"We generally give words of a claim their ordinary meaning in the context of the claim and the whole patent document; [and] the specification particularly, but also the prosecution history, informs the determination of claim meaning in context, including by resolving ambiguities"; but "even if the meaning is plain on the face of the claim language, the patentee can, by acting with sufficient clarity, disclaim such a plain meaning or prescribe a special definition." K-fee System GmbH v. Nespresso USA, Inc., 89 F.4th 915, 919 (Fed. Cir. 2023) (alteration in original) (first quoting World Class Technology Corp. v. Ormco Corp., 769 F.3d 1120, 1123 (Fed. Cir. 2014); and then citing Personalized Media Communications, LLC v. Apple Inc., 952 F.3d 1336, 1339-40 (Fed. Cir. 2020)); see also Phillips v. AWH Corp., 415 F.3d 1303, 1312-17 (Fed. Cir. 2005) (en banc); Thorner v. Sony Computer Entertainment America LLC, 669 F.3d 1362, 1365 (Fed. Cir. 2012). Within that framework, we see several issues relevant to a proper claim construction that would significantly benefit from fuller exploration by the parties and the district court.

For example, the prosecution disclaimer "inquiry is related to but distinct from the inquiry into what the prosecution history shows about a relevant artisan's understanding of the claim language in context." K-fee Sys. GmbH v. Nespresso USA, Inc., 89 F.4th 915, 923 (Fed. Cir. 2023) (analyzing whether patentee acted with "sufficient clarity" before a foreign patent office, such that a purported disclaimer should be imported to a related U.S. patent). Moreover, "[t]he same general tenets that apply to prosecution history estoppel apply to prosecution history disclaimer."

K-fee Sys. GmbH v. Nespresso USA, Inc., 89 F.4th 915, 923 (Fed. Cir. 2023). The prosecution history may also estop a patentholder from asserting too broad a scope to infringement under the doctrine of equivalents: