Supreme Court denies cert in both Vanda and HP v. Berkhimer

Leaving the only possibility for Section 101 reform this year with Congress.

Sadly, legislative reform seems unlikely this year – after much action in the summer of 2019, nothing happened.  And now, the likely champions for reform, Senators Coons and Tillis, are both up for reelection.  SCOTUS order list 13JAN2020