On March 20, 2009, the U.S. Court of Appeals for the Federal Circuit (the "Federal Circuit") issued a 2–1 panel decision holding that the U.S. Patent and Trademark Office's (the "USPTO") final rules published on August 21, 2007, regarding continuation applications and examination of claims were procedural, that the continuation rules were invalid as inconsistent with section 120 of the Patent Act, and that the USPTO's limits placed on the filing of Requests for Continued Examinations