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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 | 04.14.26

DOJ’s False Claims Act Resolution Against IBM Signals Heightened Risk for Federal Contractors with DEI Programs

On Friday, April 10, 2026, the U.S. Department of Justice (DOJ) announced that International Business Machines Corporation (IBM) has agreed to pay just over $17 million to resolve allegations that it violated the False Claims Act (FCA) by failing to comply with federal anti-discrimination requirements incorporated into its federal contracts due to allegedly discriminatory diversity, equity, and inclusion (DEI) employment practices. This resolution marks the first FCA settlement secured by the DOJ under its Civil Rights Fraud Initiative, created in May 2025, and announced by then-Deputy Attorney General Todd Blanche as part of the administration’s coordinated efforts to target allegedly unlawful DEI practices. Per the agreement, the settlement is neither an admission of liability by IBM nor a concession by the United States that its claims are not well founded....