In Helsinn, the Supreme Court noted that Congress re-enacted the on-sale bar within the context of a substantial body of law finding the on-sale bar triggered by sales that do not disclose details of the invention to the public.
The Federal Circuit affirmed the ITC's ruling in Celanese International Corp. v. ITC, declaring Celanese's process patents invalid due to secret sales prior to the on-sale bar, pre-America Invents Act.
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