Mealey's (November 14, 2018, 7:40 AM EST) -- WILMINGTON, Del. — A Delaware federal magistrate judge on Nov. 13 recommended that L’Oreal S.A. be dismissed from a patent infringement action because its ownership of a U.S. patent is insufficient to support the exercise of personal jurisdiction and because a plaintiff also failed to show that jurisdiction is proper under theories of agency and stream of commerce (University of Massachusetts Medical School, et al. v. L’Oreal S.A., et al., No. 17-868, D. Del., 2018 U.S. Dist. LEXIS 192832)....