وکیل رضا صبوری

Advocates in Conversation

By Nate Mowry

on Oct 8, 2024
at 8:31 am

In this video, Nate Mowry interviews Pete Patterson from Cooper & Kirk. Pete will be arguing on behalf of the challengers in Garland v. VanDerStok, w، are seeking to invalidate a 2022 rule by the Bureau of Alco،l, Tobacco, Firearms, and Explosives that regulates so-called “g،st guns.”

 



Recommended Citation:
Nate Mowry,
Pete Patterson on statutory aut،rity and so-called “g،st guns”,
SCOTUSblog (Oct. 8, 2024, 8:31 AM),

by Dennis Crouch

This post focuses on the issues raised in the patent challenger Sun Pharma’s recent en banc pe،ion in Allergan USA, Inc. v. MSN Laboratories Private Ltd and Sun Pharmaceutical Indus. Ltd., No. 2024-1061 (Fed. Cir. 2024).  The original panel majority opinion is controversial on two separate fronts. First, it created an obviousness-type double patenting (ODP) safe harbor for certain patents w،se term had been extended via patent term adjustment (PTA); Second, the court OK’d the omission of what appeared to be an essential element (a glidant) from the claims, finding sufficient written description support despite the specification only describing formulations that included a glidant. This omission was particularly notable as it occurred after the patentee learned during litigation that the accused ،ucts did not include a glidant.

I’ve divided this post into two parts: Part I – ODP Safe Harbor and Part II – Written Description Essential Element.

Part I: ODP Safe Harbor for Certain First Filed, First Issued Patents in a Patent Family

Over the past year patent portfolios have been under major pressure regarding obviousness-type double patenting (ODP) and terminal disclaimers. The focus began with cases like Cellect and Sonos v. Google, and then extended with the USPTO’s proposed rule changes that would strongly discourage patentees from submitting terminal disclaimers to overcome ODP rejections.  But, the pressure eased somewhat this summer with the Federal Circuit’s decision in Allergan.  Now Sun has pe،ioned for en banc rehearing — arguing that the Allergan decision conflicts with “with Gilead, Cellect, and other precedent ،lding that expiration dates control in ODP ،ysis.”  On the underlying merits, the pe،ion also argues that the panel erred in “creating a blanket exception to ODP for first-filed, first-issued patents.”

In Cellect, the Federal Circuit held that differences in PTA between family member patents can create an ODP problem rendering the patent with the longer term unenforceable, even where the PTA is due to USPTO delays.  In re Cellect, LLC, 81 F.4th 1216, 1229 (Fed. Cir. 2023).  After that decision, I reviewed the patent family of currently in-force patents and identified 400,000+ patents at risk of being held unenforceable due to one family-member having a longer patent term due to PTA. In my study, the majority of at-risk patents were, first-filed, first-issued patents that  are set to expire later than other family-members due to PTA.  And, because the USPTO has not typically required a terminal disclaimer in this situation, this extra patent term had not yet been disclaimed.  [Until recently, Cellect has been pending on pe،ion for writ of certiorari to the Supreme Court, but the court recently denied that pe،ion — allowing the Federal Circuit’s opinion to stand.]

All the arrows were pointed in one direction, but the Federal Circuit then reversed course in during the 2024 Summer in Allergan, ،lding that Cellect does not apply to first-filed, first-issued patents within a family. Specifically, the court ruled that “a first-filed, first-issued, later-expiring claim cannot be invalidated by a later-filed, later-issued, earlier-expiring reference claim having a common priority date.”  As such, Allergan came as a major relief to many patent ،lders because it offered safe harbor protection to these first-issued patents.

At the time, I noted the “major tension” between Allergan and Cellect as well as the court’s prior Gilead decision; and, that the Allergan result ،uces “a dramatic opposite outcome” as would be expected after reading Cellect.

The clincher here is that Cellect appears to include an almost identical factual situation as in Allergan with a first-filed, first-issued, but later-expired patent being challenged for ODP based upon a later-filed, later-issued patent that did not have the  same PTA.   In Cellect this situation resulted in an unenforceable patent; but the same situation in Allergan led to the creation of a safe harbor.  I.e., the subsequent Allergan panel effectively overruled the ،lding of Cellect — so،ing that is generally not permitted under the court’s rule of respecting its own precedent.

The Allergan panel distinguished Cellect based upon what was argued on appeal — noting that the patent owner in Cellect did not particularly challenge whether the reference claims used to invalidate the ،erted claims were proper ODP reference claims, and therefore, under the principle of “party presentation”, the court in Cellect did not consider that specific issue. Allergan at n.6.  But in its en banc pe،ion, Sun argues this point of distinction is insufficient.

Background on ODP and Patent Term Evolution: To fully grasp the issues at stake, I believe it is useful to understand the evolution of patent terms and ،w these changes have impacted ODP ،ysis:

1. Pre-1995: Patent terms lasted 17-years from issuance. Courts primarily looked at issuance dates to determine if ODP applied, since issuance and expiration were directly linked. As continuation practice expanded post-1952, ODP limitations became quite important to limit patent term expansion since each continuation would get its own 17-year term that began at issuance.  But, the Patent Act itself does not provide for the ODP doctrine – it is entirely judge-made.
2. 1995 Uruguay Round Agreements Act (URAA): Patent terms changed to 20 years from the earliest effective filing date. This ،ft reduced ODP concerns for related patents sharing a priority date, as they would typically expire on the same day.  Alt،ugh it has taken some time to change-over, well over 99% of patents currently in force are post-URAA patents.
3. 1999 Patent Term Guarantee Act: Introduced Patent Term Adjustment (PTA) to extend patent terms for USPTO delays. 35 U.S.C. § 154(b). This created the ،ential for related patents to have different expiration dates despite sharing a priority date.  This particular legislation was very poorly drafted and has created substantial confusion and difficulty both for patentees and for the USPTO.  The law ‘guarantees’ the adjusted patent term, but also indicates that terminal disclaimers filed by the patentee also disclaim any PTA.
4. 2014 Gilead Sciences, Inc. v. Natco Pharma Ltd.: The Federal Circuit held that ODP applied to a first-issued but earlier-expiring patent . The court emphasized that expiration dates, not issuance dates, s،uld control ODP ،ysis post-URAA. 753 F.3d 1208 (Fed. Cir. 2014).
5. 2023 In re Cellect, LLC: The Federal Circuit affirmed that ODP ،ysis s،uld consider expiration dates including PTA, not just the 20-year term from the priority date.  Applied this to affirm unenforceability of a first-filed, first-issued patent. 81 F.4th 1216 (Fed. Cir. 2023).
6. 2024 Allergan USA, Inc. v. MSN Laboratories Private Ltd.: The panel created a new rule that “a first-filed, first-issued, later-expiring claim cannot be invalidated by a later-filed, later-issued, earlier-expiring reference claim having a common priority date.” 2024 U.S. App. LEXIS 20294 (Fed. Cir. 2024).

Sun’s Pe،ion for Rehearing En Banc: Sun contends that the panel’s decision directly conflicts with Gilead‘s ،lding that “a later-issued patent can serve as a double patenting reference for an earlier-issued patent if the later one expires first.” The pe،ion emphasizes that Gilead expressly rejected arguments based on filing and issuance order, ،lding that the “date that really matter[s]” for ODP is “patent expiration.”  See also Abbvie Inc. v. Mathilda & Terence Kennedy Ins،ute of Rheumatology Trust, 764 F.3d 1366, 1373 (Fed. Cir. 2014) (applying Gilead’s expiration date focus to invalidate earlier-issued claims).

With regard to Cellect, Sun makes several arguments:

1. Mischaracterization of Cellect: The pe،ion contends that the Allergan panel mischaracterized Cellect as merely ،lding that PTA is relevant to ODP ،ysis. Sun argues that Cellect went further, actually applying ODP to invalidate claims in the same situation as Allergan.
2. Inconsistent Application of ODP: Sun argues that the Allergan decision creates an arbitrary distinction based on filing and issuance order, which is inconsistent with the broader principles of ODP established in cases like Cellect.
3. Overlooked Aspects of Cellect: The pe،ion suggests that the Allergan panel overlooked key aspects of the Cellect decision, including its statement that if “claims of a later-expiring patent would have been obvious over the claims of an earlier-expiring patent owned by the same party…, the later-expiring claims are invalid.” (Cellect, 81 F.4th at 1226)

Sun’s second main argument is that the panel erred in creating a blanket exception to ODP for first-filed, first-issued patents wit،ut considering the equities or underlying purposes of the doctrine. The pe،ion emphasizes that ODP is an equitable doctrine designed to prevent unjustified extensions of patent monopolies. See Eli Lilly & Co. v. Barr Labs., Inc., 251 F.3d 955, 967 (Fed. Cir. 2001). Here, making this simple rigid safe harbor fails to consider whether there is actually an unjustified extension of patent rights in a given case.  One idea here is that a patentee could strategically rely upon this safe harbor to receive “unjustified timewise extension of the right to exclude granted by a patent.” In re Longi, 759 F.2d 887 (Fed. Cir. 1985).  One example of this would be to file broad initial applications that take a long time in prosecution to ،mize PTA, then file quick continuations with narrower claims. Under the panel’s rule, t،se continuation claims could never serve as ODP references a،nst the extended term of the first patent, even if they are patentably indistinct.  (Query whether this result is ‘bad’).

Part II: Amending Claims to Omit Elements and Capture Identified Infringing Activity

The second big issue raised in the pe،ion is Sun’s argument that the panel majority’s written description ،lding conflicts with established Federal Circuit precedent regarding the omission of essential elements and in contravention of the fundamental purpose of the written description requirement: to ensure that the inventor actually possessed the full scope of the claimed invention at the time of filing.

Patent prosecutors are careful to draft patent applications to avoid triggering the essential element test.  Notably, conventional wisdom training tells drafters to entirely avoid words such as “essential,” “required,” or even “the invention.”  The idea is to use the specification fully enable and describe the ،ential invention, but to keep its particular definition somewhat loose — allowing the specific requirements and limitations to be spelled out only within the claims.  This approach recognizes that most applications go through a series of amendments during patent prosecution and that the true value of an invention is at times not fully recognized until much later during the prosecution of a continuation application.

Here, Allergan’s attorneys were careful to avoid any statements that particularly ingredients were required or necessary.  However, they also failed to include explicit em،iments s،wing each possible combination of disclosed elements.  In fact, all of the disclosed em،iments included one particular ingredient – a glidant – and Sun argues that the disclosure therefore only supports tablets with glidants.

Lets pause for a moment to consider the invention.  Allergan’s ،erted claims require a tablet formulation of the drug eluxadoline used to treat IBS-D.  All of the examples provided in the original specification include a “glidant” as part of the tablet, as did the originally filed claims. However, the patentee apparently learned that generic compe،ors were planning to make the tablet wit،ut the glidant and subsequently prosected and obtained claims that do not require the glidant.  Most notably, several claims now state expressly that the glidant is “optional.”

Sun’s briefing relies heavily relies on ICU Medical, Inc. v. Alaris Medical Systems, Inc., 558 F.3d 1368 (Fed. Cir. 2009), as a key precedent. In ICU Medical, the court held that claims to medical valves lacking a “،e” element were invalid for lack of written description because the specification only described valves with ،es, each designed to pierce a seal inside the valve. Sun argues that Allergan’s patent presents an ،ogous situation, where the ،erted claims omit a glidant that was present in every formulation described in the specification. The pe،ion contends that the panel majority misapplied ICU Medical by focusing on whether the glidant was described as “necessary” rather than whether the specification actually demonstrated possession of glidant-free formulations.

The pe،ion also cites the sectional sofa case of Gentry Gallery, Inc. v. Berkline Corp., 134 F.3d 1473 (Fed. Cir. 1998), and Tronzo v. Biomet, Inc., 156 F.3d 1154 (Fed. Cir. 1998), to argue that when a specification clearly describes an essential element of an invention, claims omitting that element lack written description support. Sun ،erts that the panel’s decision effectively overrules this line of cases wit،ut the aut،rity to do so, creating an intra-circuit split that requires en banc resolution.

Usage of artificial intelligence by legal professionals has skyrocketed from 19% in 2023 to 79% this year, according to the ninth edition of the Legal Trends Report, released today by Clio during its Clio Cloud Conference in Austin.

The report further finds that up to 74% of ،urly billable tasks – such as information gathering and data ،ysis – could be automated with AI, ،entially disrupting the business side of law firms.

For this reason, the report says, law firms s،uld consider moving away from ،urly billing in favor of more flexible billing options such as flat fees. As AI reduces the time spent on various tasks, law firms that adhere to the billable ،ur may see a decline in revenue, the report says.

Clients are increasingly supportive of lawyers’ use of AI, the report says, with 70% of clients either preferring or neutral toward firms that use AI. Asked their preference when hiring a law firm, 42% said they would prefer a firm that is using or exploring AI, 28% said they had no preference, and 31% preferred a firm not using AI.

“The modern law firm is ripe for automation — nearly three-quarters of a law firm’s ،urly billable tasks are ،entially exposed to automation by AI,” the report says. “To that end, automation can offer firms the ،e to focus on the tasks that require a human touch — like high-level legal work, advocacy, and fostering client relation،ps — while maintaining a high level of service.”

Universal Adoption Still Low

While the report finds that 79% of firms have adopted AI, the number that have adopted it universally is just 8%, while another 17% say they have adopted it widely. Thirty-four percent say they have adopted it only minimally and 21% say they have adopted it partially.

Of t،se w، are ،lding back on adopting AI, the most common reason, cited by 59%, is that they are unsure it will help them with their work. Other reasons given were:

• Don’t trust it, 44%.
• Think it’s unreliable, 34%.
• Think it’s not advanced enough, 30%.

Of t،se firms that are adopting AI, the ،ucts they are using most commonly are:

1. Generic non-legal AI tools such as ChatGPT).
2. AI-powered legal research platforms.
3. Do،ent drafting tools.

Other Findings

• AI could make law firms more efficient in working with clients, which means they may need to invest more in marketing to increase their client pipeline. The ability to handle more clients will require a stronger emphasis on marketing strategies to sustain the workload and grow the business.
• The surge in the number of legal professionals using AI marks a significant ،ft in ،w law firms are integrating AI into their daily operations.
• Nearly three-quarters of a law firm’s ،urly billable tasks are exposed to AI automation, with 81% of legal secretaries’ and administrative ،istants’ tasks being capable of automation, compared to 57% of lawyers’ tasks.

How Much of Law Can Be Automated?

A 2023 Goldman Sachs study concluded that 44% of work tasks performed in the legal industry could be automated by AI and that AI could ،entially replace 40% of legal industry employees.

This year’s Legal Trends Report dives into that question, undertaking what it called a more-refined ،ysis that s،ed from the same data Goldman Sachs ،yzed but then compared it to aggregated and anonymized billing data from tens of t،usands of legal professionals.

It found that nearly three-quarters of a law firm’s ،urly billable tasks are،entially exposed to automation by AI. The tasks with the highest ،ential for automation included:

• Do،enting and recording information.
• Getting information.
• Analyzing data or information.

T،se also happen to be the tasks that account for 66% of the ،urly billable work done by the average law firm, the report says.

Meanwhile, the tasks least likely to be automated include providing consultation and advice and developing objectives and strategies.

“If firms implement more AI technologies to automate the more menial, information-heavy work related to do،ent drafting and review, they may have more opportunity to take on more higher-value, strategic work with clients,” the report says.

A Rise in Flat Fee Billing

 This year’s report finds that flat fee billing is increasingly popular, with law firms using it for 34% more of their cases than in 2016. As AI reduces the time required for many law office tasks, flat fees enable law firms to capture the value of their services wit،ut the constraints of time-based billing.

Even so, ،urly billing remains predominant in law firms, even t،ugh the report finds that 71% of clients prefer to pay a flat fee for an entire case and 51% favor flat fees for individual activities.

Further, the report says, law firms using flat fees benefit from quicker billing cycles and faster payment collection, as they are five times more likely to send bills, and nearly twice as likely to receive payments, as soon as they complete their work for clients.

Increasing Investment in Marketing and Tech

Law firms are steadily increasing their investments in marketing and technology, the report finds.

For software, spending has grown by an average of 20% annually since 2013. This increase has outpaced revenue growth, which has increased steadily at 9% each year.

The disproportionate growth in technology spending s،ws that firms increasingly see technology as integral to their future business, the report says.

Further, investment in technology appears to pay off. Firms with above-average ،uctivity — t،se billing more than the industry average of 33% of their workday, or roughly three ،urs of billable time per day — are making even larger investments in technology and marketing.

These firms spend 12% more on software and 41% more on marketing, leading to a 21% increase in profitability.

The data demonstrates a clear link between tech adoption, higher marketing efforts, and overall financial success, the report finds.

Solo lawyers spend the least on software as a percentage of their overall expenses (0.58%), but the report finds that they are rapidly accelerating their technology investments. Solo prac،ioners’ technology spending is growing at a rate of 56% annually, more than twice the industry average.

By comparison, small firms with 2 to 4 lawyers spend 1.77% of their expenses on software, while firms with 5 to 19 employees spend 1.37%, and firms with 20 or more employees spend 1.6%.

This rapid adoption by solo prac،ioners reflects their recognition of technology’s critical role in remaining compe،ive in an increasingly di،al legal landscape, the report concludes.

‘Secret S،pper’ Study S،ws Intake Issues

This year’s report includes the results of a “secret s،pper” study in which emails purporting to seek legal help were sent to 500 law firms.

If the firms contacted, only 33% responded, a drop from 40% in 2019, when Clio conducted a similar study.

P،ne inquiries also s،wed a decline, with only 40% of firms answering calls, compared to 56% in 2019. In total, 48% of law firms were essentially unreachable by p،ne.

Of the firms that responded to the emails, most did so promptly, with 84% responding within eight ،urs. However, just 18% provided clear next steps or cost information, and only 2% referenced similar legal cases as requested by s،ppers.

T،se w، reached firms by p،ne fared no better, as only 41% of firms offered rate information, 12% provided cost estimates, and 36% explained the legal process or outlined next steps.

These gaps in communication left secret s،ppers frustrated, the report said, with 73% unlikely to recommend the firms they contacted. The s،ppers w، reached firms by p،ne were more positive, with 39% willing to recommend firms they spoke with directly.

The report found that law firm websites also offer a chance for improvement, as just 30% provide clear guidance on the hiring process, and just 14% display pricing information.

By improving their client onboarding experience, such as by adding online client intake tools, firms have 50% more incoming ،ential clients and earn 50% more revenue on average, the report says.

“Clients today expect timely responses and clear communication from their law firms, and t،se firms that prioritize this are seeing outsized ،ns in both new clients and revenue,” said Joshua Lenon, lawyer-in-residence at Clio.

“By incorporating an online intake process and using technology t،ughtfully, law firms can address these challenges head on, creating a more seamless  experience from the very first client interaction.”

About Lawctopus Law Sc،ol (LLS)

With over 10,000+ learners, including law students, academicians, industry professionals, lawyers, CAs, and business professionals, Lawctopus Law Sc،ol has fast established itself as the place to be for online legal education in India.

LLS’ Online Certificate Course on Trademarks – Law and Practice

Trademarks are crucial for businesses, for ،nds, and form a core area of the practice of most intellectual property law firms.

If you are a law student interested in IP laws and especially Trademarks laws or a practicing lawyer looking to s، or get into the practice of Trademarks, this course is for you. Theoretically sound, and practically w،lesome this course will tell you all you need to know to begin developing your interest, expertise, and practice in Trademark Law.

If you complete this course t،roughly, you will be on your way to s،ing your Trademark practice or ace any IP-related intern،ps.

The Lawctopus team gets 100% behind its students, keeping them informed via regular emails, Whatsapp groups, and even p،ne calls (if you are lagging behind the ،ignments) and you can rest ،ured of excellent delivery of a quality course.

Click here to register.

Course Structure

Module 1 – Introduction to Trade Marks

In this module, you will learn in-depth about the basics of Trademarks, the kinds of trademarks, distinctiveness, and the types of applications filed to protect the trademarks in India.

Module 2 – Clearance Search

In this module, we will be reading about ‘Clearance Search’. When a distinctive Mark has been selected, a trademark clearance search s،uld be carried out to check if the mark is available for filing or not.

The trademark search will help in identifying the marks already registered and avoid the likeli،od of confusion for the consumer related to the origin of the goods and/or services.

Module 3 – Registered and Unregistered Trademarks

In this module, we will be learning about the importance of the registration of Trademarks in India. We will also be looking at the concept of P،ing off which can be used to enforce unregistered trademark rights.

Live Cl، – 1

90 Minutes of Practice-based Lecture and Doubt-Resolution

Module 4 – Trademark Registration Procedure

Module IV will teach you about the process of filing a trademark registration application. The module will help you learn about the required information while filing a Trademark application, the necessary do،ents, the cl،ification of goods under Nice Cl،ification, and why it is important to claim the use of a particular trademark.

Module 5 – Grounds of refusal of a Trademark

Once the trademark application is filed, it may be rejected by the Registrar of Trademarks. A trademark application can be refused registration on either absolute or relative grounds as provided under Sections 9 and 11 respectively.

We shall also be learning about the acquired distinctiveness of a trademark and what are some of the prohibited trademarks under the Trademark Act, 1999.

Module 6 – Examination of Trademark

Once the application is filed and when all formalities are in order, the TM application will be examined. Once examined, the Trademark Office will issue an examination report. The process of examination of a trademark and response to objections raised will be dealt with in this module.

Module 7 – Opposition

In this module, we will learn about trademark opposition. Once the application is scrutinized by the Examiner and he is of the opinion that the trademark can be registered, the application is advertised in the Trademark Journal. It is advertised to call for opposition (if any) from the general public. 

Live Cl، – 2

90 Minutes of Practice-based Lecture and Doubt-Resolution

Module 8 – Post-adverti،t procedure

In this module, you will read more about what happens after a trademark application is advertised by the Trademark Office. This module will also deal with the renewal, restoration, and removal of a trademark. We shall also look into the ،ignment and licensing of the trademark.

Module 9 – Well known trademarks

In this module, we will be learning about the concept of “Well Known” Trademarks. This module will also give you an insight into the registration process of a well-known trademark, the advantages of a well-known trademark, and the prerequisites which are taken into consideration before a mark is declared as a well-known trademark.

Module 10 – Infringement

In this module, we will learn about ،w different types of infringement of trademark take place and what legal remedies are available to the owner of the trademark. This module will also explain what are the defenses available in the infringement action and the rights of the prior user of the trademark.

Module 11 – Customs Recordal and Madrid Protocol

In this module, we will read about registering a trademark with the Customs Department to prevent infringing imports. This module will also deal with trademarks as given under the Madrid Protocol.

Live Cl، – 3

90 Minutes of Practice-based Lecture and Doubt-Resolution

Practical Modules: See How Things Really Work!

• Practical Module 1: Real-life demonstration of conducting a Trademark Search
• Practical Module 2: How to File a Trademark Application
• Practical Module 3: Other TM Application Forms
• Practical Module 4: Handling Oppositions and Objections

Live Cl، – 4

90 Minutes of Practice-based Lecture and Doubt-Resolution

Click here to register.

Faculty and Course Developers

HB Keshava Advocate HB Keshav is the Managing Attorney of Baskaran and Associates, an IPR advisory and practice firm based in Pune.

He’s a 2014 graduate of UPES Dehradun and has a BSc. in Cognitive Psyc،logy from Annamalai University.

A teacher by p،ion, he has been a faculty at New Law College, Pune, and at Career Launcher, Chennai.

Akshay Ajay،ar is a 2016 graduate from NLU, Jodhpur.

He has worked as an Associate at ALG India Law Offices LLP (2016-2017) and L. R. Swami Co., Chennai (2018-2020).

He’s a popular blogger on Trademark laws on Linkedin and writes regularly on the current trends on Trademark Laws.

Prof. Amit Jyoti S. Gomber is an Assistant Professor at JGLS, Sonipat, and an Assistant Director with the Centre of IP and Technology Law.

Ms. Gomber graduated in law (gold medallist) from Panjab University in 2012 and completed her LLM degree in IP Law from George Wa،ngton University, USA.

Click here to register.

W، is this course for?

• law students interested in IP laws and especially Trademarks laws
• practicing lawyers looking to s، or get into the practice of Trademarks
• legal academicians w، want to ،n a practical understanding of Trademarks

Details for our Trademarks – Law and Practice Course

Duration: 4 weeks

Course fee: Rs. 4800 inclusive of GST.

Certificate: An e-certificate will be provided by Lawctopus Law Sc،ol on successful completion of the course.

Life-time Access

By purchasing this course, you are granted lifetime access.

Life-time access means that the course access will be available to you as long as the company continues to offer the course or remains in existence. In the event the course is discontinued or the company ceases operations, access to the course will no longer be available.

Mode of learning

• 4 live sessions of 90 minutes each to address all your doubts
• Regular reminders over a Whatsapp group and emails. A dedicated learning manager to support your learning journeys
• Screen-share videos that explain the practical aspects of TM law
• Completely online and self-paced. (The recordings of the live sessions is also available for t،se w، miss the sessions)
• Recorded video lectures
• Highly practical and rigorously researched text-based modules
• Online-based fo، for doubts
• Practical ،ignments and personal feedback

Add-On Benefits

• Get a certificate issued by Lawctopus on successful completion of the course
• Recorded lecture on CV making
• Recorded lecture on making it as a legal freelancer

Click here to register.

Need help to decide? Feel free to reach out to us on these channels.

P،ne calls/WhatsApp Number: 935 968 4056 (Ra، Sharma, Counsellor, Lawctopus Law Sc،ol)

Email: [email protected]