Wells Fargo analyst David Maris that the U.S. Patent Office's Trials and Appeal Board issued yesterday Final Written Decisions for six inter partes reviews of the patents covering Jazz Pharmaceuticals' Xyrem's specialized distribution system, or REMS program. The PTAB found the petitioners, generic filers Par and Amneal, had shown by a preponderance of the evidence that the challenged claims of patents are unpatentable, Maris tells investors in a research note. After speaking to the company, Maris says he would not be surprised if Jazz appeals PTAB's decisions on the six patents to the U.S. Federal Circuit, which he notes typically results in a final decision in 12 to 18 months. Yesterday's news is incrementally negative for Jazz, but "several significant hurdles" remain for generic filers, Maris contends. The analyst keeps an Outperform rating on Jazz shares with a $173-$177 price target range. The stock dropped 2% last night in after-hours trading to $139.00.