Fresh From the Bench: Latest Federal Circuit Court Case

CASE OF THE WEEK

University of Massachusetts v. L’Oréal S.A., Appeal No. 2021-1969 (Fed. Cir. June 13, 2022)

In an appeal from the U.S. District Court for the District of Delaware, the Federal Circuit addressed (1) whether the district court relied on the proper claim construction to arrive at its indefiniteness conclusion; and (2) whether UMass was entitled to jurisdictional discovery before the district court granted a motion to dismiss based on lack of personal jurisdiction. The Federal Circuit overruled the district court on both rulings, vacating the indefiniteness ruling and the dismissal without jurisdictional discovery.

UMass’s patents at issue, both titled “Treatment of Skin with Adenosine or Adenosine Analog,” describe methods for enhancing the condition of non-diseased skin by topical application of compositions containing a naturally occurring nucleoside called adenosine.

Read more.

By Mario Delegato

Edited by Nika Aldrich and Scott D. Eads, Schwabe Williamson & Wyatt