CAFC discusses Nautilus "zone of uncertainty" in GE case; '999 patent survives

From the case:


As the district court recognized, “[t]he claims, specification
and prosecution history demonstrate[] that any
amount of heat transfer is sufficient for ‘heat sink (verb).’”
J.A. 25–26 (emphasis added). And that is true even if a
lamp’s design seeks to minimize heat transfer. J.A. 27
(“[A]s [heat sinking] is used in the ’999 Patent, an object
that is shielded from receiving heat is still ‘heat sinking.’”).
Thus, whether a component heat sinks another
component is an objectively defined fact: either heat is
transferred between the components and heat sink, or it
is not. Because “to heat sink” creates no “zone of uncertainty,”
see Nautilus, 134 S. Ct. at 2129, we conclude that
the asserted claims of the ’999 patent are not indefinite.3