What was once considered settled law in joint infringement in patent litigation has been changing. The National Law Journal examines this recent shift in joint infringement jurisprudence. Previous decisions held that joint infringement existed only when one person performs the steps of a patent process. But other members of the patent bar have felt that the court has effectively rendered many Internet, software, and telecommunications enabled method patents unenforceable, where different or multiple individuals participate in performing the patented process. The Federal Circuit has agreed to hear an en banc rehearing in one of its cases which could determine the validity of many of these types of patents. Donald Dunner, partner at Finnegan, weighed in that, "people have expectations that when they filed these cases they'd be able to get patent protection. Suddenly they're told there's some special rule."