Our Patent Case Summaries provide a weekly summary of the precedential patent-related opinions issued by the Court of Appeals for the Federal Circuit and the opinions designated precedential or informative by the Patent Trial and Appeal Board.
Canatex Completion Solutions, Inc. v. Wellmatics, LLC, et al.
No. 2024-1466 (Fed. Cir. (S.D. Tex.) Nov. 12, 2025). Opinion by Taranto, joined by Moore and Prost.
Canatex owns a patent directed to a “releasable connection” tool used in operations in oil and gas wells. After Canatex sued Wellmatics and others for infringement, they challenged the validity of the patent on the ground that the claims are indefinite for lack of an antecedent basis for the phrase “the connection profile of the second part.” Canatex agreed that a required antecedent basis was missing but argued that the phrase contains an evident error with an evident simple solution: correcting “second” to “first.” The district court disagreed and found the claims invalid for indefiniteness. Canatex appealed.
The Federal Circuit reversed, concluding that “it is evident that the claim contains an error and that a relevant artisan would recognize that there is only one correction that is reasonable given the intrinsic evidence.”
In so ruling, the Federal Circuit noted “the very demanding standards for judicial correction of a claim term.” Meeting those standards here requires asking “whether the intrinsic evidence clearly establishes that ‘second’ in the claim phrase could only be reasonably understood by a relevant skilled artisan to mean ‘first.’” The court answered that question in the affirmative, and did so “de novo as a matter of claim interpretation based entirely on intrinsic evidence.”
The court stated that it “has repeatedly held that judicial correction of errors in patents is proper in narrow circumstances.” The court identified three elements of the standard. “First, one necessary requirement is that the error must be evident from the face of the patent … , i.e., obvious, as determined from the point of view of one skilled in the art.” “Second, another necessary requirement is that correction is appropriate only if (1) the correction is not subject to reasonable debate based on consideration of the claim language and the specification and (2) the prosecution history does not suggest a different interpretation of the claims.” “Third,” the court has ruled that a district court “may correct obvious minor typographical and clerical errors in patents.” The Federal Circuit noted it has not said this third element is a necessary requirement, but “it may well be,” and in this case the court “assume[d] that it is.”
Applying the standard, the Federal Circuit concluded that judicial correction of Canatex’s claims is appropriate because “the existence of an error in the phrase at issue is evident (obvious) on the face of the patent, and there is only one reasonable correction, considering all the intrinsic evidence, including the prosecution history.” Also, the correction “plainly is simple and ‘minor’ as a textual matter.” “And it follows that the fact of error and uniqueness of the small correction mean that the error is properly characterized as a minor clerical or typographical error.” The Federal Circuit thus reversed and remanded.
Smartrend Manufacturing Group (SMG), Inc. v. Opti-Luxx Inc.
Nos. 2024-1616, -1650 (Fed. Cir. (W.D. Mich.) Nov. 13, 2025). Opinion by Dyk, joined by Linn and Stark.
Smartrend owns two patents—a design patent and a utility patent—that are directed to an illuminated school bus sign. Smartrend sued Opti-Luxx for infringement of both patents.
The design patent claims “the ornamental design for an LED light panel, as shown and described.” In the description, the patent indicates that “oblique shading lines visible in the front and perspective views denote transparency.” The district court construed the term “transparency” to mean both “transparent” and “translucent.”
As to the utility patent, the district court construed the claim term “frame” to be “a separate and distinct” component. Because the accused product did not have a separate frame, the court granted summary judgment of no literal infringement. The case then proceeded to trial under a theory of doctrine of equivalents infringement.
A jury found that Opti-Luxx infringed both patents. The district court denied Opti-Luxx’s motion for judgment as a matter of law (JMOL), and Opti-Luxx appealed.
The Federal Circuit first considered the design patent. Opti-Luxx objected to the admission of Smartrend’s expert testimony regarding infringement because he had conceded he is not an ordinary observer himself and had not worked with ordinary observers before. The Federal Circuit stated that it had “not yet had the occasion to decide what exactly qualifies an expert witness to testify as to the perspective of the ordinary observer” but that “it seems logical that the[] same principles [in the utility patent context] will apply in a design patent context—such that expert witnesses may possess knowledge beyond that of ordinary observers yet still testify as to the perspective of an ordinary observer, provided the expert can establish familiarity with that perspective.” But the court ruled that it need not decide that issue because Opti-Luxx forfeited its objection to the expert’s testimony.
Turning to the district court’s construction of “transparency,” the Federal Circuit held that the court erred in holding that “transparency” includes “translucent.” “Transparency is not synonymous with translucency and does not mean both transparent and translucent.” Thus, the Federal Circuit reversed the construction, vacated the judgment of infringement, and remanded.
The Federal Circuit next addressed the utility patent. The court upheld the district court’s construction of “frame” to mean “a separate, distinct component” from the remainder of the sign. The specification “repeatedly, consistently, and exclusively” referred to a “separate” mounting frame, and it “describes functions of the claimed invention that cannot be performed by a sign with an integrated frame.” Thus, summary judgment of no literal infringement was proper.
As to the doctrine of equivalents, the court agreed with Opti-Luxx that no reasonable jury could have found that the accused products infringed. “The undisputed evidence shows that the accused device does not perform the required functions.” Therefore, the Federal Circuit reversed the district court’s denial of JMOL as to the utility patent.