Summary: CAFC affirms claim construction.
Case: Astrazeneca AB v. Hanmi USA, Inc., No. 2013-1490 (Fed. Cir. Dec. 19, 2013) (non-precedential). On appeal from D.N.J. Before Dyk, Moore, and Taranto.
Procedural Posture: Plaintiffs appealed district court’s claim construction of the term “alkaline salt,” which was construed to be limited to salts specifically identified in the patent. CAFC affirmed.
- Claim Construction: The CAFC affirmed the district court’s finding that the written description of the patent limited the construction of the claim term “alkaline salt” to certain specifically named salts. The CAFC concluded that the written description contained a clear disclaimer of any salt other than the 6 cations enumerated in the patent, and that the disclaimer was not overcome by any of the other aspects of the intrinsic record.