“Our cases instruct that when a patent describes the features of the ‘present invention’ as a whole, this description limits the scope of the invention.”
Background / Facts: The patent here is directed to “a spring-actuated desktop stapler that … relates to an improved staple track and staple ejection features.” It describes a few improvements for desktop staplers, including an “automatic track opening function.” Descriptions of the automatic track opening feature and its advantages are repeated throughout the specification. Nevertheless, the district court determined that the claims at issue cover both automatic and manual track openings based on the broader language of the claims.
Issue(s): Whether the description of the “invention” in the specification limits the broader language of the claims to only automatic track opening staplers.
Holding(s): Yes. “[W]e conclude that the claim is limited to track pulls that open automatically when the stapler handle and body are rotated away from the stapler base.” The specification makes it clear that the automatic opening feature is central to the invention. Most notably, the specification contrasts the automatic opening feature with “a typical prior art stapler without the automatic opening feature of the present invention.” The patent also contains several other references that characterize the automatic opening feature as central to the “present invention” (“present invention provides an automatic track opening function”; “improvement of the present invention is an automatic opening mechanism”).