1. “Whether a state trade secret claim that requires resolution of who invented a patent claim, and whether patent claims read on an industry standard, ‘necessarily raises’ a federal issue sufficient for jurisdiction under 28 U.S.C. §1441, per Gunn v. Minton, 568 U.S. 251 (2013), and, whether the panel’s ‘lack of an adequate explanation of the basis’ for relying on a trade secret claim that was never raised violates Dennison Mfg. Co. v. Panduit Corp., 475 U.S. 809 (1986).” 2. “Whether a party must have a state court’s permission to bring patent counterclaims before a case becomes removable under 28 U.S.C. §1454, when every rule of statutory construction refutes that conclusion.”
