How does In re Young affect patent claim interpretation?
In re Young is another important case cited in MPEP 2115 that affects patent claim interpretation, particularly for apparatus claims. The MPEP states:
In Young, a claim to a machine for making concrete beams included a limitation to the concrete reinforced members made by the machine as well as the structural elements of the machine itself. The court held that the inclusion of the article formed within the body of the claim did not, without more, make the claim patentable.
This case reinforces the principle that the inclusion of the material or article worked upon by an apparatus does not automatically confer patentability. Patent examiners and practitioners should focus on the structural elements of the claimed apparatus rather than the output it produces.
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