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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 | 14 min read | 03.13.26

AI for Government: 7 Days for Contractor Comments on GSA Proposed Contract Clause for AI Systems

On March 6, 2026, the General Services Administration (GSA) issued a significant proposed contract clause, GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems (“Clause”), for inclusion in GSA Schedule solicitations and contracts for AI capabilities.  The proposed clause would impose substantial new requirements related to AI sources, intellectual property rights, data use, change management, and performance standards.  The Clause would also take precedence over any other contract terms (including commercial licensing terms) related to AI, including a Seller’s terms of sale and service to which the Government had previously agreed.  GSA requests comments by March 20, 2026....