id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ihlr-27183	Phillips, Abraham	The Safe Harbor of 35 U.S.C. § 271(e)(1): The Costly Confusion About the Scope of "Patented Invention"	2023	30	.pdf	application/pdf	13748	714	55	Though Allele could use the technology internally, Allele generates a large part of its revenue from producing and selling cutting edge technology for clinical and therapeutic use and develops an array of research tools.187 A second consequence of limiting enforceability of research tool patents is that fewer patents will be issued on research tools commonly used in generating data for FDA approval. Referring to Eli Lilly, Merck states it is “apparent from the statutory text that § 271(e)(1)'s exemption from infringement extends to all uses of patented inventions that are reasonably related to the development and submission of any information under the FDCA.”157 Whether “any information” signifies that the information need not relate to approval of the subject patented invention has not been answered by the Supreme Court, and as we have already seen, is a subject of disagreement in lower courts.158 It has been over fifteen years since this textualistic statement of the statute concerned holders of research tool patents.	cache/ihlr-27183.pdf	txt/ihlr-27183.txt