By Kevin E. Noonan — In reviewing (and reversing) the District Court’s claim construction in University of Massachusetts v. L’Oreal S.A., the Federal Circuit availed itself of both the disclosure in the specification and the prosecution history to construe a limitation in a wherein clause, based on its determination that the term did not have a plain meaning and thus other indicia of what the claim term at issue meant should be considered. The Court also reviewed the District Court’s favorable consideration of L’Oreal S.A.’s motion to dismiss on jurisdictional grounds, vacating this determination as an abuse of discretion for…
