Product-By-Process claim does not basically meet Clarity requirement.

The Supreme Court says, “In the case of what is generally referred to as a “product-by-process claim,” that is, when a claim of a patent for an invention of a product recites the manufacturing process of the product, the recitation of the claim should be held to meet the requirement that the claimed invention is clear as prescribed in Article 36, paragraph (6), item (ii) of the Patent Act, only if there are circumstances where it was impossible or utterly impractical to directly define the product subject to the invention by means of its structure or characteristics at the time of the filing of the application.” (2012 (Ju) 1204)