to be fished to deter-mine whether the water is clear, stained, or muddy,
        (2) measuring light transmittance at a depth in the water where a fishing hook is to be placed, and then
        (3) selecting a colored or colorless quality of the fishing hook to be used by matching the observed water conditions ((1) and (2)) with a color or color-less quality which has been previously determined to be less attractive under said conditions than those pointed out by the following correlation for fish-attractive non-fluorescent colors:

    Image
    The Federal Circuit followed the two-step framework for assessing patent eligibility under § 101, and noted that it is not bound by the Office Guidance, which cannot modify or supplant the Supreme Court's law regarding patent eligibility.

    Thus, despite a portion of the Board's analysis being framed as a recitation of the Office Guidance, in this particular case, the Federal Circuit found that the Board's reasoning and conclusion are nevertheless fully in accord with the relevant caselaw.

    Applying the Supreme Court's two-step framework, the Federal Circuit first determined whether the claims at issue are directed to a patent-ineligible concept, such as an abstract idea or a law of nature.  The Federal Circuit found that claim 34 is directed to the abstract idea of selecting a fishing hook based on observed water conditions, which is a mental process of hook color selection based on a provided chart.

    The Federal Circuit has held in the computer context that "collecting information" and "analyzing" that information are within the realm of abstract ideas, and the Court stated that the same is true in other contexts, including the fishing context.

    The Court stated that claim 34 requires nothing more than collecting information (water clarity and light transmittance) and analyzing that information (by applying the chart included in the claim), which collectively amount to the abstract idea of selecting a fishing hook based on the observed water conditions.

    Mr. Rudy stated in his brief that "all that is required of the angler is observation, measuring, and comparison with a predetermined chart."  Mr. Rudy continued, "even a fish can distinguish and select colors . . . the fisherman can do this too."  The Federal Circuit explicitly declined "to adopt a bright-line test that mental processes capable of being performed by fish are not patent eligible," but noted that such an observation underscores the conclusion that claim 34 is directed to the abstract idea of selecting the color of a fishing hook.

    Having concluded that claim 34 is directed to the abstract idea of selecting a fishing hook based on observed water conditions, the Federal Circuit turned to step two of the inquiry and asked whether the elements of the claim, either individually or as an ordered combination, transform the nature of the claim into a patent eligible application of that abstract idea.

    In this case, the three elements of the claim (observing water clarity, measuring light transmittance, and selecting the color of the hook to be used) are each themselves abstract, being mental processes akin to data collection or analysis.  Considered as an ordered combination, these three steps merely repeat the abstract idea of selecting a fishing hook based on observed water conditions.

    The Federal Circuit made quick work here to determine that claim 34 fails to recite an inventive concept at step two of the test.

    Thus, the Board affirmed the decision by the Board that the claims on appeal are ineligible for patenting.

    In re Rudy (Fed. Cir. 2020)
    Panel: Chief Judge Prost and Circuit Judges O'Malley and Taranto
    Opinion by Circuit Judge Prost

  • By Kevin E. Noonan

    Federal Circuit SealLast week, the Federal Circuit had the occasion to address anew the requirements for standing to appeal an adverse decision of the Patent Trial and Appeal Board in an inter partes review proceeding under Article III of the Constitution, in Argentum Pharmaceuticals LLC v. Novartis Pharmaceuticals Corp.

    The appeal arose over U.S. Patent No. 9,187,405, with several parties having filed inter partes review petitions, for which the PTAB granted joinder under 35 U.S.C. § 315 (c).  These parties included Apotex Inc. and Apotex Corp. (who filed the first granted petition); Sun Pharmaceutical Industries, Ltd., Sun Pharmaceutical Industries, Inc., and Sun Pharma Global FZE (collectively, Sun); Teva Pharmaceuticals USA, Inc. and Actavis Elizabeth LLC; and Argentum Pharmaceuticals LLC.  The PTAB determined that the petitioners had not demonstrated unpatentability under 35 U.S.C. § 314(a); petitioners appealed.  However, before the Federal Circuit could render a decision, all petitioners except Argentum settled with Novartis and withdrew their appeals.

    Novartis filed a motion to dismiss Argentum's appeal, on the grounds that Argentum lacked standing.  Anyone (other than the patent holder) has standing to petition for inter partes review under the Leahy-Smith America Invents Act.  Paradoxically, petitioners who fail to establish that at least one challenged claim is invalid do not automatically have standing to appeal.  Here this was not an issue initially, because only one party to an appeal needs to have standing and it was undisputed that the other petitioners did so.  Once those unsuccessful petitioners settled, however, only Argentum remained in the appeal.  As argued by Novartis, the question of Argentum's standing was a threshold issue that the Court was required to settle before reaching the merits, citing Phigenix, Inc. v. Immunogen, Inc.

    The Federal Circuit held that Argentum did not have standing, in an opinion by Judge Moore, joined by Judges Lourie and Reyna.  The test for standing is that the putative appellant has "(1) suffered an injury in fact, (2) that is fairly traceable to the challenged conduct of the defendant, and (3) that is likely to be redressed by a favorable judicial decision," citing Spokeo, Inc. v. Robins, 136 S. Ct. 1540, 1547 (2016).  This requirement for appeals from PTAB decisions was established by the Federal Circuit in Consumer Watchdog v. Wis. Alumni Research FoundationThe quantum of injury-in-fact requires a showing that the appellant has "suffered 'an invasion of a legally protected interest' that is 'concrete and particularized' and 'actual or imminent, not conjectural or hypothetical'" the opinion states, citing Spokeo.

    Argentum argued three bases for injury-in-fact.  The first was a "reasonable and imminent threat of litigation" because it is pursuing a generic version of Novartis's Gilyena® product and was "in the process of filing an ANDA" with its manufacturing partner, KVK-Tech.  Novartis argued in response that KVK, not Argentum, would be filing any such ANDA and thus Argentum could not rely on this risk of suit for standing (and in addition litigation was conjectural because neither party had filed any such Gilyena®-targeting ANDA).  Argentum countered with the Federal Circuit's Altaire Pharmaceuticals, Inc. v. Paragon Bioteck, Inc., 889 F.3d 1274, 1282–83 (Fed. Cir. 2018), decision for the principle that an ANDA did not need to have been filed to confer standing.  The Court found Argentum's arguments "unavailing" with respect to Altaire, stating that in that case the company asserting standing was the company that planned to file the ANDA, unlike the case here.  There "the threat of litigation was 'real' and 'imminent' and Altaire was affected 'in a personal and individual way,'" according to the opinion.

    Argentum's second argument was that it would incur "significant economic injury" ("$10-50 million per year in lost profits once the FDA grants provisional approval to the ANDA; italics added) if subject to a "looming infringement action by Novartis."  Novartis responded that this argument was entirely speculative.  The Court concluded that "Argentum has not provided sufficient evidence to establish an injury in fact through economic harm," citing General Electric Co. v. United Techs. Corp., 928 F.3d 1349, 1353–54 (Fed. Cir. 2019), for analogous circumstances.  The opinion also concluded that Argentum had not established that it had an investment in KVK's generic Gilyena® product nor ANDA, characterizing Argentum's allegations as "generalities" and its assertions regarding the economic costs as "conclusory and speculative."  This, the Court held, was not "concrete and particularized" nor "actual and imminent" injury-in-fact.

    Finally (with regard to the arguments the Court entertained), Argentum argued that it would be estopped under 35 U.S.C. § 315(e) from raising patentability and validity issues should Novartis eventually sue them for infringement under 35 U.S.C. § 271(e)(2).  But Phigenix held that potential IPR estoppel was not sufficient to establish standing and thus this argument also failed to persuade the panel.

    The Court having found no standing, it dismissed the appeal, costs to Novartis.

    Argentum Pharmaceuticals LLC v. Novartis Pharmaceuticals Corp. (Fed. Cir. 2020)
    Panel: Circuit Judges Lourie, Moore, and Reyna
    Opinion by Circuit Judge Moore

  • CalendarMay 5, 2020 – "How to develop and maintain a world-class patent portfolio" (LexisNexis, PatentSight, and iam) – 10:00 am (EDT)

    May 6, 2020 – "Managing Trade Secrets During the Pandemic — Widespread Working From Home and Economic Meltdown" (Intellectual Property Owners Association) – 2:00 to 3:00 pm (ET)

    May 6, 2020 – "Marketing and selling patents in the current environment – hear from the experts" (IPBC Talking Heads, Richardson Oliver Insights, and iam) – 11:00 am (EDT)

    May 7, 2020 – "Highlights from the Field: Current IP developments in China" (U.S. Patent and Trademark Office) – 9:00 to 10:30 am (ET)

    May 7, 2020 – "Patents in the Time of COVID-19: How the Crisis is Shaping IP, Innovation, and Access to Medicine Now, and for the Future" (The Federal Circuit Bar Association) – 11:00 am to 12:00 pm (EST)

    May 7, 2020 – "Defining the PTAB: Click to Call and Windy City" (Intellectual Property Owners Association) – 1:00 pm (CDT)

  • USPTO SealThe U.S. Patent and Trademark Office will offer a one-hour webinar entitled "Highlights from the Field: Current IP developments in China" on May 7, 2020 from 9:00 to 10:30 am (ET).  Michael Mangelson, senior counsel for China IP, USPTO Office of Policy and International Affairs and former IP attaché at the U.S. Consulate, Shanghai; Duncan Willson, USPTO IP attaché at the U.S. Embassy, Beijing; and Conrad Wong, USPTO IP attaché at the U.S. Consulate, Guangzhou will offer their unique insights on the current IP environment in China, and will cover new laws and regulations, current trends, significant court and administrative rulings, and what these developments mean for U.S. rights holders looking to protect their IP.

    Those interested in registering for the webinar can do so here.

  • Federal Circuit Bar Association_2The Federal Circuit Bar Association (FCBA) will be offering a remote program entitled "Patents in the Time of COVID-19: How the Crisis is Shaping IP, Innovation, and Access to Medicine Now, and for the Future" on May 7, 2020 from 11:00 am to 12:00 pm (EST).  Ute Kilger of Boehmert & Boehmert will moderate a panel consisting of Robert DeBerardine of Johnson & Johnson, David Rosen of Foley & Lardner LLP, Corey Salsberg of Novartis, and Hans Sauer of the Biotechnology Innovation Organization (BIO).  The panel will discuss the effects of patents on the development and on the availability of new medicaments and tests in times of COVID-19.

    The webinar is complimentary for FCBA members, $25 for government/students, or $75 for private practitioners.  Those interested in registering for the program, can do so here.

  • IPO #2The Intellectual Property Owners Association (IPO) will offer a one-hour webinar entitled "Defining the PTAB: Click to Call and Windy City" on May 7, 2020 at 1:00 pm (CDT).  Gregory Castanias of Jones Day, Dennis Crouch of the University of Missouri School of Law, and Scott McKeown of Ropes & Gray LLP will untangle the complexities involving all the players including the PTAB, the Director of the U.S. Patent and Trademark Office, and the Federal Circuit, and assess who emerges as a winner and in what way.  The panel will also give an analysis of how practice could change, including:

    • What other PTAB determinations will be found to be "final and nonappealable" in addition to time bar determinations?
    • What happens to appeals that have been decided or are pending at the Federal Circuit on matters that now are no longer appealable?
    • What is the impact on proceedings involving state sovereign immunity?
    • What are the implications of the PTAB having enlarged unchecked power?
    • What is the role of the USPTO's Precedential Opinion Panel (POP)?

    The registration fee for the webinar is $135 (IPO member) or $150 (non-member) (government and academic rates are available upon request).  Those interested in registering for the webinar can do so here.

  • IAMLexisNexis, PatentSight, and iam will be offering a free webinar entitled "How to develop and maintain a world-class patent portfolio" on May 5, 2020 starting at 10:00 am (EDT).  The webinar address how leaders in academic innovation research define a world-class patent portfolio, how to implement processes in organisations to develop and maintain such a patent portfolio, and requirements for software applications that derive from these requirements, and provide examples of how smart tools can be utilised.

    Those interested in registering for the webinar, can do so here.

  • IPO #2The Intellectual Property Owners Association (IPO) will offer a one-hour webinar entitled "Managing Trade Secrets During the Pandemic — Widespread Working From Home and Economic Meltdown" on May 6, 2020, from 2:00 to 3:00 pm (ET).  Ken Corsello of IBM; Cathy Lui of Orrick Herrington & Sutcliffe; Jim Pooley, Chair of the Sedona Conference Working Group 12 on Trade Secrets; and Rachel Walsh of Goodwin Procter will provide tips and insights on basic trade secret management practices and how they can be adapted for the current environment.

    The registration fee for the webinar is $135 (IPO member) or $150 (non-member) (government and academic rates are available upon request).  Those interested in registering for the webinar can do so here.