Today in Wells Fargo & Co. v. United States, __ F.3d __ (Fed. Cir. 2016)(Stoll, J.), in the course of dealing with a tax matter, the panel reiterated several principles that apply to all areas of the law including patent law:

“Last antecedent rule”:  “[T]he last antecedent rule [ ] requires that ‘a limiting clause or phrase ‘should ordinarily be read as modifying only the noun or phrase that it immediately follows.’ [Ener­gy East Corp. v. United States, 645 F.3d 1358, 1361 (Fed. Cir. 2011)] (quoting Barnhart v. Thomas, 540 U.S. 20, 26 (2003)).”

Presumption of Familiarity with Agency Practice:  “We presume that Congress is familiar with existing Federal law when it enacts a new statute.  See, e.g., Miles v. Apex Marine Corp., 498 U.S. 19, 32 (1990).”

Regards,
Hal