Scriptpro LLC v. Innovation Assocs, Inc.

Scriptpro’s patent is directed to a “collating unit” used with a control center and an automatic dispensing system to store prescription containers after a medication has been dispensed into the containers. After a remand in an infringement case, the district court entered summary judgment, finding four claims invalid for lack of written description. The Federal Circuit reversed and remanded. The patent expressly states that containers can be sorted and stored “by patient, prescription, or other predetermined storage scheme without input or handling by the operator.” Not every claim must contain every limitation or achieve every disclosed purpose. Here, the original claims filed as part of the patent application did not include a requirement that sorting and storing be done by use of patient-identifying information. The district court erred when it determined that the specification limited the invention to storing prescription containers based on patient name and slot availability. Because the specification does not limit the scope of the invention in the manner the district court described, the asserted claims are not invalid for lacking such a limitation. View "Scriptpro LLC v. Innovation Assocs, Inc." on Justia Law