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The Federal Circuit Confirms Proper SCA Price Adjustments

Client Alert | less than 1 min read | 08.24.06

The Federal Circuit, in Lear Siegler Services, Inc. v. Rumsfeld (July 28, 2006), reverses the ASBCA and confirms that the Service Contract Act Price Adjustments clause, FAR 52.222-43, entitles the contractor to an adjustment for its increased cost of providing health and welfare benefits specified in a collective bargaining agreement, even though the benefits themselves did not change.

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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)....