No, the patent cannot cover the all-in-one cup. The judges said Rivera's patent is invalid because his original application never described an all-in-one design. They looked at his paperwork and saw that every single picture and paragraph was about making two separate things—the adapter and the pod—work together. Because Rivera never showed or described a cup with a built-in filter, the law says he didn't 'possess' that invention when he filed his patent. Therefore, he can't stop others from making it, even if his final patent used broad language.

Yes, the inventors didn't describe their invention well enough to cover a container with a built-in filter. This is because their patent talks a lot about a special holder for coffee pods, but always describes the coffee pod as separate from the holder. The patent never mentions or shows a container that is both the pod and the holder in one, with a built-in filter. Even though the patent gives a broad definition of what a 'pod' is, it still always treats the pod as different from the holder. Just because experts in coffee machines might know about containers with built-in filters, that doesn't mean the inventors showed they came up with that idea in their patent. The law says we can only look at what's actually written in the patent, not what experts might know. So, the patent isn't valid for the type of container Solofill was making.

No, a patent specification that exclusively describes an invention with two separate components does not provide adequate written description for claims covering an integrated, single-unit version. The court determined that the written description requirement is not met because the '320 patent's specification, when viewed in its entirety, fails to convey that the inventor possessed an invention where the filter is integrated into the receptacle. The court reasoned that the distinction between the 'pod' and the 'cartridge' or 'receptacle' is fundamental to the invention as described, permeating the entire patent from the abstract to every embodiment. Even the patent's broad definition of 'pod' cannot overcome the fact that the specification consistently treats the pod and the receptacle as two distinct elements. The knowledge of a person skilled in the art cannot be used to add a new configuration (an integrated filter) that is entirely absent from the 'four corners of the specification.' Citing ICU Medical, Inc. v. Alaris Medical Sys., Inc., the court analogized this case to one where claims for a 'spikeless' valve were invalidated because the specification only disclosed valves with spikes; similarly, because the '320 patent only discloses an adapter for a separate pod, it cannot support claims for a container with an integrated filter.

Yes, the specification of the '320 patent does not provide sufficient written description support for the claims concerning a 'container adapted to hold brewing material' because the specification and embodiments focus on a 'pod adaptor assembly' distinct from the container. The patent consistently describes an invention in which the 'pod' and the receptacle or container are distinct components. Nothing in the specification shows that the 'pod' and the receptacle may be the same structure. The patent does not disclose a container that is itself a pod or that contains an integrated filter, which is fundamental to the claimed invention. The broad definition of 'pod' in the specification does not change this analysis, as even under this definition, the pod must still be distinct from the pod adapter assembly. The background knowledge of those skilled in the art cannot supplement the teaching in the specification to provide written description support for an undisclosed configuration. Therefore, the claims are invalid for lack of written description.

Rivera v. International Trade Commission

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