Law360, New York ( July 24, 2013, 12:55 PM EDT) -- On May 1, 2013, the Federal Circuit found composition claims, but not a method of use claim, obvious in Allergan's Orange Book-listed patents for Combigan (a combination eye-drop product used for treating glaucoma). Allergan Inc. v. Sandoz Inc., 2011-1619, -1620, -1635, -1639. The inconsistent obviousness determination between the composition claims and the method claim in this case is difficult to reconcile....
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