In The Gentry Gallery Inc. v. The Berklin Corp., the Court of Appeals for the Federal Circuit affirmed the lower court decision that Berklin’s recliner sofas that included tray units did not infringe Gentry Gallery's patent because the disclosure of the patent was limited to a sectional sofa with a fixed console between the sections of the sofa. The prosecution history established that the term "console" did not include tray units such as those that were part of the Berklin sofa and that Gentry Gallery had made this argument to distinguish its invention from the prior art which described sofas having tray units.

Berklin also argued that certain claims were invalid because they failed to comply with the requirement of 35 USC 112 that the claims be supported by a written description. The claims were directed to recliner sofas in which the location of the recliner controls was not limited to the console. The court found that the description "clearly identifies the console as the only possible location of the controls" and noted that one of the stated objects of the invention could only be achieved if the controls were located on the console. Gentry argued that location of the controls on the console was a preferred embodiment. However, the inventor admitted at the trial that he did not consider alternative locations for the controls until he had seen the defendant's design. The Federal Circuit noted that whether a specification complies with the written description requirement is a question of fact and to meet the written description requirement the patent specification must clearly allow persons of ordinary skill in the art to recognize that the inventor invented what is claimed. The Federal Circuit noted that the original specification was limited to a sofa where the controls were located on the console and that case law established that an “applicant is entitled to claims as broad as the prior art and his disclosure will allow”. (emphasis added) The Federal Circuit agreed with Berklin that the patent disclosure did not support claims in which the location of the recliner controls is other than on the console and reversed the lower court decision that found otherwise.