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Form 18 Complaints Trump Twiqbal: Judge

By Pete Brush (September 3, 2010, 4:52 PM EDT) -- Patent infringement complaints made using Form 18 of the Federal Rules of Civil Procedure are sufficient to state a cause of action, even when the allegations are insufficiently pled under the U.S. Supreme Court's Twombly and Iqbal standards, a federal magistrate judge has held in recommending the rejection of First Niagara Financial Group Inc.'s bid to toss Automated Transactions LLC's suit over ATM patents....

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