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The U.S. Supreme Court yesterday reversed the Second Circuit Court of Appeals and held in Reed Elsevier v. Muchnick that the copyright registration requirements for certain works under Section 411(a) of the Copyright Act of 1976 are not jurisdictional, but rather are preconditions for instituting an infringement action.

In Wellman, Inc. v. Eastman Chemical Co., No. 2010-1249 (Fed. Cir. Apr. 29, 2011), the Federal Circuit affirmed the U.S. District Court for the District of Delaware’s grant of summary judgment on invalidity of Wellman’s patent claims for failure to disclose the best mode.