The decision does not address whether Fortress Iron made reasonable efforts to locate Huang or what standard courts will apply to such efforts going forward. The opinion also does not clarify whether partial correction under § 256—adding some but not all omitted inventors—creates any intermediate legal status for the patent.
Patent owners should treat inventorship accuracy as a threshold compliance matter. The Federal Circuit's strict approach means that discovering omitted inventors late in a patent's life, or being unable to contact them, creates genuine invalidation risk that § 256 may not cure. Counsel should audit inventorship records early and maintain contact information for all contributors to patented technology. For litigators, this decision signals that defendants will continue pressing inventorship defects as a straightforward path to invalidity when records are incomplete.