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Many Small Projects Do Not Equal One Big Project

Client Alert | less than 1 min read | 09.28.09

In Caddell Constr. Co. (Sept. 21, 2009), GAO found unreasonable the agency's determination that a vendor had shown the requisite experience performing services "similar in complexity, type of construction, and value to the project being bid" as required by the Security Act in a provision relating to construction of embassies, when the vendor's submission aggregated a number of smaller projects to equal the value of the construction project at issue. Contrary to the agency's determination, GAO held that the statute's experience requirement anticipates that an offeror has completed at least one construction project of similar value and complexity.

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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)....