In re Wright
Court of Appeals for the Federal Circuit
999 F.2d 1557 (1993)
Wright (applicant) sought a patent on processes for making living vaccines against viruses, disclosing a general description of the invention but only one working example. The patent examiner allowed some narrower claims but rejected Wright's broader claims — which arguably extended to vaccines against HIV — for lack of enablement, relying on prior art literature showing that, as of Wright's filing date, someone skilled in the art would need substantial additional research beyond the specification to actually make and use the broadly claimed invention. The Board of Patent Appeals and Interferences affirmed, and Wright appealed to the Federal Circuit.
Whether a patent applicant who discloses only one example of an invention but claims far more broadly than what was disclosed has satisfied the enablement requirement.