Jazz Pharmaceuticals v. Avadel CNS Pharmaceuticals, decided May 6, 2025

The core of the dispute involves Avadel's product, Lumryz, and whether the district court correctly issued a permanent injunction preventing Avadel from engaging in certain activities related to it, specifically concerning its patent U.S. Patent 11,147,782. The appeals court addressed three distinct enjoined activities: initiating new clinical trials, offering open-label extensions in ongoing trials, and applying for FDA approval for new indications of Lumryz, ultimately reversing the injunction on the first two grounds and vacating and remanding the third for further consideration based on the legal interpretation of 35 U.S.C. § 271(e)(2) and the applicability of the Hatch-Waxman Act's safe harbor provision. The decision focuses on the limitations on injunctive relief for certain activities related to FDA submissions and clinical trials under patent law.