The U.S. Supreme Court affirmed the Federal Circuit’s decision to grant Sanofi’s Motion for Judgment as a Matter of Law for lack of enablement. The Supreme Court analyzed whether Amgen’s claims were enabled. Under Section 112 of the Patent Act, the specification must describe the invention in sufficient detail to enable any person skilled in the art to make and use it. In the Supreme Court’s words “the more a party claims for itself, the more it must enable.” Thus, “[i]f a patent claims an entire class of processes, machines, manufactures, or compositions, the patent’s specification must enable a person skilled in the art to make and use the entire class.”
