For the record, Samiam *did* cite Surgisil in its summary judgment brief, albeit in its discussion of obviousness: https://www.scribd.com/document/619555735/Samiam-v-Coopersburg-Samiam-MSJ-Brief

Note that SurgiSil did not address the issue of primary references (or § 103 at all). But I think this is a fair reading of the logical implications of SurgiSil.

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