Affymax, Inc. v. Ortho-McNeil-Janssen Pharmaceutical Research and Development, LLC

Dist. Ct. erred in vacating portion of arbitration award that found that defendant had solely invented and owned certain foreign patents, after finding that arbitration panel had disregarded law when finding in favor of defendant as to ownership of foreign patents. Dist. Ct.'s rationale is not contained in any of four areas that arbitration award may be vacated under Federal Arbitration Act, and Dist. Ct.'s conclusion that arbitrators disregarded law by failing to discuss foreign patents separately from domestic patents did not justify vacatur of award. Ct. further noted that Dist. Ct. had failed to identify law that arbitrators had violated.