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Fourth Circuit Affirms Award By Interstate Compact

Client Alert | less than 1 min read | 03.01.04

In Washington-Dulles Transp., Ltd. v. Metro. Wash. Airports Auth. (Jan. 30, 2004), the Fourth Circuit issued the first decision by an appeals court addressing the merits of a challenge to the award of a contract by the Metropolitan Washington Airports Authority (represented by C&M). The court upheld the Authority’s award because it was "grounded in a methodical and public review of the proposals," had "a rational basis," and was not "arbitrary or irrational."

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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)....