Read the following excerpt from a US court opinion:
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was not appropriately incorporated by reference into the '889 patent for this point and even if it had been, that Dickinson effectively teaches away from claim 13 because in deactivating those genes responsible for expressing the pathway, isobutanol production was “virtually abolished.” Id. Notwithstanding the shortcomings of the foregoing, Butamax has identified sufficient evidence that at least creates a genuine dispute of material fact. Gevo makes much of the fact that Dickinson, though cited in the '889 patent, was not cited in connection with the deactivation of this pathway and was not incorporated by reference into the patent. Nonetheless, Dickinson’s teachings still reflect what was known in the art. See Falko-Gunter Falkner v. Inglis, 448 F.3d 1357, 1368 (Fed.Cir.2006) . Dickinson does show that persons of ordinary
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What is the most suitable continuation to the opinion? Your options are:
A. holding that where accessible literature sources clearly provided a description of the teachings at issue the written description requirement does not require their incorporation by reference
B. holding that words which expressly refer to adequate legal description provide nucleus of description that is legally sufficient for statute of frauds
C. holding finding of reliability not clearly erroneous despite lack of prior description
D. holding that description was sufficiently detailed
E. holding that a written description analysis occurs as of the filing date sought
Reply with [A, B, C, D, E] only.