FDAnews
www.fdanews.com/articles/138601-judge-oks-expired-patents-label-in-cold-eeze-suit

Judge OKs Expired Patents Label in Cold-Eeze Suit

July 21, 2011
A New York federal judge said a label indicating a product was “developed under” expired patents did not imply the product was protected by those patents, granting a partial win to Cold-Eeze cough drop maker ProPhase Labs in a case alleging false patent marking.
Law360