35 U.S.C. § 101 limits an inventor to only one patent per invention. Courts have extended this limitation by crafting the judicially created doctrine of obviousness-type double patenting (“ODP”),1 which “prohibit[s] the issuance of the claims of a second patent that are not patentably distinct from the claims of the first patent.”2
Two policy rationales underlie ODP. The first is to prevent an unjustified time-wise extension of the right to exclude granted by a patent, while the second is to protect potential infringers from “harassment by multiple assignees” when the primary and reference patents or applications are owned by different parties.3
 In re Longi, 759 F.2d 887, 893 (Fed. Cir. 1985).
 In re Janssen Biotech, Inc., 880 F.3d 1315, 1318 (Fed. Cir. 2018).
 In re Hubbell, 709 F.3d 1140, 1145 (Fed. Cir. 2013).