Juno Therapeutics, Inc. v. Kite Pharma, Inc. (Fed. Cir. 2021)

By Kevin E. Noonan — Dominating the entering gallery of the Impressionists exhibit at the Art Institute of Chicago is Georges Seurat’s A Sunday on La Grande Jatte (see below). Painted in the pointillist style, the work comprises millions of individual paint dots reminiscent of photos taken with late 20th Century technology made up of hundreds of individual photographs. Both these examples of “from many, one” come to mind when considering the Federal Circuit’s opinion today in Juno Therapeutics, Inc. v. Kite Pharma, Inc., wherein the Court overturned a jury’s factual determination that Kite had not shown by clear and…