Fresh From the Bench: Latest Federal Circuit Court Case
CASE OF THE WEEK
Nature Simulation Systems Inc. v. Autodesk, Inc., Appeal No. 2020-2257 (Fed. Cir. Jan. 27, 2022)
In its only precedential patent decision this week, the Court of Appeals for the Federal Circuit corrected what it considered to be an incorrect standard for claim indefiniteness applied by the U.S. District Court for the Northern District of California. In doing so, the Federal Circuit reversed the lower court’s holding that claims of Nature Simulation Systems, Inc.’s (NSS’) 10,120,961 and 10,109,105 patents were indefinite.
The lower court declared the claims indefinite because there were “unanswered questions” contained in them. The Federal Circuit rejected the lower court’s position that all questions must be answered within the claim language, explaining that a claim is viewed and understood not solely on what is in the claim language but on the context of the specification, the prosecution history, and extrinsic evidence concerning relevant scientific principles, the meaning of technical terms, and the state of the art. After rejecting the lower court’s “unanswered questions” standard, the Federal Circuit remanded the case for further proceedings.
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By Tyler Hall
Edited by: Scott D. Eads and Nika Aldrich, Schwabe Williamson & Wyatt
Contributor: Tyler Hall