It is back to state court for Acer America Corp., after the Federal Circuit held that Acer’s state law trade secret claims should never have been removed to federal court in the first instance. Intellisoft Ltd. v. Acer America Corp., No. 19-1522. Vacating the district court’s judgment in Acer’s favor, the Federal Circuit reiterated longstanding precedent that only a “special and small category” of cases involving state law claims, such as those requiring resolution of a substantial patent question, give rise to federal subject matter jurisdiction. Cases in which a party merely uses patents as evidence of trade secret misappropriation are not among them.