Commissioner for Patents United States Patent and Trademark Office P.O. Box 1450 Alexandria, VA 22313-1450 www.uspto.gov MEMORANDUM DATE: June 7, 2018 TO: Pa~~ng Corps FROM: ~ertW.B~ Deputy Commissioner for Patent Examination Policy SUBJECT: Recent Subject Matter Eligibility Decision: Vanda Pharmaceuticals Inc. v. West-Ward Pharmaceuticals On April 13, 2018, the U.S. Court of Appeals for the Feder