Tag: Rule 12(b)(6)
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AML IP v. Bath & Body Works Direct: Federal Circuit Allows Section 101 Dismissal After Finding Patent Venue Improper
The Federal Circuit’s decision in AML IP, LLC v. Bath & Body Works Direct, Inc., Case No. 2025-1280 (Fed. Cir. Aug. 28, 2026), holds that a district court may, in appropriate circumstances, decide a fully briefed merits defense even after concluding that patent venue is improper. Because venue is a waivable protection belonging to the…
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Adnexus v. Meta: Federal Circuit Rejects Premature Claim Construction at Pleading Stage
On December 5, 2025, the Federal Circuit vacated and remanded the dismissal of Adnexus Inc.’s v. Meta Platforms, Inc., holding that the district court prematurely resolved a claim construction dispute under the guise of Rule 12(b)(6) plausibility. The decision is a pointed reminder that, while courts retain flexibility at the pleadings stage, they may not…