Every Term in a Claim Should be Given Meaning

In Enzo Biochem Inc. v. Applera Corp., [2014-1321] (March 16, 2015), the Federal Circuit reversed the district’s courts’ claim construction, and thus the district court finding of infringement. At issue was the language “represents at least one component of a signaling moiety capable of producing a detectable signal.” The district court determined that this language encompassed a compound that was the entire signaling moiety. However, the Federal Circuit reversed for several reasons, including the fact that this construction improperly read out “component” form the claim language, citing Bicon, Inc., v. Straumann Co., 441 F.3d 945, 950 (Fed. Cir. 2006).