Federal Circuit Vacates Preliminary Injunction Based on Erroneous Construction of “Composition”

In FMC Corp. v. Sharda USA, LLC, No. 2024-2335 (Fed. Cir. Aug. 1, 2025), the Federal Circuit vacated a preliminary injunction and remanded because the district court abused its discretion due to an erroneous construction of the claim term “composition.”

FMC sought a temporary restraining order (“TRO”) against Sharda for infringement of patents relating to insecticide and miticide compositions. Sharda opposed the TRO by alleging that the patents faced substantial questions of invalidity under theories of anticipation and obviousness. The district court granted the TRO, which converted to a preliminary injunction, based on a construction requiring “composition” to cover only stable compositions. Sharda appealed.

On appeal, the Federal Circuit held that the district court erroneously imposed a stability requirement onto the term “composition” because the district court had relied on references to stability in a related provisional application and patent that were deleted in the specification of the at-issue patents. On remand, the Federal Circuit instructed the district court to give “composition” its plain and ordinary meaning and to reconsider whether Sharda had raised substantial questions of anticipation and obviousness under that construction.