Article: Written Description - A Must Or Not?

Originally published December 17, 2004

INTRODUCTION

Recently, the United States Court of Appeals for the Federal Circuit strongly reaffirmed a patentee's obligation to provide a written description in a patent to comply with the written description requirement of 35 U.S.C. s.112 [micro]1. The Federal Circuit rendered this decision in University of Rochester v. G.D. Searle & Co.[i] Specifically, the Federal Circuit upheld the Federal District Court for the Western District of New York's decision[ii] to invalidate the University of Rochester's patent[iii] based on the patentee's failure to comply with the written description requirement of s.112. This ...

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