Board of Trustees of the Leland Stanford Junior University v. Roche Molecular Systems, Inc.

Summary

The Supreme Court resolved a patent ownership dispute between Stanford University and Roche over an HIV testing method developed by Stanford researcher Holodniy who also agreed to assign rights to Cetus. The Court held that the Bayh-Dole Act does not automatically vest title to federally funded inventions in federal contractors. Inventors retain ownership rights to their inventions absent an assignment. A dissent argued the Act presupposes contractor ownership, while a concurrence shared concerns about the lower court's assignment doctrine.