Showing posts with label federal. Show all posts
Showing posts with label federal. Show all posts
Saturday, February 11, 2017
Federal Tax 2014 Refund Calc 1 0 apk free download
Federal Tax 2014 Refund Calc 1 0 apk free download
Federal Tax, 2014 Refund Calc.
Finance
Download .apk
The Tax Refund Calculator (2014) application provides user a quick peak at their Tax refund to be filed by April, 2014. It can help employee and employer both to calculate a refund. The app calculates refund for all 52 states and for all filing status (single, married, head of household ) and pay periods (daily, weekly, bi weekly, semimonthly, monthly, annually). Pre-deduction (IRA, 401k, medical, eligible deduction etc) and post-deduction (child spouse support, judgement, garnishment, medical, etc.) amounts are also taken into account while calculating refund. It provides annual summary of federal tax holdings, State Tax holdings, Social security, Medicare and calculates tax refund or tax you owe. The results are shown in detail user friendly format. Actual federal tax tables are used for calculations. Developer had used most accurate and and recent data available to calculate refunds. This app may help in budgeting and managing household expenses.
• Calculates refund for all 52 states and for all filing status (single, married, head of household ) and pay periods (daily, weekly, bi weekly, semimonthly, monthly, annually).
It provides annual summary of Federal tax holding, State Tax holdings, Social security, Medicare and calculates tax refund or amount you owe.
• Pre-deduction (IRA, 401k, medical, eligible deduction etc) and post-deduction (child spouse support, judgement, garnishment, medical, etc.) are also taken into account while calculating refund.
• Actual federal tax tables are used for calculations, IRS verified.
• This app may help in budgeting and managing household expenses.
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DEVANDY Partners. llc.
Download .apk
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Friday, February 10, 2017
Federal Circuit Affirms Decision Finding Biogen’s Patent Not Infringed by Arzerra
Federal Circuit Affirms Decision Finding Biogen’s Patent Not Infringed by Arzerra
Today in Biogen Idec v. GlaxoSmithKline a divided panel of the Federal Circuit affirmed a district court’s decision that GSKs monoclonal antibody product Arzerra does not infringe Biogens patent number 7,682,612. I discussed the district courts decision in an October 2011 blog post. Arzerra is a fully human antibody that specifically binds to a small loop on the CD20 antigen. Biogen markets a competing product, Rituxan, which is a chimeric antibody that targets a different, larger loop on the CD20 antigen.
Representative claim 1 of Biogens patent recites:
1. A method of treating chronic lymphocytic leukemia in a human patient, comprising administering an anti-CD20 antibody to the patient in an amount effective to treat the chronic lymphocytic leukemia, wherein the method does not include treatment with a radiolabeled anti-CD20 antibody.
The dispute centered on the interpretation of the claim term "anti-CD20 antibody." The District Court construed the term as limited to antibodies that bind to the same epitope of the CD20 antigen as Rituxan, i.e., the large loop. Under this interpretation, Biogen stipulated to noninfringement, since it is undisputed that Arzerra binds to a different epitope, i.e., the small loop.
On appeal, the Federal Circuit majority affirmed the district courts claim interpretation, based on the doctrine of "prosecution history disclaimer." The majority noted that while claim terms are generally given their ordinary and customary meaning, a "clear and unmistakable" disavowal of subject matter during prosecution overcomes the "heavy presumption" that claim terms carry their full ordinary and customary meaning. In this case, although the ordinary meaning of anti-CD20 antibody would presumably encompass any antibody that specifically recognizes any epitope on the CD20 antigen, the majority found that statements made during prosecution limited the claim to antibodies that bind at the same epitope as Rituxan. The majority pointed out that when representations are made by the time the during prosecution, "competitors are entitled to rely on those representations when determining a course of lawful conduct, such as launching a new product or designing-around a patented invention."
To summarize, during prosecution the examiner rejected Biogen’s claims for lack of enablement, finding that while the specification was enabling for Rituxan, but that it was "silent concerning what sort of specificity and affinity would be necessary" for other anti-CD20 antibodies. In response, Biogen pointed to its disclosure of Rituxan and argued that:
even though antibodies directed to the same antigen might have different affinities and functional characteristics, one of skill in the art could readily identify an antibody that binds to CD20 with similar affinity and specificity as does Rituxan using techniques that are well known in the art . . . With that knowledge in hand, the skilled artisan could readily produce anti-CD20 antibodies using similar techniques, and screen such antibodies for those having an affinity and functional activity similar to Rituxan.
After considering this argument, the examiner withdrew the enablement rejection. Even though the claims were not amended, the majority found that by arguing that the specification was enabling for antibodies with similar affinity and specificity as Rituxan, instead of challenging the examiners understanding of the crucial terms, Biogen had effectively limited its claims to antibodies similar to Rituxan, i.e., antibodies binding the same epitope.
A dissenting opinion was filed by Judge Plager, who found that Biogens arguments during prosecution were sufficiently ambiguous that they did not meet the "clear and unmistakable" disclaimer standard necessary to overcome the presumption that claim terms should be attributed their plain meaning. He voiced the opinion that Biogens argument represented nothing more than "the give-and-take that is often part of the process of negotiation between it and examiner and an applicant [which] may result in less-than-clear understandings,” and that the majority had made "too much of such ambiguous statements."
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Tuesday, January 31, 2017
Federal Circuit Decides Ariosa and Its Not Good News for Innovation in the Life Sciences
Federal Circuit Decides Ariosa and Its Not Good News for Innovation in the Life Sciences
On November 1, 2013, I reported on the district court decision in Aria Diagnostics v. Sequenom that invalidated diagnostic method claims under the Mayo v. Prometheus test for patent eligibility. In that post, I predicted that if “the approach used by this court is upheld by the Federal Circuit and applied generally to diagnostic claims, it would seem to severely limit the availability of patent protection for diagnostics.
The Federal Circuit’s decision came out today, and Ariosa Diagnostics v. Sequenom (Aria has changed its name to Ariosa) is indeed very bad news for the patenting of diagnostic methods, and in the life sciences generally. The outcome appears to have been driven by unfortunate and unnecessarily broad language used by the Supreme Court in Mayo, as noted in a thoughtful concurring opinion by Judge Linn (discussed below).
Ariosa begins by setting forth the test for patent eligibility established in Mayo:
- Step 1 – Determine whether the claims at issue are directed to a patent ineligible concept. Id. at 1297. If the answer is yes, then proceed to Step 2.
- Step 2 - Determine whether additional claimed elements “transform the nature of the claim” into a patent-eligible application of the concept.
The Supreme Court has described the second step of this analysis as a search for an “inventive concept”—i.e., an element or combination of elements that is “sufficient to ensure that the patent in practice amounts to significantly more than a patent upon the [ineligible concept] itself.”
The court then proceeded to apply the Mayo test to Sequenom’s claims. The court found that the existence of cell free fetal DNA (“cffDNA”) in maternal plasma is a natural phenomenon, that the claims are directed to methods that begin and end with cffDNA, pointing out that “Sequenom does not contend that [the inventors] created or altered any of the genetic information encoded in the cffDNA, and it is undisputed that the location of the nucleic acids existed in nature before [the inventors] found them." After concluding that the claims are directed to “matter that is naturally occurring,” thereby satisfying Step 1 of the test, the court turned to Step 2.
In applying Step 2, the court found that none of the additional elements recited in the claims provided sufficient “inventive concept” to render the claims patent eligible. In particular, the claims recite steps of preparing, amplifying and detecting DNA, but the court held that all these techniques, such as PCR or detection of a specific chromosome, were “well-understood, routine, and conventional” at the time of the invention. The court states:
[I]n this case, appending routine, conventional steps to a natural phenomenon, specified at a high level of generality, is not enough to supply an inventive concept. Where claims of a method patent are directed to an application that starts and ends with a naturally occurring phenomenon, the patent fails to disclose patent eligible subject matter if the methods themselves are conventional, routine and well understood applications in the art.
Sequenom argued that there are numerous other uses of cffDNA aside from those claimed in its patent, and thus, the patent does not preempt all uses of cffDNA. But the court rejected this argument, ruling that:
[A]lthough the Supreme Court “has made clear that the principle of preemption is the basis for the judicial exceptions to patentability, . . . the absence of complete preemption does not demonstrate patent eligibility. . . Where a patent’s claims are deemed only to disclose patent ineligible subject matter under the Mayo framework, as they are in this case, preemption concerns are fully addressed and made moot.
Sequenom and some of its supporting amici had urged the court to draw distinctions among natural phenomena based on whether or not their patenting would interfere significantly with innovation in other fields, now or in the future. The court rejected this policy argument, however, finding that the Supreme Court cases “ have not distinguished among different laws of nature or natural phenomenon according to whether or not the principles they embody are sufficiently narrow.”
In a thoughtful concurring opinion, Judge Linn states that he joined court’s opinion invalidating the claims of the Sequenom patent only because he felt “bound by the sweeping language of the test set out” by the Supreme Court in Mayo. Judge Linn expressed his view that Part 2 of the Mayo test is overly broad and was unnecessary to decide that case, and that the broad language of Mayo has had the “perhaps unintended” consequence of in this case "excluding a meritorious invention from the patent protection it deserves and should have been entitled to retain.”
Judge Linn found it “hard to deny that Sequenom’s invention is truly meritorious,” noting that prior to the invention prenatal diagnoses required invasive methods, which “present[ed] a degree of risk to the mother and to the pregnancy.” The available “techniques [we]re time consuming or require[d] expensive equipment.” He pointed out that the Royal Society had lauded the inventors’ discovery as “a paradigm shift in non-invasive prenatal diagnosis,” and that the commercial embodiment of the invention, the MaterniT21 test, was the first marketed non-invasive prenatal diagnostic test for fetal aneuploidies, such as Down’s syndrome, and presented fewer risks and a more dependable rate of abnormality detection than other tests.
According to Judge Linn, under “traditional” (pre-Mayo) standards of patentability, Sequenom’s patent would have been valid, since the inventors had “effectuate[d] a practical result and benefit not previously attained.” His opinion concludes with the following observation:
But for the sweeping language in the Supreme Court’s Mayo opinion, I see no reason, in policy or statute, why this breakthrough invention should be deemed patent ineligible.
I agree with Judge Linn on this point, and can only hope that the Federal Circuit can find some way to rein in the unnecessarily expansive language of Mayo. But if the Federal Circuit is as constrained by Mayo as Judge Linn seems to believe, Congressional or Supreme Court intervention might be necessary to restore effective patent protection for important innovations as exemplified by the Sequenom test.
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