Opinions — Thursday, October 1, 2026

In re Satius Holding, Inc. involves an appeal from a Patent Trial and Appeal Board decision rejecting claim 1 of U.S. Patent No. 6,711,385 as obvious in an ex parte reexamination proceeding. The Federal Circuit dismissed the appeal as moot because it concluded claim 1 of the '385 patent is invalid in a companion case, Satius Holding, LLC v. Samsung Electronics Co., No. 2025-1446 (Fed. Cir. Oct. 1, 2026), and ordered no costs.

The Federal Circuit affirmed the District of Delaware's final judgment invalidating claims 1, 11, and 18 of U.S. Patent No. 6,711,385 owned by Satius Holding, LLC in its infringement suit against Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. The court reversed the district court's indefiniteness holding under 35 U.S.C. § 112(b), concluding that claim language reciting "transmitting electric or electromagnetic signals over air" was definite despite covering scientifically impossible embodiments, because the claim scope remained clear to a person of ordinary skill in the art even if inoperable. However, exercising discretion to reach an issue not decided below, the Federal Circuit held the same claims invalid for lack of enablement under 35 U.S.C. § 112(a), reasoning that the specification failed to enable the full scope of the claims where the claim language expressly encompassed transmitting electric signals over air—an undisputed scientific impossibility that cannot be made or used.

The decision establishes that impossibility and indefiniteness are distinct inquiries under Section 112, rejecting any per se rule that claims covering inoperable embodiments are necessarily indefinite. The court distinguished Synchronoss Technologies, Inc. v. Dropbox, Inc., where impossible claims were held indefinite because they were "nonsensical" and contradicted the specification's disclosure of the invention. Here, because both the claims and specification included the impossible limitation and the parties agreed on what the claim language meant, the Nautilus standard for reasonable certainty was satisfied. The enablement ruling reinforces that claims must enable their full scope as construed, applying Amgen Inc. v. Sanofi's principle that "the more one claims, the more one must enable" to invalidate claims expressly covering alternative embodiments that are physically impossible to practice, even where other claim scope may be operable.

The Federal Circuit affirmed the district court's dismissal of Truinject Corporation's tortious interference claim and summary judgment for Galderma S.A. on breach of contract, trade secret misappropriation, and damages claims. Truinject alleged that Galderma fraudulently induced it into an exclusive negotiation agreement to prevent partnership discussions with Allergan, then breached confidentiality obligations by sharing Truinject's proprietary training-system technology with third parties. The court held that Truinject forfeited its primary theory of intentional interference and could not establish damages causally linked to any breach.

On the intentional interference claim, the court applied Third Circuit forfeiture doctrine to conclude that Truinject failed to preserve its appellate argument that Galderma's pre-contract conduct—pressuring Truinject into the exclusivity agreement to torpedo the Allergan relationship—satisfied the intentional interference element. Truinject's district court briefing focused exclusively on post-agreement disparagement, never identifying the agreement's formation as the wrongful act, and Truinject declined to amend after dismissal without prejudice. On damages, the court affirmed summary judgment because Truinject's sole theory traced injury to canceling a November 2014 Allergan meeting upon entering the contracts, but the alleged breaches occurred afterward in December 2014, precluding the necessary causal link between breach and harm under basic but-for causation principles.