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Federal Circuit Mandates Full Lost Profits Award for Breach

Client Alert | less than 1 min read | 09.19.13

In Rockies Express Pipeline LLC v. Salazar (Sept. 13, 2013), the Federal Circuit confirmed that, by backing out of its agreement to take for ten years a certain percentage volume of a pipeline to be constructed in part on federal land, Interior materially breached. The CBCA had cut off the duration of the pipeline's lost profits remedy, but the circuit court reversed because Interior could not limit its damages by its actions after the pipeline had canceled for breach.


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Client Alert | 6 min read | 11.26.25

From ‘Second’ to ‘First:’ Federal Circuit Tackles Obvious Claim Errors

Patent claims must be clear and definite, as they set the boundaries of the patentee’s rights. Occasionally, however, claim language contains errors, such as typographical mistakes or incorrect numbering. Courts possess very limited authority to correct such errors. The United States Court of Appeals for the Federal Circuit has emphasized that judicial correction is appropriate only in rare circumstances, where (1) the error is evident from the face of the patent, and (2) the proposed correction is the sole reasonable interpretation in view of the claim language, specification, and prosecution history. See Group One, Ltd. v. Hallmark Cards, Inc., 407 F.3d 1297, 1303 (Fed. Cir. 2005) and Novo Indus., L.P. v. Micro Molds Corp., 350 F.3d 1348, 1357 (Fed. Cir. 2003)....