The Federal Circuit revived an oil-well viscometer patent by holding that a term of degree must be measured against the intrinsic record before a court reaches for a dictionary — while affirming a separate means-plus-function construction.
The Federal Circuit held 'visually negligible' definite because it was anchored to what the normal human eye can perceive, supplying the objective baseline that purely subjective terms lack.
The Federal Circuit's first major post-Nautilus decision held the phrase 'in an unobtrusive manner that does not distract the user' indefinite, illustrating how purely subjective language fails the reasonable-certainty test.
The Supreme Court discarded the Federal Circuit's forgiving 'insolubly ambiguous' test and replaced it with a public-notice standard that asks whether a patent claim informs skilled artisans of its scope with reasonable certainty.
