Case Overview
The Federal Circuit addressed the construction of functional claim limitations in In re Blue Buffalo Enters., Inc., No. 2024-1611, 2026 U.S. App. LEXIS 872 (Fed. Cir. Jan. 14, 2026) (nonprecedential). The Court determined whether the claim terms "configured to" and "configured for" should be interpreted narrowly as “specifically designed to” or more broadly as “capable of.” The Federal Circuit affirmed the decision of the Patent Trial and Appeal Board (PTAB), ruling that PTAB properly construed "configured to" and “configured for” as meaning "capable of."
Factual Background and Procedural History
The dispute involved U.S. Patent Application No. 15/456,152, directed to a wet pet food container. The invention features a storage area defined by a bottom wall and at least one sidewall. The bottom wall contains a "tool portion" for tenderizing food and a deformable “sidewall.”
The claims at issue recited that the sidewall is “configured to be readily deformable by a hand of a user,” raising the question of how narrowly to construe that language. The PTAB interpreted "configured to" broadly, finding the claim anticipated by prior art structures capable of manual deformation. Blue Buffalo appealed, arguing the construction ignored Federal Circuit precedent regarding the intentionality of design required by such functional descriptors.
Federal Circuit Analysis
On appeal, the Federal Circuit agreed with the PTAB’s claim interpretation of “configured to” and “configured for” as meaning “capable of.” The Federal Circuit based the opinion on two primary rationales.
First, relaying on the prior cases of In re Giannelli, and Aspex Eyewear, Inc. v. Marchon Eyewear, Inc., appellant argued that “configured for” and “configured to” should be interpreted as “specifically designed to.” However, the Federal Circuit distinguished these cases, noting that the terms “configured to” and “configured for” are distinct from the phrase “adapted to” analyzed in the cited precedents.
Second, the Federal Circuit looked to the overall language of the claims and the written description in the cited precedent to conclude that “adapted to” required a narrower construction than “capable of”. The Federal Circuit explained that in In In re Gianelli, the written description necessitated construing “adapted to” more narrowly than “capable of.” The Federal Circuit distinguished Aspex Eyewear by noting that the patent’s specification and claims used both “adapted do” and “capable of.” This distinct usage demonstrated an intent for “adapted to” to carry a specific, narrower meaning than the broader “capable of.”
Conclusion
The Federal Circuit held that the PTAB did not err in its decision to broadly interpret “configured to” and “configured for” as “capable of.” Since the specification and claims did not further define or limit "configured to" as "specifically designed to," and prior case law was distinguishable, the broader interpretation prevailed.
Author: Lucas Stelling
Edited by: Craig Drachtman and April Capati