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Law School Case Brief

Incandescent Lamp Patent - 159 U.S. 465, 16 S. Ct. 75 (1895)

Rule:

If the description of a device in a patent application be so vague and uncertain that no one can tell, except by independent experiments, how to construct the patented device, the patent is void.

Facts:

In their application for the patent involving the use of carbonized paper for an incandescent conductor, the patentees declared their device to be an improvement of the electric light. The alleged infringers justified their actions under certain patents to Thomas Edison, denied the novelty and utility of the holder's patent, and averred that it had been fraudulently and illegally procured. The Circuit Court held the patent to be invalid and dismissed the bill. The patent holder appealed.

Issue:

Was the circuit court correct in declaring the patent invalid?

Answer:

Yes.

Conclusion:

The United States Supreme Court noted that Rev. Stat. § 4888 required that an application for a patent shall contain a written description of the device and of the manner and process of making, constructing, compounding, and using it in such full, clear, concise, and exact terms as to enable any person, skilled in the art or science to which it appertains or with which it is most nearly connected, to make, construct, compound, and use the same. The Court held that the claims of the patent were too indefinite to be the subject of a valid monopoly of the use of carbonized paper for the purpose of electric illumination.

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