The Patent Act requires that a patent's "specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains … to make and use the same"—commonly known as the "enablement requirement." 35 U.S.C. §112(a) (emphasis added). In November, the Supreme Court granted certiorari to review courts' application of this statutory enablement requirement.