Last week, Chief Judge Colleen McMahon of the Southern District of New York made clear that she is through “making findings” in a declaratory judgment action brought by Ferring Pharmaceuticals against Reprise Pharmaceutics and Serenity Pharmaceuticals over the drug desmopressin, taking the unusual step of handwriting on the face of a brief her reasons for terminating a motion to amend the judgment to prepare it for appeal to the Federal Circuit: “I refuse to ‘pretend’ that there is a valid patent to infringe and make findings as though there were one. In fact, I am DONE making findings”.