On November 12, 2025, the U.S. Court of Appeals for the Federal Circuit (“CAFC”) reversed and remanded the claim construction decision of the U.S. District Court for the Southern District of Texas that invalidated for indefiniteness several claims of U.S. Patent No. 10,794,122 (“the ’122 Patent”). Canatex Completion Solutions, Inc. v. Wellmatics, LLC, No. 2024-1466, __ F.4th __ (Fed. Cir. Nov. 12, 2025).
Canatex Completion Solutions, Inc. (“Canatex”) owns the ’122 Patent, which relates to a “releasable connection” tool for oil and gas wells. The tool comprises two parts that can be disconnected from each other while the tool is downhole, which allows the operator of the tool to retrieve one part if the other becomes stuck. The underlying dispute here centered on the claim language “the connection profile of the second part,” which appears in independent claims 1, 7, and 13.
In September 2022, Canatex sued Wellmatics, LLC; GR Energy Services, LLC; GR Energy Services Management, LP; GR Energy Services Operating GP, LLC; and GR Wireline, L.P. (collectively, defendants), alleging infringement of the ’122 Patent. The defendants challenged the validity of the asserted claims, arguing that the phrase “the connection profile of the second part” lacked antecedent basis and rendered the claims indefinite. Canatex responded that the phrase contained an evident clerical error and should be understood as “the connection profile of the first part,” consistent with the disclosed inventions—notwithstanding that the incorrect phrase was also used in the abstract and in the specification.
The district court rejected Canatex’s argument, holding that the error was not evident from the face of the patent and that the correction was not as simple as Canatex suggested. The district court further reasoned that the fact that this error could be found in the claims and specification suggested intentional drafting, and noted Canatex’s failure to seek correction from the U.S. Patent and Trademark Office as evidence that the error was not minor.
On appeal, Canatex argued that the district court erred in refusing to judicially correct the claim language and in finding the claims indefinite. The CAFC reviewed the district court’s claim construction de novo, and applied the prevailing, demanding standard for judicial correction of patent claims—i.e., the error must be evident from the face of the patent, and the correction must be the only reasonable interpretation based on intrinsic evidence (claim language, specification, and prosecution history).
The CAFC found that the error—referring to “the connection profile of the second part”—was obvious on the face of the patent. The claims and specification consistently described the releasable engagement profile of the second part as engaging and releasing the connection profile of the first part. The figures and written description supported this reading, and no antecedent basis existed for a connection profile of the second part. The only reasonable correction was to change “second” to “first.”
The CAFA rejected the defendants’ alternative interpretations, including the suggestion that another component could serve as the connection profile of the second part. The CAFC found these alternatives illogical and unsupported by the patent’s disclosures, and that the prosecution history did not suggest any other reasonable interpretation.
The CAFC therefore reversed the district court’s claim construction, holding that judicial correction was warranted. The error was deemed a minor clerical or typographical mistake, and the only reasonable correction was to change “second” to “first.” Accordingly, the CAFC remanded the case for further proceedings consistent with the corrected claims.
