直 Japanese PDF Font
  • Our Professionals
  • Our Work
  • Our Insights
  • Offices
  • Firm
  • Careers
Finnegan
  • Articles & Books
    • Ad Law Buzz Blog
    • At the PTAB Blog
    • European IP Blog
    • Federal Circuit IP Blog
    • INCONTESTABLE® Blog
    • Prosecution First Blog
  • Events & Webinars
  • IP Updates
  • Podcasts
    • AI + Finnegan
    • AI + Copyright
    • AI + Patent
    • AI + Privacy
    • AI + Trade Secrets
    • AI + Trademark
  • Unified Patent Court (UPC) Hub

Federal Circuit IP Blog

Applying Teva’s Clear-Error Standard, Federal Circuit Reverses Course

June 26, 2015

Authored and Edited by Forrest A. Jones; Elizabeth D. Ferrill; Lauren J. Dreyer

On remand from the Supreme Court, the Federal Circuit in Lighting Ballast Control v. Philips Electronics North America affirmed the claim construction ruling of the district court, as it relied on factual determinations that were not clearly erroneous.

The district court initially had determined that the term “voltage source means” was a means-plus-function limitation, but later reversed itself, relying on expert testimony that a skilled artisan would understand it to mean “a rectifier.” In a previous en banc decision in this case, the Federal Circuit applied the long-standing Cybor rule that claim construction is reviewed de novo. Shortly after, the Supreme Court issued Teva v. Sandoz, which changed claim construction from a purely a legal question, reviewed de novo, to one where underlying “subsidiary” factual findings on extrinsic evidence are reviewed for clear error. The Supreme Court remanded this case for consideration in light of Teva.

On remand, the Federal Circuit in a panel decision reversed itself, upholding the district court’s construction of “voltage source means.” Under the Teva standard of review, it concluded that the district court’s factual findings on the expert extrinsic evidence regarding the structure were not clearly erroneous, and affirmed that the term “voltage source means” is not a means-plus-function limitation.

Tags

indefiniteness (35 USC § 112), means-plus-function claim

Contacts

Forrest A. Jones
Partner
Washington, DC
+1 202 408 4019
Email
Elizabeth D. Ferrill
Partner
Washington, DC
+1 202 408 4445
Email

Copyright © 2015 Finnegan, Henderson, Farabow, Garrett & Dunner, LLP. 


DISCLAIMER: Although we wish to hear from you, information exchanged in this blog cannot and does not create an attorney-client relationship. Please do not post any information that you consider to be personal or confidential. If you wish for Finnegan, Henderson, Farabow, Garrett & Dunner, LLP to consider representing you, in order to establish an attorney-client relationship you must first enter a written representation agreement with Finnegan. Contact us for additional information. One of our lawyers will be happy to discuss the possibility of representation with you. Additional disclaimer information.

Related Insights

Conference

2027 ABA-IPL Section Annual Meeting – IPLSPRING

April 14-15, 2027

Arlington

Conference

IP Life Sciences Forum 2026

December 13-15, 2026

Coral Gables

Conference

Licensing Executives Society Chinese Taipei – Annual Conference 2026

December 4, 2026

Taipei

Webinar

Data and Market Exclusivity: An Update on China’s New Law and Comparisons to the US and Europe

November 19, 2026

Webinar

Conference

Broad's 3rd Annual Biotech IP Summit

November 10, 2026

Cambridge

Conference

IAM Live: Trade Secret Strategy USA

November 10, 2026

San Jose

Seminar

U.S. Patent Litigation 2026: Key Developments, Strategic Trends, and Winning Before Trial

November 6, 2026

Taipei

Conference

Life Sciences Patent Network North America Fall 2026

November 2-3, 2026

San Francisco

Conference

2026 TIPA International Symposium

October 30, 2026

Taipei City

Due to international data regulations, we’ve updated our privacy policy. Click here to read our privacy policy in full.

  • Privacy
  • Disclaimer
  • Legal Notices
  • Fraud Alert
  • EEO Statement
  • Cookies
  • Contact Us

© 2026 Finnegan, Henderson, Farabow, Garrett & Dunner, LLP