On October 1, 2026, the Federal Circuit affirmed that claims in a wireless-communications patent were invalid—not because their wording was unclear, but because they claimed something science says cannot be done. In Satius Holding, LLC v. Samsung Electronics Co., Ltd., No. 2025-1446 (precedential), Chief Judge Moore, joined by Judges Lourie and Hughes, held that claims covering an apparatus for transmitting “electric or electromagnetic signals over air” are definite under 35 U.S.C. § 112(b) yet fail enablement under § 112(a). Electric signals over air, the parties agreed, are a physical impossibility. The court would not rewrite the claim to save it. This overview is general information for Iowa engineers, founders, and manufacturers who draft or review patent claims, not legal advice, and it does not create an attorney-client relationship.

The patent and the claim

Satius Holding, LLC (formerly Satius Holding, Inc.) sued Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. in the District of Delaware for alleged infringement of claims 1, 11, and 18 of U.S. Patent No. 6,711,385. The ’385 patent describes a communications apparatus with a coupler that matches transmitter impedance to the characteristic impedance of the air. Claim 1, treated as representative, begins: “A communications apparatus for transmitting electric or electromagnetic signals over air ….” Claims 11 and 18 depend from claim 1.

After a USPTO reexamination stay, the district court construed the claims, held them indefinite because one alternative (electric-over-air) is scientifically impossible, and entered judgment of invalidity. Satius appealed.

Definite, even if one alternative cannot work

The Federal Circuit agreed with the district court on claim scope: the “or” language covers two kinds of over-the-air transmission—(1) signals in electric form and (2) signals in electromagnetic form—and the first kind is undisputed scientific impossibility. But impossibility is not the same as indefiniteness. Under Nautilus, claims must inform skilled artisans of the invention’s scope with reasonable certainty. Here the scope was clear: the claim covers both alternatives, including an inoperable one. There is no per se rule that a claim covering inoperable embodiments is indefinite.

Satius argued that “transmitting electric … signals over air” really meant transforming an electric signal inside the device into an electromagnetic signal that then travels through the air. The court refused that reading. Transmitting signals over the air is not the same as communicating signals to the air later in the claim, and different words generally mean different things. Rewriting the claim to insert a transformation step would redraft the inventor’s language—something the court said it may not do merely to make a claim operable or sustain validity (Chef America).

Invalid for enablement: full scope under Amgen

Although the district court had not decided enablement at claim construction, the Federal Circuit reached the issue on appeal. Section 112(a) requires the specification to enable a skilled artisan to make and use the invention. Under Amgen Inc. v. Sanofi, the specification must enable the full scope of what the claims define. “The more one claims, the more one must enable.”

Because claim 1 expressly covers transmitting electric signals over air—an alternative that cannot be made or used—the full scope cannot be enabled. Dependent claims 11 and 18 fall with claim 1. The court therefore affirmed the judgment of invalidity of claims 1, 11, and 18, on enablement grounds rather than indefiniteness.

Takeaways for Iowa engineers and founders

• Every alternative in an “A or B” list must actually work. Listing a physically impossible option can leave the claim definite but still invalid for lack of enablement across its full scope.
• Courts will not rewrite your claim to save it. If the only reasonable construction covers an impossible embodiment, expect that reading—and the enablement consequences that follow.
• Indefiniteness and enablement answer different questions. Clear claim language that covers something that cannot be done may survive § 112(b) and still fail § 112(a).
• Drafting discipline matters early. When you or counsel choose claim alternatives—signal types, materials, environments, modes—check that each alternative is real for the technology you are protecting.

Sources: the Federal Circuit’s October 1, 2026 precedential opinion (PDF) and Patent Case Watch’s case summary.

For related reading, see our patents overview and the step-by-step guide to getting a patent in Iowa.

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Jason Sytsma works with Iowa inventors and technology companies on claim strategy and patent prosecution. Learn more on the About Jason page and the firm bio.

Contact the office to request a consultation. Any engagement is subject to conflicts review, an engagement agreement, and applicable professional-responsibility rules. This article is attorney advertising and is intended for general educational purposes only; results vary, and past experience does not guarantee a particular outcome.