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Helsinn Healthcare S. A. v. Teva Pharmaceuticals USA, Inc.

Supreme Court of the United States (2019) | 139 S. Ct. 628; 202 L. Ed. 2d 551; 2019 U.S. LEXIS 807

4 min read

TL;DR: A pharmaceutical company's confidential sale of its invention to a partner triggered the "on sale" bar under the America Invents Act, invalidating its later-issued patent. The Court held that a commercial sale need not make the invention's details public to bar patentability.

Legal Significance: The case confirms that the America Invents Act did not narrow the "on sale" bar. A commercial sale, even if confidential, can qualify as prior art under 35 U.S.C. § 102(a), preserving the long-standing rule from pre-AIA precedent like *Pfaff*.