Fresh From the Bench: Latest Precedential Patent Cases

CASE OF THE WEEK

Canatex Completion Solutions, Inc., Appeal No. 2024-1466 (Fed. Cir. Nov. 12, 2025)

In our Case of the Week, the Federal Circuit revisited and clarified the “demanding standard for judicial correction via claim construction,” which permits a court in narrow circumstances to modify claim language to correct obvious errors.  Plaintiff Canatex’s U.S. Patent No. 10,794,122 was directed to an oil- and gas-drilling device with a separable, “downhole” component that could be released by an operator on the surface—for example if it becomes stuck—and separated from the rest of the device for later retrieval.  The parties’ dispute concerned the claim phrase “the connection profile of the second part,” which Canatex argued a skilled artisan would understand to mean “the connection profile of the first part.”  Notwithstanding that the language appeared in every independent claim and was reflected multiple times in the patent’s specification, the Federal Circuit agreed with Canatex that it was an obvious error subject to judicial correction, reversing the lower court’s determination that the claims were indefinite.

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ALSO THIS WEEK

Smartrend Manufacturing Group (SMG), Inc. v. Opti-Luxx Inc., Appeal Nos. 2024-1616, -1650 (Fed. Cir. Nov. 13, 2025)

Following a jury verdict of infringement and issuance of a permanent injunction in a case concerning components of “school bus” vehicle signs, the Federal Circuit reversed denial of the defendant’s motion for judgment as a matter of law and vacated the injunction.  In so ruling, the Court emphasized the limiting effect of “as shown and described” language in design patents.  The Court explained that such language, when used to define a design, limits the scope of the patent’s protection to the drawings and accompanying written description of the patent.  In this case, the patent at issue contained oblique shading on certain surfaces, which the Manual of Patent Examining Procedures explained could indicate transparency or translucency.  But because the patent included “as shown and described” language in defining the design, both the drawings and the accompanying description were used to limit the patent’s scope.  The patent’s description stated that “oblique shading lines… denote transparency.”  Thus, the claims were limited to surfaces that were transparent, but not translucent.  By expanding “transparency” to include translucency, the district court improperly broadened the claimed design, requiring vacatur of the infringement judgment.

On a related utility patent, the Court found judgment of the defendant was also appropriate where an asserted “equivalent” did not perform the functions recited in the specification for the claim element at issue.

The opinion can be found here.

Editors:

Nika Aldrich, IP Litigation Group Leader, Schwabe

Jason A. Wrubleski, Shareholder

Contributors:

Jason Evans