Invention Need Not Be Publicly Disclosed to Trigger AIA Version of On-Sale Bar

The Federal Circuit ruled yesterday that public sales of a product do not need to disclose the details of an invention to bar a patent application under post-America Invents Act (“AIA”) 35 U.S.C. § 102.  Helsinn Healthcare S.A. v. Teva Pharmaceuticals USA, Inc. et al.  In reaching this decision, the court rejected Helsinn’s argument that […]