Intellectual property profs batting below the Mendoza line?

In baseball, the Mendoza Line is said to occur at a batting average of .200, and when a position player's batting average falls below that level, the player is said to be below the Mendoza Line. As a rule of thumb, the Mendoza line is the offensive floor below which a player's presence in the big leagues cannot be justified despite his defensive abilities. [see wikipedia]

The vote in the en banc Ariad case was 9-2, meaning that the IP profs who challenged the existence of a "written description" requirement batted 2 for 11 or .182, which is below the Mendoza line.

Can their presence in the IP big leagues be justified?

See also

Blogs quiet on Ariad?