In 3M Company v. Avery Dennison Corp., No. 11-1339 (Fed. Cir. Mar. 26, 2012), the Federal Circuit vacated and remanded the district court’s dismissal of a DJ action for lack of a case or controversy. Notably, the Federal Circuit determined that telephonic communications between the parties, without a formal cease-and-desist letter with prescribed deadlines, may support DJ jurisdiction. See this month’s edition of Last Month at the Federal Circuit for a full summary of this decision.