Satius Holding, LLC v. Samsung Electronics Co., Ltd.

Satius Holding v. Samsung Electronics, decided October 1st, 2026. A precedential panel of the Federal Circuit, in an opinion by Chief Judge Moore, held that a patent claim covering a scientific impossibility is not, for that reason, indefinite. But the same claim is invalid for lack of enablement, because no one can make or use an embodiment that cannot exist. The court affirmed the judgment of invalidity on that alternative ground. Here's the brief.

Satius owns the ’385 patent, which relates to a communications apparatus with a coupler that matches the impedance of a wireless transmitter to the characteristic impedance of the air.

In 2018, Satius sued Samsung for infringing claims 1, 11, and 18. The district court stayed the case for reexamination. The Patent and Trademark Office rejected independent claim 1 but upheld dependent claims 11 and 18.

When the case resumed, the problem was the preamble. Claim 1 covers an apparatus for transmitting electric or electromagnetic signals over air. The parties agreed that transmitting a signal over air in electric form is scientifically impossible. On that basis, the district court held all three claims indefinite and entered judgment of invalidity. Satius appealed. Samsung defended the judgment and argued, in the alternative, that the claims were not enabled.

The court first construed the language. Satius argued that the preamble really described an electric signal converted into an electromagnetic one before it left the device. The court disagreed. Transmitting signals over the air is not the same as transmitting them to the air, and a court may not redraft claims to make them operable or to sustain their validity.

That left two questions. Under the Supreme Court's decision in Nautilus, a claim is indefinite if, read in light of the specification and prosecution history, it fails to inform skilled artisans about the scope of the invention with reasonable certainty. Under section 112(a), as the Supreme Court explained in Amgen v. Sanofi, the specification must enable the full scope of the invention as claimed.

On indefiniteness, the court reversed the district court's reasoning.

Operability, the court explained, may say nothing about a skilled artisan's understanding of a claim's bounds. It distinguished its 2021 decision in Synchronoss v. Dropbox, where impossible claims were held indefinite because the specification made clear the claims did not set forth what the inventor regarded as the invention. Here, the impossible language appeared in the written description too, and no one disputed what the claim covered. Samsung itself argued that claim 1 unmistakably claims the impossibility.

On enablement, the court exercised its discretion to decide the issue for the first time on appeal. It was fully briefed, it raised a question of law, the impossibility was undisputed, and a remand would serve no purpose.

Quoting Amgen, the court observed that the more one claims, the more one must enable, and that these claims fell woefully short.

Satius v. Samsung separates two requirements of section 112 that impossible claims can blur. Definiteness asks whether the claim's boundaries are clear; enablement asks whether the full scope within those boundaries can be made and used. A claim that clearly covers an inoperable alternative satisfies the first and fails the second. The decision rejects any per se rule that impossibility means indefiniteness, and it applies Amgen's full-scope standard to an express claim limitation that no skilled artisan could practice.

Satius Holding, LLC v. Samsung Electronics Co., No. 2025-1446, decided October 1st, 2026. I'm John Goodhue. Thanks for watching.