Steven Simonis presented at the 23rd Annual Joint Patent Practice Seminar in New York, NY. He discussed how The Court of Appeals for the Federal Circuit (CAFC) considered the issue of whether certain patent licensing restrictions in license agreements may constitute unlawful tying arrangements in Monsanto Co. v. Scruggs, 459 F.3d 1328 (Fed. Cir. 2006). The CAFC determined that the license restrictions contained in Monsanto’s license agreements did not constitute antitrust violations.