The patent-in-suit concerned slot machines.
The Federal Circuit held today that, in patent lingo, "comprised of" generally means the same thing as "comprising" — "including but not limited to". The term doesn’t signify "consisting of", which implies the whole of a thing’s composition. Thus, the United States comprises the South and the Midwest but consists of all 50 states. CIAS, Inc. v. Alliance Gaming Corp., No. 06-1342 (Fed. Cir. Sept. 27, 2007).
The distinction didn’t matter. The court affirmed summary judgment of noninfringement anyway.
Barry Barnett
