Federal Circuit reverses jury verdict of invalidity and non-infringementNovember 7, 2005

In Callicrate v. Wadsworth Manufacturing, Inc., the Federal Circuit Court of Appeals recently reversed a finding that the patent involved was invalid and not infringed. The technology at issue relates to mechanisms for castrating animals by preventing blood flow to the scrotum. The court found that the two disputed claim terms were misconstrued by the district court. As a result, the jury’s finding that the accused tools did not infringe must be reversed. The court also found that there was no reason to remand for a new trial on infringement. Based on its construction of the claim terms, judgment of infringement was warranted as a matter of law.The jury also found that the patents involved were anticipated by a previously-issued patent. However, if the patents were entitled to the filing date of an earlier patent, the previously-issued patent would not be prior art, and therefore could not be used to invalidate the asserted patents. The district court determined that the patents were not entitled to an earlier filing date because the original disclosure was not enabled, as required by