WASHINGTON, D.C. - A dispute over discrete segments of DNA capable of enhancing the expression of one or more functionally associated genes was properly resolved by a California federal judge with a grant of summary judgment of noninfringement, the Federal Circuit U.S. Court of Appeals ruled March 22 (Sanofi-Aventis Deutschland GmbH v. Genentech Inc. and Biogen Idec Inc., No. 11-1397, Fed. Cir.; 2012 U.S. App. LEXIS 5985).