What is the relationship between single means claims and property-dependent claims?
The MPEP draws a parallel between single means claims and claims that depend on a recited property: When claims depend on a recited property, a fact situation comparable to Hyatt is possible, where the claim covers every conceivable structure (means) for achieving the stated property (result) while the specification discloses at most only those known to the inventor.
This means that claims based on a specific property or result, rather than a specific structure, can face similar enablement issues as single means claims. If such a claim covers all possible ways to achieve a property but only discloses a few in the specification, it may be rejected for lack of enablement, similar to single means claims.
To learn more:
Topics:
MPEP 2100 - Patentability,
MPEP 2164.08(A) - Single Means Claim,
Patent Law,
Patent Procedure