District Court holds that IPR estoppel does not apply to grounds denied institution on the merits By Tom Owens (US) on February 7, 2017 In Verinata Health, Inc. v. Ariosa Diagnostics, Inc., Judge Susan Illston of the Northern District of California held that the IPR estoppel statute, 35 U.S.C. § 315(e), does not apply to invalidity grounds asserted in an IPR petition but…