Case Law Review: Volume 11, No. 2
The Federal Circuit reaffirmed a core principle of patent law: a patent must describe what it claims—nothing more. In this decision involving Novartis and generic manufacturers of Entresto®, the court held that the written description requirement does not obligate a patentee to disclose later-discovered improvements that are not actually claimed. By focusing on the claim language itself, the court reversed the district court’s invalidity ruling and clarified the proper scope of written description analysis.