Federal Circuit Courts ae using rule 36 to avoid difficult subjecy matter: "Rule 36 affirmances at the Federal Circuit have been on the rise in recent years. This growing usage of one-word decisions from the Federal Circuit raises rather serious concerns, which justify many questions, including whether the Federal Circuit is simply using Rule 36 to avoid difficult subject matter, or to prevent meaningful review by a Supreme Court that has seemed keenly interested in second guessing so many important decisions reached by the Court in recent years"
http://www.ipwatchdog.com/2018/07/30/federal-.../id=99202/