id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
inlawrev-25150	Carter, R. Trevor; Hayden, Leslie B.; Dodge, Reid E.	Developments in Intellectual Property Law: October 1, 2018--September 30, 2019	2021	25	.pdf	application/pdf	10005	583	62	This substantial body of law includes Supreme Court authority—which implicitly suggested “that a sale or offer of sale need not make an invention available to the public”35—and Federal Circuit authority—which has “long held that ‘secret sales’ can invalidate a patent.”36 In Return Mail, Inc. v. U.S. Postal Service, the Supreme Court issued an opinion holding that a United States federal agency is not a “person” that can institute one of the three types of patent review proceedings (inter partes review, post-grant review and covered-business-method review) authorized by the America Invents Act.68 A. Background The AIA, which was enacted in 2011, provides three types of administrative proceedings for reviewing and seeking to invalidate claims of an issued patent, all three of which can be initiated by a “person.”69	cache/inlawrev-25150.pdf	txt/inlawrev-25150.txt