On December 23, 2014 Chief ALJ Bullock denied a motion for judicial enforcement of a subpoena ad testification in Certain Hemostatic Products, No. 337-TA-913. The subpoena, which was issued by Respondent Ferrosan Medical Devices, sought to compel the testimony of Kilpatrick Townsend & Stockton LLP, which was prosecution counsel for the patents at issue in the Investigation. Judge Bullock held that Ferrosan failed to establish “the purpose, relevance, and reasonableness” of the subpoena “in a particularized manner” as required by Commission Rule 210.32. He found that Ferrosan’s claims that it needed information “in order to fully investigate Baxter’s infringement allegations as well as Ferrosan’s defenses,” and that the information was “critical to Ferrosan’s defenses of invalidity, prosecution history laches, inequitable conduct, and patent misuse” are conclusory statements that do not warrant judicial enforcement.