scott eads
Feb 1, 2022

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