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Currently, there is no effective treatment for many types of retinal degeneration. Nor are there sufficient treatments for autoimmune uveitis, as current uveitis treatment primarily uses steroidal anti-inflammatory medication, which can produce significant unwanted side effects with long-term use

In Merck KGaA v. Integra Lifesciences I, Ltd., 125 S. Ct. 2372 (Jun. 13, 2005), the Supreme Court considered the scope of the exemption from patent infringement embodied in 35 U.S.C. § 271(e)(1). Under §271(e)(1), also referred to as the safe harbor provision, "[i]t shall not be an act of