The CAFC vacated a Pennsylvania district court's injunction against Sharda's insecticide, finding an erroneous claim construction regarding "composition". The district court limited this term to stable compositions based on specifications from the parent application, which was contested by Sharda. The Federal Circuit concluded that the district court improperly added a stability requirement that was not part of the asserted patents' definitions. This decision emphasizes the implications of changes in patent specifications on legal interpretations and claims.
The CAFC noted that FMC chose to alter the written specification of the asserted patents by removing every reference to stability from the parent application before it matured into the asserted patents.
The Federal Circuit found that the district court's grant of injunctive relief rested on an erroneous claim construction for "composition" that failed to take into account the removal of references to stable compositions.
FMC Corp. accused Sharda's insecticide of infringing claims from two asserted patents and the district court constructed "compositions" as limited to stable compositions.
On appeal, the Federal Circuit agreed with Sharda's arguments that the district court impermissibly grafted a stability requirement onto the "compositions" limitation.
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