Claims must find support in the specification, despite that they may be obvious in light of that specification
The patentee filed a complaint with the International Trade Commission (ITC) alleging that the accused infringer was importing single serve coffee capsules that infringed claims of the patent-in-suit. The ITC concluded that the asserted claims were invalid for lack of written description and certain claims were anticipated. On appeal, the Federal Circuit affirmed the ITC on the basis that all asserted claims were invalid for the lack of written description.
The patent-in-suit addressed the incompatibility between single serve beverage brewers using cup-shaped beverage cartridges (e.g., the Keurig K-Cup) and systems using small pods, such as disc shaped filter paper packets containing coffee. The patent described a “pod-adaptor assembly” compatible with a K-Cup cartridge based system, with the assembly comprising a cup-shaped “receptacle” that could hold a “pod” and a “cover” to seal the receptacle. “Pod” was broadly defined as a “package formed of a water permeable material and containing an amount of ground coffee or other beverage therein.” The patent application originally claimed a “pod-adaptor assembly” with a “receptacle” adapted to provide a support surface for a “pod” but the allowed claims were directed to a “beverage brewer” with a “brewing chamber” and “a container…adapted to hold brewing material.” The alleged infringer’s accused coffee capsules were a K-Cup type design with an integrated mesh filter that could accept loose coffee grounds.
The court noted that the written description inquiry looks to the “four corners of the specification” to determine whether “the inventor(s) had possession of the invention as broadly claimed.” While “knowledge of ordinary artisans may be used to inform what is actually in the specification,” it may “not teach limitations that are not in the specification, even if those limitations would be rendered obvious by the disclosure in the specification.” Although ordinary artisans might have understood that an integrated filter could have been incorporated into a cartridge, the patent never discussed the possibility of a pod-adaptor assembly alone serving as the pod. The four corners of the patent did not demonstrate that the patentee had possession of such a system, and disclosure of a “pod-adaptor assembly,” “receptacle,” and “pod” could not support broader claims to a “container . . . adapted to hold brewing material.”