Guidelines for Assessing Enablement in Utility Applications and Patents in View of the Supreme Court Decision in Amgen Inc. et al. v. Sanofi et al., 83 Fed. Martin Luther King Jr. acquired the Nobel Peace Prize in 1964, and I re-read his speech today — especially the portion contrasting development of science and technology against growth of the human spirit. The past 60 years have continued to disclose astonishing discoveries and invention. Yet King’s phrases and warnings proceed to resonate as a result of we now have continued to neglect our inside realm. If judges were keen to sanction plaintiffs—or no much less than shift fees—when Schedule A defendants were wrongfully restrained, that might do lots to assist stage the taking half in area and incentivize the plaintiffs to convey better claims. In the tip, the choice to sanction and to award fees is left to the discretion of the …