reflects the views of the patentee as to the construction of the claims is inadmissible". Netherlands The Dutch Supreme Court has effectively come to the opposite conclusion to most other countries in Europe. The Dutch Supreme Court has stated that where "a third party invokes the examination file in the course of confirming the interpretation defended by him of a patent, it cannot be seen that that requirement [the reasonable doubt threshold] would force any restriction on involving public data from the examination file with the interpretation of the patent". United Kingdom The UK courts have ruled that use of the examination file in aiding construction of a patent should be discouraged except where that file includes "objective information about and commentary on experiments". United States The defining case on prosecution estoppel in the United States is Festo Corp. v. Shoketsu Kinzoku Kogyo Kabushiki Co.. Festo Corp. v. Shoketsu Kinzoku Kogyo Kabushiki Co. Court of Appeals for the Federal Circuit Holding In November 2000, the Court of Appeals for the Federal Circuit set a complete bar rule. This complete bar rule completely prohibited a patent owner from asserting the doctrine of equivalents for certain elements of her claim in instances where, during her patent prosecution she files: an amendment that narrows the scope of a claim for any reason related to the statutory requirements for a patent will give rise to a complete bar with respect to the amended claim element; a "voluntary" claim amendment that narrows the scope of the claim for a reason related to the statutory requirements for a patent will give rise to prosecution history estoppel as to the amended claim element; and an amendment and fails to explain the reasons for the amendment during prosecution of her patent. Supreme Court reversal The United States Supreme Court in their opinion Festo Corp. v. Shoketsu Kinzoku Kogyo Kabushiki Co., 535 U. S. 722 (2002), citing the instruction in Warner-Jenkinson Company, Inc. v. Hilton Davis Chemical Co., finding that "courts must be cautious before adopting changes that disrupt the settled expectations of the inventing community", overturned the complete bar issued by the Federal Circuit. It also acknowledged that while any narrowing amendment made for a reason related to patentability could give rise to prosecution history estoppel, inventors who amended their claims under the previous case law had no reason to believe that they were conceding all equivalents of