Patentee Secures Reversal of JMOL on Written Description and Enablement for Method

Federal Circuit reversed district court JMOL, holding Teva's method claims for treating headaches using anti-CGRP antibodies satisfied written description and enablement requirements. Jury found Lilly willfully infringed valid claims. District court invalidated claims despite jury verdict. Federal Circuit distinguished claims from genus antibody patents, emphasizing claims covered specific treatment method, not broad antibody genus. Court noted antibodies were well-known in prior art and specification showed all antagonistic anti-CGRP antibodies treat headaches effectively.