In the Lovenox patent case where MNTA sued Amphastar and TEVA in US District Court, TEVA was able to get a summary dismissal by simply showing that TEVA’s Lovenox was produced in Italy and therefore not subject to a US manufacturing patent.
Why to have a mfg. patent then? You can always dodge that simply by manufacturing out of US? I don't think it would be that simple...
And if that's true, MNTA seems to foolish as they have handed-over their mfg. secrets to other exUS manufacturers to copy.