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ARTICLE · 12 NOVEMBER 2026

Federal Circuit Affirms Invalidity Challenge To Scientifically Impossible Claim Language On Enablement Grounds

Finnegan, Henderson, Farabow, Garrett & Dunner LLP
Finnegan, Henderson, Farabow, Garrett & Dunner LLP
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The Federal Circuit affirmed invalidity of a patent claiming transmission of electric signals over air—a scientifically impossible feat—but diverged from the lower court by basing its decision on enablement rather than indefiniteness grounds. This case explores the critical distinction between claim definiteness and enablement under 35 U.S.C. § 112, particularly when patent claims encompass scientifically impossible embodiments.

United StatesIntellectual Property
Erin Lynch
Erin Lynch
Christopher Anderson
Christopher Anderson
Erik Puknys
Erik Puknys
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In Satius Holding, LLC v. Samsung Electronics Co., Ltd., No. 25-1446 (Fed. Cir. Oct. 1, 2026), the Federal Circuit affirmed an invalidity finding for Satius’ U.S. Patent No. 6,711,385 but did so on enablement grounds rather than the indefiniteness grounds relied on by the district court.

Satius sued Samsung for infringement of the ’385 patent, which claims a communications apparatus capable of transmitting electric (along with electromagnetic) signals over air—a feat that both parties agreed is scientifically impossible. As a result, the district court held the asserted claims indefinite and entered a final judgment of invalidity in favor of Samsung. Satius appealed, challenging the finding of indefiniteness. In reply, Samsung argued that the claims were invalid for lack of enablement even if found to be definite

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