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Does a patentee bear the burden of proving infringement when a licensee brings a declaratory judgment action to establish non-infringement? See “Court to clarify burden of proof in Medtronic ‘non-infringement’ action” Medtronic, Inc. v. Boston Scientific Corp., No. 12-1128. Certiorari granted: May 20, 2013. Ruling below: 695 F.3d 1266 (Fed.Cir. 2012).