Magsil Corp. v. Hitachi Global Storage Techs., No. 11-1221 (Fed. Cir. 2012)
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MIT is the assignee of the 922 patent and MagSil is the exclusive licensee. The patent application was filed in 1995; it issued in 1997. The patent claims read-write sensors for computer hard disk drive storage systems. Hard disk drives store digital data in microscopic magnetic patterns on the surface of spinning platters, or disks, inside the drive. The patent claims both a method of manufacturing a tri-layer tunnel junction and the junction itself. MagSil filed suit in 2008 against several defendants, alleging that their disk drive products infringed the patent. The district court found the asserted claims invalid as a matter of law for lack of enablement. The Federal Circuit affirmed. The specification must contain sufficient disclosure to enable an ordinarily skilled artisan to make and use the entire scope of the claimed invention at the time of filing. The specification containing the broad claims at issue, does not contain sufficient disclosure to present “even a remote possibility” that an ordinarily skilled artisan could have achieved the modern dimensions of this art.
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