Clear but Impossible: Satius v. Samsung Moves Inoperable Claims from Indefiniteness to Enablement

by Dennis Crouch

The Federal Circuit has affirmed invalidity of Satius's wireless-coupler patent, but on a different ground than the district court. Satius Holding, LLC v. Samsung Electronics Co., No. 2025-1446 (Fed. Cir. Oct. 1, 2026). Claim 1 of U.S. Patent No. 6,711,385 recites an apparatus "for transmitting electric or electromagnetic signals over air." Everyone agrees the first option is impossible: electromagnetic signals travel through air; electric signals do not. Magistrate Judge Burke (D. Del.) held the claims indefinite on that basis. Chief Judge Moore's opinion for the panel (joined by Judges Lourie and Hughes) rejects that reasoning, holding that a claim can be clear about its scope even when part of that scope is physically impossible. The court then held the claims invalid for lack of enablement, an issue the district court had found waived.

Judge Hughes previewed the result at oral argument: "If I claim the transporter from Star Trek, everybody knows what I'm claiming. It's impossible. But it's impossible because it's not enabled, not because it's indefinite." The panel's precedential opinion adopts that view.

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