The last element listed above — personal to the employer — can significantly diminish the value of a shop right. A personal right typically cannot be assigned or sublicensed. The Federal Circuit recently discussed this limitation in a nonprecedential opinion in Beriont v. GTE Laboratories, Inc. (No. 2013-1109, 8/9/13). In the case, GTE received an assignment of the patent from the inventor in 2005, but the inventor asserted that GTE’s rights prior to the assignment infringed the patent. The Court noted that GTE’s activity prior to 2005 was covered by the shop rights doctrine, but that it was unclear whether all that activity was within the scope of GTE’s personal shop rights.