MPEP § 2164.08(a) — Single Means Claim (Annotated Rules)

§2164.08(a) Single Means Claim

USPTO MPEP version: BlueIron's Update: 2025-12-31

This page consolidates and annotates all enforceable requirements under MPEP § 2164.08(a), including statutory authority, regulatory rules, examiner guidance, and practice notes. It is provided as guidance, with links to the ground truth sources. This is information only, it is not legal advice.

Single Means Claim

This section addresses Single Means Claim. Primary authority: 35 U.S.C. 112(a) and 35 U.S.C. 112. Contains: 2 statements.

Key Rules

Topic

Means-Plus-Function Claims

1 rules
StatutoryInformativeAlways
[mpep-2164-08-a-7f4695c3d9bd0a86ed16e182]
Single Means Claim Is Nonenabling
Note:
A claim that recites a means without other elements is not enabled if it covers all possible structures for achieving the stated purpose, as disclosed only up to the inventor's knowledge.

A single means claim, i.e., where a means recitation does not appear in combination with another recited element of means, is subject to an enablement rejection under 35 U.S.C. 112(a) or pre-AIA 35 U.S.C. 112, first paragraph. In re Hyatt, 708 F.2d 712, 714-715, 218 USPQ 195, 197 (Fed. Cir. 1983) (A single means claim which covered every conceivable means for achieving the stated purpose was held nonenabling for the scope of the claim because the specification disclosed at most only those means known to the inventor.). 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.

Jump to MPEP SourceMeans-Plus-Function ClaimsWhen 112(f) Is Invoked (MPEP 2181)
Topic

Claims

1 rules
StatutoryInformativeAlways
[mpep-2164-08-a-8fa818b513f71def8f0cf19f]
Claim Covers Every Structure for Stated Property
Note:
A single means claim must be supported by the specification, which must disclose all known structures for achieving the stated property.

A single means claim, i.e., where a means recitation does not appear in combination with another recited element of means, is subject to an enablement rejection under 35 U.S.C. 112(a) or pre-AIA 35 U.S.C. 112, first paragraph. In re Hyatt, 708 F.2d 712, 714-715, 218 USPQ 195, 197 (Fed. Cir. 1983) (A single means claim which covered every conceivable means for achieving the stated purpose was held nonenabling for the scope of the claim because the specification disclosed at most only those means known to the inventor.). 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.

Jump to MPEP SourcePatent Application ContentMeans-Plus-Function Claims

Citations

Primary topicCitation
Claims
Means-Plus-Function Claims
35 U.S.C. § 112
Claims
Means-Plus-Function Claims
35 U.S.C. § 112(a)

Source Text from USPTO’s MPEP

This is an exact copy of the MPEP from the USPTO. It is here for your reference to see the section in context.

BlueIron Last Updated: 2025-12-31