Species Claims Invalidated by Genus Prior Art and a Lack of Secondary Indicia of Non-Obviousness ) The U.S. Court of Appeals for the Federal Circuit upheld the U.S. District Court for the District of New Jersey's finding of patent invalidity on the basis of obviousness, but did not reach the issue of invalidity due to double patenting, in this Hatch-Waxman patent infringement action. Prometheus Laboratories, Inc. v.