Arbutus wins partial summary judgment in Moderna patent case; enablement goes to trial

Arbutus Biopharma Corp

Court bars Moderna's obviousness defense: IPR estoppel applies to '435 Patent, issue preclusion bars routine-optimization and phospholipid-range arguments.
Arbutus's motion to exclude Moderna's obviousness expert Dr. Anderson granted.
Moderna's enablement defense survives: Dr. Prud'homme's testimony creates genuine factual dispute; trial needed on whether claims require undue experimentation.
Moderna's derivation defense dismissed for lack of evidence.
Court upholds that prior IPR final written decisions trigger statutory estoppel even without appeal; Moderna cannot relitigate previously rejected arguments.

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