Adequate disclosure is the "quid pro quo" of the patent system: the public grants exclusive rights to the patent holder for a limited time, and in exchange, the patent holder divulges the operating principles of the invention to the public.' Since adequacy of disclosure determines a patent's validity and scope, the Supreme Court has cautioned against "[f]undamental alterations in [disclosure] rules" that may "risk destroying the legitimate expectations of inventors in their property" by invalidating pending or issued patents. The current standard for adequate disclosure, set forth in 35 USC § 112, requires that the "specification . . . 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, or with which it is most nearly connected, to make and use the same."

Courts have interpreted this statute to include two separate requirements that valid patents must fulfill: "written description" and "enablement."'