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ARTICLE · 24 DECEMBER 2013

Federal Circuit Patent Updates - December 2013

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Federal Circuit Patent Updates - December 2013

United StatesIntellectual Property
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Astrazeneca AB v. Hanmi USA, Inc. (No. 2013-1490, 12/19/13) (Dyk, Moore, Taranto)

December 19, 2013 8:09 AM

Taranto, J. Affirming judgment of noninfringement because the written description of the patent limited the claim term "alkaline salt" to certain specifically named salts. "The written description describes the invention clearly and narrowly as including only those salts, and AstraZeneca points to nothing in the intrinsic record that is sufficient to overcome that disclaimer." Statements in the specification "clearly confine the invention to the six identified cations, disclaiming anything else."

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