Canatex Completion Sols., Inc. v. Wellmatics, LLC

Authored by: Jeremy J. Gustrowsky

In a recent patent dispute in the oil and gas industry, the Federal Circuit stepped in to fix a clear drafting mistake in a patent claim, overturning a lower court’s decision that had declared the claims invalid. Canatex Completion Solutions sued Wellmatics and related companies, accusing them of infringing a patent for a releasable tool used in drilling wells. This device allows operators to disconnect parts of a tool string if something gets stuck deep underground, making retrieval easier. The heart of the case was whether the patent’s wording was so unclear as to be unenforceable.

The trouble started with a phrase in the patent’s key claims: “the connection profile of the second part.” This wording lacked a proper setup earlier in the claim, creating confusion about what it referred to. The district court in Texas saw this as a fatal flaw, ruling the claims indefinite and invalid because the error seemed intentional and widespread, appearing in the claims, abstract, and description. Canatex argued it was just a simple slip—likely meant to say “first part” instead of “second”—based on how the device actually works, as shown in the patent’s drawings and explanations.

The Federal Circuit disagreed with the lower court, applying strict rules for fixing patent errors. They examined the patent’s own language, figures, and overall description, concluding that a skilled engineer would immediately spot the mistake and know the fix: swap “second” to “first.” This small change made perfect sense, as the device’s design only involves a connection profile on the first part, which gets released by expanding a component on the second part. Other possible fixes suggested by the defendants didn’t align with the invention’s clear purpose, so the court saw no real debate. Importantly, the prosecution history didn’t contradict this correction.

By reversing the indefiniteness ruling, the Federal Circuit sent the case back for further review with the corrected claims, emphasizing that courts can tidy up obvious clerical errors without rewriting the patent. This decision highlights how intrinsic clues in a patent can rescue otherwise strong claims from technical pitfalls.