On October 2, 2026, the Federal Circuit issued a nonprecedential opinion by Judge Prost, for a panel that included Judges Dyk and Cunningham, affirming a final written decision of the Patent Trial and Appeal Board in post-grant review PGR2023-00022. Inari Agriculture, Inc. petitioned for the review, and the Board determined that claims 1 through 33 of Pioneer Hi-Bred International, Inc.'s U.S. Patent No. 11,371,055 are unpatentable for lack of enablement. The opinion is Pioneer Hi-Bred International, Inc. v. Inari Agriculture, Inc., No. 2025-1287. According to the opinion, representative claim 1 defines a genus of enzymes by both function and structure, while the specification provides only two example species. The court said the Board's decision was properly rooted in the Supreme Court's reasoning in Amgen Inc. v. Sanofi that "[t]he more one claims, the more one must enable." Pioneer's own experiments, performed more than a decade after the patent's priority date and submitted with its patent owner response, found that only two of eight tested enzymes meeting the claimed structural limitations had the dual herbicide-degrading function. The court said Pioneer's objection to post-priority data "appears to be forfeited because Pioneer did not raise the issue before the Board," and held that it "was not error for the Board to rely on the post-priority experimental data that Pioneer provided," because all tested variants of the claimed genus could have been created at the priority date.