The U.S. Court of Appeals for the Federal Circuit issued a precedential ruling in International Medical Devices, Inc. v. Cornell, reversing the Central District of California's denial of judgment as a matter of law on trade secret misappropriation, breach of contract, and patent invalidity claims arising from a dispute over penile implant technology. The court held that self-evident variants of known prior art cannot receive trade secret protection under California law — a clean doctrinal statement with broad implications for medical device IP disputes. The Federal Circuit's reversal on patent invalidity means the lower court's finding that the patents were valid will not stand. The court's willingness to issue a precedential opinion signals it views the legal questions as settled enough to bind future panels, making this decision a reference point for trade secret and patent overlap cases in the medical device space.
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Media Coverage · April 19, 2026
The court entered judgment.
newspaper Read article“‘California courts have recognized that self-evident variants of the known art cannot be protected’ under trade secret law.” – Federal Circuit The U.S. Court of Appeals for the Federal Circuit (CAFC) issued a precedential decision Friday in International Medical Devices, Inc. Cornell, reversing the United States District Court for the Central District of California’s denial of judgment as a matter of law (JMOL) on trade secret misappropriation, breach of contract, and patent invalidity claims.
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The court entered judgment.
“‘California courts have recognized that self-evident variants of the known art cannot be protected’ under trade secret law.” – Federal Circuit The U.S. Court of Appeals for the Federal Circuit …
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