Page:Amgen Inc. v. Sanofi.pdf/14

10 Morse described as “the use of the motive power of the electric or galvanic current … however developed for marking or printing intelligible characters, signs, or letters, at any distances.” Id., at 112 (internal quotation marks omitted). Leaving no doubt about this claim’s scope, Morse stated plainly: “ ‘I do not propose to limit myself to the specific machinery or parts of machinery described in the foregoing specification and claims.’ ” Ibid.

The Court held the eighth claim “too broad, and not warranted by law.” Id., at 113. The problem was that it covered all means of achieving telegraphic communication, yet Morse had not described how to make and use them all. See id., at 113–117; see also 3 Chisum on Patents §7.03[1], pp. 7–18 to 7–19 (2021). “[I]f the eighth claim … can be maintained,” the Court concluded, “there was no necessity for any specification, further than to say that he had discovered that, by using the motive power of electro-magnetism, he could print intelligible characters at any distance.” 15 How., at 119. “[I]t will be admitted on all hands, that no patent could have issued on such a specification.” Ibid.

Consider, too, Incandescent Lamp. For much of the 19th century, gas lamps helped illuminate streets and supplemented candles inside homes, factories, offices, and theaters. But gas lighting had drawbacks. It took effort to ignite lamps each night and extinguish them each morning. Then there were the problems of soot and fumes. See R. Stross, The Wizard of Menlo Park 84–85 (2007) (Stross). By the 1870s, many had experimented with other forms of lighting, including incandescence and the arc light. 159 U. S., at 470. But these alternatives burned unreliably or with unbearable brightness. See id., at 470–471. The latter problem in particular led one observer to lament this “new sort of urban star,” which shines “horrible, unearthly, obnoxious” light. R. L. Stevenson, A Plea for Gas Lamps, in Virginibus Puerisque and Other Papers 295 (1881).

Enter Thomas Edison. From his laboratory in Menlo