There are few doctrines in patent prosecution more familiar, and yet more persistently contested in application, than the Broadest Reasonable Interpretation (BRI) standard. The standard is broad, but it is not boundless. Practitioners often remind examiners and the Board alike that claim terms are not interpreted in a vacuum, and that the broadest reasonable interpretation must remain tethered to the specification as it would be understood by one of ordinary skill in the art. The MPEP reflects this principle, including MPEP § 2111’s recognition that during examination claims must be given their broadest reasonable interpretation consistent with the specification, not merely the broadest conceivable interpretation. That distinction often becomes decisive where applicants rely on words that carry structural implications, even when those implications are not expressed in lengthy definitional language.

This issue can arise with terms such as “integral” and related phrases such as “integrally formed with,” where applicants may reasonably draft specifications and claims expecting the terminology itself to convey something about structural unity. As discussed in a prior post on this topic [link here], disputes over “integral” language can be difficult precisely because the term can be used with varying shades of meaning. In some contexts, “integral” has been read broadly enough to encompass components fixed together into a functioning whole. In others, particularly where the specification or claim language points more narrowly toward unitary construction, “integral” or “integrally formed” has been understood to require something closer to one-piece or monolithic structure. Much depends on claim language, specification context, and the evidentiary posture in which the issue arises.

A recent PTAB decision provides a useful reminder that these disputes remain highly contextual and that applicants can prevail where an examiner’s interpretation untethers itself from how the applicant used the term (as well as terms describing distinct structure) in the disclosure. In this case (Appeal 2026-000532), the Board reversed an obviousness rejection premised in part on an interpretation of “integrally formed with” that treated separately manufactured components as satisfying the claim because they were assembled together into a larger structure. The technology involved a rotary valve, but the broader significance of the decision lies less in the mechanics of the invention than in the Board’s treatment of claim interpretation. For reference, relevant portions of claim 1 are reproduced below:

1. A multi-port rotary valve comprising: a tapered valve body defining at least one flow passage between first and second openings, the flow passage extending transverse to a rotational axis of the tapered valve body, the tapered valve body further including an upper axial surface defining a socket opening and including a lower axial surface defining a diameter that is greater than a diameter defined by the upper axial surface … wherein the upper axial surface of the tapered valve body includes a first projection and wherein an axial surface of the upper housing includes a second projection, the upper axial surface of the tapered valve body being opposite of the axial surface of the upper housing, the first projection being integrally formed with the tapered valve body and the second projection being integrally formed with the upper housing …

The examiner’s theory, at a high level, was that projections formed on separate components in the prior art could nonetheless be considered “integrally formed with” the claimed valve body and housing because the relevant pieces were assembled into a final valve assembly. As practitioners have seen in many variants, the theory effectively sought to move from “assembled together” to “integrally formed,” treating assembly as sufficient to satisfy the structural language. The Board rejected that approach, not because “integral” always excludes multi-piece structures, but because the interpretation advanced here was not reasonable in light of this specification.

In this way, the Board confirmed there is no universal lexicographic rule that “integrally formed” invariably means monolithic. Indeed, the decision expressly acknowledged that cases exist reading “integral” broadly enough to include multi-part structures, while emphasizing those cases turn on their own disclosures. Instead, the Board focused on the applicant’s specification, including the way the disclosure used “integrally formed,” the drawings’ indication of one-piece construction, and the specification’s contrasting use of other relational terms such as “joined,” “secured,” and “coupled” when separate components were intended.  In particular, the Board relied on cross-hatching in the Applicant’s drawings, as well as Rule 84:

Appellant’s Figure 5, showing a cross section of its valve body 74 with “integrally formed” projections 104, and its valve housing 72 with “integrally-formed” projections 96 (Spec. ¶ 27), evidences that “integrally formed with” is best understood as being formed of one-piece or monolithic, as confirmed by the cross hatching indicating one-piece constructions. See 37 C.F.R. § 1.84 (“[h]atching must be used to indicate section portions of an object, and must be made by regularly spaced oblique parallel lines,” and “various parts of a cross section of the same item should be hatched in the same manner,” while “hatching of juxtaposed different elements must beangled in a different way.”).

In other words, the applicant did not prevail merely by invoking an abstract dictionary meaning of “integrally formed,” but by showing that within the intrinsic record the phrase carried structural implications inconsistent with the examiner’s reading.  Further, the cross-hatching in the drawings, along with Rule 84, provided a concrete way for the Board to definitively exclude the Examiner’s interpretation. 

Too often claim interpretation disputes are framed as though applicants must either have acted as explicit lexicographers or else accept any broad reading not facially impossible. That is not the law. Reasonableness is bounded by context, and context often includes how the specification consistently uses terminology, including the representations made in the figures.

The drafting lessons are obvious but still worth restating. Where practitioners can anticipate it, structural terminology such as “integral,” “unitary,” or “integrally formed” often benefits from reinforcing disclosure. Specifications can, where appropriate, describe features as single-piece, monolithic, seamless, molded as one component, formed without intervening joints, or otherwise structurally unified in ways that make intended meaning harder to dilute later. Drawings can also help by showing cross-sections to reinforce sections of the same monolithic component. As the Board’s discussion implicitly illustrates, what appears in figures and how components are represented can become part of the interpretive record. And remember, linguistic discipline matters. Consistently reserving other terminology such as “joined,” “attached,” or “coupled” for assembled components while using “integral” for unitary structures may help establish the kind of specification pattern needed for the desired interpretation.

But of course careful drafting does not eliminate the problem. These disputes often emerge only after an examiner combines art in a way the drafter did not foresee. Even where the specification does not contain ideal express definitional language, applicants should consider whether the intrinsic record nonetheless provides contextual support to challenge overbroad interpretations.

Practitioners should also consider the strategic use of examiner burden. If an examiner adopts an expansive interpretation of structurally loaded terminology, it may be appropriate to press the examiner to articulate the actual construction being applied, not merely invoke broadest reasonable interpretation as a label. One notable aspect of the Board’s analysis was its observation that the examiner claimed to apply broadest reasonable interpretation but did not clearly articulate the interpretation itself. That kind of omission can matter. Sometimes prosecution improves simply by forcing precision.

For prosecutors drafting new applications, a practical takeaway is not to abandon flexible structural terms, but to support them deliberately. “Integral” language can be powerful claim language precisely because it can imply structural character without cumbersome detail. But that power depends on specification support. If a feature’s unitary or seamless nature may matter later, say so. If a component is intended to exclude multi-piece assemblies, consider whether the specification gives a future advocate enough material to make that argument credibly.

For prosecutors responding to rejections, do not assume disputes over words like “integral” are semantic sideshows. They may be the rejection. Where an examiner stretches structural terminology beyond what the specification supports, claim construction may be the cleanest path to allowance. The recent PTAB reversal is a useful example that these arguments can succeed when framed as what they are: not requests for narrow imported limitations, but demands that broadest reasonable interpretation remain reasonable.