Case: Patents/JMOL (Fed. Cir.)

The Federal Circuit reversed the decision of the District of Massachusetts granting judgment as a matter of law that claims of some Teva Pharmaceuticals International GmbH and Teva Pharmaceuticals USA Inc.'s patent that concern the use of humanized anti-CGRP antagonist antibodies to treat headaches are invalid, after a jury found that Eli Lilly and Company willfully infringed the patents and failed to prove the asserted patent claims invalid. According to the appeals court, JMOL of no written description and no enablement was improper.