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Failure to Disclose Employee Notes Constitutes Inequitable Conduct

Client Alert | 1 min read | 02.20.08

In Monsanto Co. v. Bayer Bioscience N.V., (No. 07-1109; January 25, 2008) a Federal Circuit panel affirms a district court’s decision that a patent is unenforceable. Bayer disclosed an abstract relating to a poster shown at a scientific conference. Bayer did not disclose detailed notes that one of its employees took regarding the poster.


The panel’s analysis focuses on whether or not the district court made a clear error in determining the failure to disclose the notes, which were not prior art, amounted to inequitable conduct. Because the notes clearly and convincingly refute the position Bayer took in opposing the Examiner’s rejection, says the panel, the notes are material and should have been disclosed. But the panel is also careful in pointing out that not all internal documents of potential relevance must be submitted. In this case, however, the notes are material because they directly contradict Bayer’s arguments made in support of patentability.


With regard to intent, the panel points out that “[i]ntent is easily inferred when, as here, an applicant makes arguments to the PTO that it knows, or obviously should have known, are false in light of information not before the examiner, and the applicant knowingly withholds that additional information.” The district court’s determination that Bayer failed to offer a credible explanation for withholding the notes is not disturbed. 

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Client Alert | 3 min read | 05.28.26

PFAS Regulatory Alert: EPA Rolls Back RCRA Proposed Rule on “Hazardous Waste” but Does Not Disturb Proposed RCRA Rule on PFAS

Earlier this month, the U.S. Environmental Protection Agency (EPA) withdrew a February 2024 Biden administration proposed rule, “Definition of Hazardous Waste Applicable to Corrective Action for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the narrower regulatory definition. Now, EPA is maintaining the status quo for corrective action under RCRA. However, EPA’s withdrawal of its proposed RCRA hazardous waste definition makes no mention of its corresponding proposal from 2024 to list nine per- and polyfluoroalkyl substances (PFAS) as RCRA hazardous constituents.[2] This disjointed withdrawal, while providing some certainty for regulated entities, does not resolve how EPA plans to address PFAS under the RCRA program....