At the end of betting in Monte Carlo casinos, the croupiers announce, “Les jeux sont faits. Rien ne vas plus.” Gamblers remain transfixed as they wait for the white ball to drop into a numbered slot of the roulette wheel. Biotech companies have a lot in common with these Monegasque gamblers. In June 2013, they watched the U.S. Supreme Court in Association for Molecular Pathology v. Myriad Genetics Inc., 569 U.S. 2013, eliminate patent protection for isolated DNA. Fortunately, the international biotech …