On June 11, 2025, the U.S. Court of Appeals for the Federal Circuit upheld PTAB's decisions that invalidated Agilent Technologies' patents for modified CRISPR guide RNAs. Agilent challenged the anticipation findings, arguing that the pivotal prior art, a 2014 publication called Pioneer Hi-Bred, did not disclose required functionalities or sufficient enablement. However, the court found substantial evidence of disclosed capabilities in the reference, emphasizing that only one operable embodiment is needed for anticipation, thus clarifying the legal standards between § 102 and § 112.
The Federal Circuit clarified that for anticipation under § 102, enablement requires only one operable embodiment, not the full scope of claims mandated under § 112.
The Federal Circuit, however, rejected this argument, affirming that substantial evidence demonstrated Pioneer Hi-Bred expressly disclosed chemically modified guide RNAs capable of binding Cas proteins and targeting DNA sequences.
The court emphasized these examples did not negate the clear disclosures of functional modified guide RNAs elsewhere in the reference.
Synthego Corp. challenged the validity of these patents through IPR proceedings, asserting that the claims were either anticipated by or rendered obvious in view of a 2014 scientific publication.
Collection
[
|
...
]