SHIRE LLC v. AMNEAL PHARMACEUTICALS, LLC (Fed. Cir. 2015) (P) – The prior art must “teach a finite and limited class” that includes the compound claimed

For a broad reference to be considered as disclosing a particular chemical compound for prior art purposes, it must “teach a finite and limited class” that includes the compound claimed. Here, for example, a compound representing the active ingredient in a claimed...

SUMMIT 6, LLC v. SAMSUNG ELECTRONICS CO., LTD. (Fed. Cir. 2015) (P) – An element described as “being provided” in a particular way may not require a separate method step

A claim limitation describing a previously recited element as “being provided” in a particular way may be interpreted as a characteristic of that element rather than a separate method step. Here, for example, a “pre-processing” step at a client device in accordance...

DYNAMIC DRINKWARE, LLC v. NATIONAL GRAPHICS, INC. (Fed. Cir. 2015) (P) – A provisional application must also support the later filed claims to qualify as secret prior art

For a provisional application to qualify as secret prior art under 35 U.S.C. 102(a)(2) or pre-AIA 35 U.S.C. 102(e), it must support the claims of the application or patent asserting priority thereto. Here, for example, an otherwise anticipatory disclosure found in a...

MEDIA RIGHTS TECHNOLOGIES v. CAPITAL ONE FINANCIAL CORP (Fed. Cir. 2015) (P) – Inter-connection among components of a system is not by itself sufficient to avoid means plus function

Inter-connection among claimed components of a system is not by itself sufficient to avoid the application of § 112, ¶ 6. Here, for example, the claimed “compliance mechanism” was found to invoke application of § 112, ¶ 6 even though the specification describes how...