Federal Circuit Affirms Invalidity of Satius Claims Against Samsung for Lack of Enablement

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Photo: analogicus / Pixabay

On 1 October 2026, the U.S. Court of Appeals for the Federal Circuit affirmed a Delaware judgment that claims 1, 11 and 18 of U.S. Patent No. 6,711,385 are invalid for lack of enablement under 35 U.S.C. § 112(a) (Satius Holding, LLC v. Samsung Electronics Co., Ltd., No. 2025-1446).

Chief Judge Moore wrote for the Court. On appeal, Satius challenged the district court's indefiniteness ruling. The Federal Circuit agreed that enablement could be reached and affirmed invalidity on that ground. The decision reinforces that claims must teach a person skilled in the art how to make and use the full scope of what is claimed, not merely describe a goal.

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