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An Indefinite Article "A" Or "An" Means "One Or More"

Client Alert | 1 min read | 01.17.08

In Baldwin Graphic Systems v. Siebert (No. 07-1262, January 15, 2008), a Federal Circuit panel reaffirms that an indefinite article “a” or “an” carries the meaning of “one or more” in open-ended claims containing the transitional phrase “comprising.” At issue is a district court’s claim construction that the term “a pre-soaked fabric roll” means “a single pre-soaked fabric roll.” In reversing the district court, the Federal Circuit concludes “[t]hat ‘a’ or ‘an’ can mean ‘one or more’ is best described as a rule, rather than merely as a presumption or even a convention.” The exceptions to this rule are extremely limited; a patentee must evince a clear intent to limit ”a” or “an” to “one”.

The panel also notes that “[a]n exception to the general rule that ‘a’ or ‘an’ means more than one only arises where the language of the claims themselves, the specification, or the prosecution history necessitate a departure from the rule.” The subsequent use of the definite articles “the” or “said” in a claim to refer back to the same claim term is not deemed to change the general plural rule, but simply reinvokes that non-singular meaning.

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Client Alert | 13 min read | 06.12.26

EU Cyber Resilience Act Countdown: 11 September 2026 Incident/Vulnerability Reporting Deadline Less Than 100 Days Away

The EU Cyber Resilience Act (CRA) is an EU product cybersecurity law for connected products (formally, “products with digital elements” under the CRA) commercialized in the EU; it entered into force on 10 December 2024, with direct application across the EU. Full application begins 11 December 2027, but one of its most operationally demanding provisions takes effect in just under 100 days, on 11 September 2026: the mandatory vulnerability and incident reporting under Article 14 CRA....