Phylogenetic Relationships of the Enigmatic Malesian Fern Thylacopteris (Polypodiaceae, Polypodiidae)

Thylacopteris is the sister to a diverse clade of polygrammoid ferns that occurs mainly in Southeast Asia and Malesia. The phylogenetic relationships are inferred from DNA sequences of three chloroplast genome regions (rbcL, rps4, rps4‐trnS IGS) for 62 taxa and a fourth cpDNA sequence (trnL‐trnF IGS) for 35 taxa. The results refute previously proposed close relationships to Polypodium s.s. but support suggested relationships to the Southeast Asiatic genus Goniophlebium. In all phylogenetic reconstructions based on more than one cpDNA region, we recovered Thylacopteris as sister to a clade in which Goniophlebium is in turn sister to several lineages, including the genera Lecanopteris, Lepisorus, Microsorum, and their relatives. Goniophlebium and allies comprise a significant component of vascular fern epiphytes in the rain forests of Southeast Asia and Malesia. The relationships of the genus Thylacopteris as at the base of the clade comprising the genera Goniophlebium, Lecanopteris, Lepisorus, Microsorum, and their relatives indicate that this entire lineage arose in Malesia and subsequently dispersed to continental Asia, Australia, the Pacific, and Africa

Brief of Amici Curiae 56 Professors of Law and Economics in Support of Petition of Writ of Certiorari

28 U.S.C. § 1400(b) provides that a defendant in a patent case may be sued where the defendant is incorporated or has a regular and established place of business and has infringed the patent. This Court made clear in Fourco Glass Co. v. Transmirra Prods. Corp., 353 U.S. 222, 223 (1957), that those were the only permissible venues for a patent case. But the Federal Circuit has rejected Fourco and the plain meaning of § 1400(b), instead permitting a patent plaintiff to file suit against a defendant anywhere there is personal jurisdiction over that defendant. The result has been rampant forum shopping, particularly by patent trolls. 44% of 2015 patent lawsuits were filed in a single district: the Eastern District of Texas, a forum with plaintiff-friendly rules and practices, and where few of the defendants are incorporated or have established places of business. And an estimated 86% of 2015 patent cases were filed somewhere other than the jurisdictions specified in the statute. Colleen V. Chien & Michael Risch, Recalibrating Patent Venue, Santa Clara Univ. Legal Studies Research Paper No. 10-1 (Sept. 1, 2016), Table 3. This Court should grant certiorari to review the meaning of 28 U.S.C. § 1400(b) because the Federal Circuit’s dubious interpretation of the statute plays an outsized and detrimental role, both legally and economically, in the patent system

Brief of Amici Curiae 56 Professors of Law and Economics in Support of Petition of Writ of Certiorari

28 U.S.C. § 1400(b) provides that a defendant in a patent case may be sued where the defendant is incorporated or has a regular and established place of business and has infringed the patent. This Court made clear in Fourco Glass Co. v. Transmirra Prods. Corp., 353 U.S. 222, 223 (1957), that those were the only permissible venues for a patent case. But the Federal Circuit has rejected Fourco and the plain meaning of § 1400(b), instead permitting a patent plaintiff to file suit against a defendant anywhere there is personal jurisdiction over that defendant. The result has been rampant forum shopping, particularly by patent trolls. 44% of 2015 patent lawsuits were filed in a single district: the Eastern District of Texas, a forum with plaintiff-friendly rules and practices, and where few of the defendants are incorporated or have established places of business. And an estimated 86% of 2015 patent cases were filed somewhere other than the jurisdictions specified in the statute. Colleen V. Chien & Michael Risch, Recalibrating Patent Venue, Santa Clara Univ. Legal Studies Research Paper No. 10-1 (Sept. 1, 2016), Table 3. This Court should grant certiorari to review the meaning of 28 U.S.C. § 1400(b) because the Federal Circuit’s dubious interpretation of the statute plays an outsized and detrimental role, both legally and economically, in the patent system

Taxonomy based on science is necessary for global conservation

Peer reviewe

Data from: Seasonal changes in starch content in trophopods of Matteuccia struthiopteris

Trophopods are modified stipe bases that function as starch-storage organs in a wide variety of mainly temperate ferns. Ever since they were first observed, the presence of trophopods has been explained by reference to seasonality and they have been assumed to provide nutrition for the rapidly expanding fern leaves in spring. We present the results of an analysis of the annual variation in starch content in Matteuccia struthiopteris (L.) Todaro, cultivated in the Leiden botanical garden. Our results show a distinct seasonal variation in starch content, suggesting that the presence of trophopods is indeed functionally linked to seasonality, but we do not find a decrease in starch content corresponding to the period of leaf expansion that would clearly link the depletion of stored starch to the expansion of new leaves