Genetics Institute, Inc. v. Amgen, Inc.

How later courts describe this case

• open access policy was means by which FERC sought to increase competition in the market for natural gas
• NLRB determination that bargaining issue is a mandatory term and condition under § 8(d) entitled to deference because of Board's expertise
• Section 112 “requires that the scope of the claims must bear a reasonable correlation to the scope of en-ablement provided by the specification to persons of ordinary skill in the art.”
• employer transferred work in order to “reduce manufacturing costs by $2.6 million, $2 million of which would be directly attributable to cheaper labor.... Obviously, labor costs were the driving force behind the Company’s action”