The Federal Circuit has affirmed the invalidity of Satius's wireless-coupler patent, but on different grounds than the district court. In Satius Holding, LLC v. Samsung Electronics Co., the panel considered claim 1 of U.S. Patent No. 6,711,385, which recites an apparatus for transmitting electric or electromagnetic signals over air. Everyone agreed the electric-signal option is impossible, since electric signals do not travel through air.
Magistrate Judge Burke had held the claim indefinite on that basis. Chief Judge Moore's opinion, joined by Judges Lourie and Hughes, rejected that reasoning. The court held that a claim can be clear about its scope even when part of that scope is physically impossible. Instead, the panel found the claims invalid for lack of enablement, an issue the district court had considered waived.
Judge Hughes had previewed the result at oral argument, comparing the claim to a Star Trek transporter: everyone knows what is being claimed, but it is impossible because it is not enabled, not because it is indefinite. The precedential opinion adopts that view, shifting how inoperable claims are analyzed under patent law.