Implicit Redefinition Of Claim Scope

Although "the words of a claim are generally given their ordinary and customary meaning," Thorner v. Sony Computer Entm't Am. LLC, 669 F.3d 1362, 1365-67 (Fed. Cir. 2012), if the specification reveals "a special definition given to a claim term by the patentee that differs from the meaning it would otherwise possess[,] . . . the inventor's lexicography governs," Phillips v. AWH Corp., 415 F.3d 1303, 1316 (Fed. Cir. 2005) (en banc).  The Federal Circuit has recognized that determining when a patentee is acting as his own lexicographer can be difficult because "the distinction between using the specification to interpret the meaning of a claim and importing limitations from the specification into the claim can be a difficult one to apply in practice."  Id. at 1323; see also Bell Atl. Network Servs., Inc. v. Covad Commc'ns Grp., Inc., 262 F.3d 1258, 1268 (Fed. Cir. 2001).  Recently, in SkinMedica, Inc. v. Histogen, Inc., No. 2012-1560 (Fed. Cir. Aug. 23, 2013), the