In addition, neither party has filed a motion asserting that no interference-in-fact exists between the parties' involved claims. All of Strelchenko's involved claims were made afterAugust 31,2000, more than ayear after Stice 577 issued on August 31, 1999.' Thus, applying the express language of 35 U.S.C. § 135(b)(1), Strelchenko's Claims 57-58, 61-63, 69-88, 106, 112-115 and 118 would appear to be barred. However, under thejurisprudence interpreting § 135(b), Strelchenko's claims are not barred if Strelchenko had on file at least one claim which was directed to the same or substantially same subject matter as claimed by the patentee prior to the critical date. See, e.g., Corbett v. Chisholm, 568 F.2d 759,759-60,196 USPQ 337,338 (CCPA 1977) ("Theissue, therefore, is whether the board was correct in holding that Corbett was not claiming subject matter substantially the same as that covered by the copied claims prior to January 19, 1972, i.e., within the year after Chisholm's patent issued"). We focus, therefore, on the claims Strelchenko had pending prior to the critical date of August 31, 2000. Strelchenko specifically relies on three such claims: cancelled claim 48, an earlier version of involved claim 106 and cancelled claim 107. Paper 50, p. 18. If Strelchenko's precriti6l date claims include all the material limitations of Stice's' patent claims, then Strelchenko is entitled to rely on the earlier filing date for the purpose of the § 135(b)(1) analysis. In re Berger 279 F.3d 975, 982, 61 USPQ2d 1523, 1527 (Fed. Cir. 2002). A limitation is material if it is necessary to patentability. Corbett, 568 F.2d at 765, 196 USPQ at 343. The Stice 577 claims and Strelchenko's precritical date claims are directed to cloning processes including the step of inserting a specified donor cell or the nucleus of the donor cell into an enucleated oocyte. In the Stice 577 claims the donor cell is a "proliferating somatic cell which has been expanded in culture." In Strelchenko's precritical date claims the donor cell is a "totipotent cell." Thus, Slice's Claim I provides: 9 Strelchenko's involved claims were made prior to the issue date of the Stice 041 and 969 Patents. Thus only Stice 577 is relevant to this motion. -15-Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: November 3, 2007