In Gilead Sciences, Inc. v. Lee, No. 14-1159 (Fed. Cir. Feb. 26, 2015), the Federal Circuit held that the PTO reasonably interpreted 35 U.S.C. § 154(b)(2)(C) to reduce patent term adjustment ("PTA") for a patent based on the filing of a supplemental information disclosure statement ("IDS") after a response to a restriction requirement.