The Federal Circuit reversed a district court's judgment as a matter of law in Teva Pharmaceuticals International GmbH v. Eli Lilly & Co., No. 2024-1094, upholding method-of-treatment patents directed to using anti-CGRP antagonist antibodies to treat headaches. The court held that written description and enablement requirements under 35 U.S.C. § 112 may be satisfied for method claims even when the claims recite a broad genus of antibodies defined by binding target without amino acid sequences. The decision distinguishes method-of-treatment claims from composition claims, finding the invention is the use of antibodies to treat headache rather than the antibodies themselves.