Dialing Up Fixes To Your Patent Claims: So Relaxing!

Holding

In American National Manufacturing Inc. v. Sleep Number Corp., Nos. 21-1321, 21-1323, 21-1379, 21-1382 (Fed. Cir. Sept. 29, 2022), the Federal Circuit held that as long as a claim amendment proposed during an IPR does not enlarge the scope of the claims, does not add new matter, and responds to a ground of unpatentability in the proceeding, the patent owner may also make additional amendments to a claim. The Federal Circuit also held that a clear typographical error does not render the claims unpatentable for lack of enablement.

Background

The inter partes reviews ("IPRs") on appeal involved challenges to U.S. Patent Nos. 8,769,747 ("the '747 patent") and 9,737,154 ("the '154 patent"), directed to "systems and methods that purport to adjust the pressure in an air mattress 'in less time and with greater accuracy' than previously known." Id. at *3. The patents disclose adjusting pressure in an air bed by measuring the air pressure inside the valve