This blog could be nothing but disputes about claim narrowing. We'd have 72,000 posts a year and we'd never get to the bottom of all the little sub-disputes, and how each judge prefers to handle them. I'm sure it would be quite popular.
This week in IPA Technologies Inc. v. Amazon.com, Inc., Judge Andrews clarified his position on one of the more common disputes -- how exactly to count "references" for the purposes of narrowing.
The defendant, Amazon, had been ordered to reduce the number of references in its invalidity contentions and had responded by limiting itself to 4 prior art "systems." …