The Power and Limits of Judicial Claim Correction
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The Power and Limits of Judicial Claim Correction
"The Federal Circuit reversed a district court's indefiniteness holding, ruling that courts have authority to correct an obvious claim error through claim construction where the error is evident on the face of the patent and only one reasonable correction exists. Canatex Completion Solutions, Inc. v. Wellmatics, LLC, No. 2024-1466 (Fed. Cir. Nov. 12, 2025). The court relied upon its own prior precedent and referred back to the foundational case of I.T.S. Rubber Co. v. Essex Rubber Co., 272 U.S. 429 (1926) that permits judicial correction"
"When defendants challenged the claims as indefinite for lack of antecedent basis, Canatex argued that "second" was an obvious error that should be construed as "first," pointing to the claim language and specification showing that only the first part has a connection profile and that this is what gets released when the two parts disconnect. The S.D. Tex. Judge Alfred Bennett rejected the patentee's argument and instead found the claims invalid as indefinite."
The Federal Circuit reversed a district court finding of indefiniteness and held that a court may correct an obvious claim error through claim construction when the error is evident on the patent's face and a single reasonable correction exists. The patent claims a releasable connection device with a "first part" and "second part," but the claims mistakenly referenced the "connection profile of the second part" despite earlier identifying a connection profile of the first part. Defendants challenged indefiniteness for lack of antecedent basis. The patentee argued "second" was an obvious error that should read "first."
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