1. The history of � 271 demonstrates that, contrary to the Supreme Court's historical antipathy to patents, Congress has taken an expansive view of them, enlarging the class of activities covered by the patent statute's forms of infringement;See Holbrook;Threat of a Sale, supra note 9
2. discussing amendments to � 271); see also Timothy R. Holbrook, The Treaty Power and the Patent Clause: Are There Limits on the United States' Ability to Harmonize?;See Timothy;Territoriality Waning? Patent Infringement for Offering in the United States to Sell an Invention Abroad,2004
3. PAEs"), also known as trolls. See generally Colleen V. Chien, From Arms Race to Marketplace: The Complex Ecosystem and Its Implications for the Patent System, 62 HASTINGS L;One exception to Congress's favorable views of the patent system has been recent patent reform efforts to address patent assertion entities,2010
4. 617 F.3d 1296, 1310 n.4 (Fed. Cir. 2010) ("[The district court] never reached the factual issue of whether the subject of the offer to sell was of a 'patented invention' by analyzing the design of the rig;Of course