It is unclear whether an in house lawyer who conducts litigation for her employer and who moves to a new employer is subject to the strict rules on conflicts of interest laid down for external firms of solicitors by the House of Lords in Bolkiah v KPMG. The Court of Appeal was divided in its opinion as to whether a barring order would be appropriate in such circumstances or whether relief should be limited to injunctive relief under the Faccenda Chicken v Fowler line of authority. The court was agreed that an employed patent attorney stands in exactly the same position as an in-house lawyer (Generics (UK) Ltd v Yeda Research & Development Co Ltd).