1. Enzo Biochem, Inc. v. Gen-Probe Inc. 323 F. 3d 956 C. A. Fed. (N. Y
(Rader, dissenting: at 981) In sum, the written description language has been in the statute since 1870, yet only since 1967 has case law separated it from enablement. The separation itself is not disruptive of the patent system, however, because the doctrine operated solely to police priority.

2. Rader, cont’d
the aberrant form of WD requires far more specific disclosure than enablement. Because [it] requires a far more demanding disclosure, defendants will have no need to invoke enablement, but will proceed directly to the more demanding requirements. Thus, the new breed of WD [in] this case threatens to further disrupt the patent system by replacing enablement the statutory test for adequate disclosure.