On February 21, 2017, the U.S. Court of Appeals for the Federal Circuit (“Federal Circuit”) issued its opinion in Secure Axcess, LLC v. PNC Bank (“PNC”), holding that, to be eligible for covered business method (“CBM”) review under the America Invents Act (“AIA”), a patent”™s claims must contain some financial activity element.

On March 21, 2017, the United States Supreme Court (“Supreme Court”) issued its opinion in SCA Hygiene Prods. V. First Quality Baby Prods., holding that laches, an equitable defense to infringement damages based upon unreasonable delay in commencing suit, cannot be a defense against infringement damages where the infringement occurred within the six year period established in 35 U.S.C. §286.

On February 22, 2017, the United States Supreme Court (“Supreme Court”) issued its opinion in Life Tech. v. Promega, holding that the export of a single component of a patented article does not give rise to infringement liability under 35 U.S.C. § 271 (f)(1).