Whether the written description requirement under 35 USC 112(a) should be measured by the statutory standard or the Federal Circuit's 'possession' test

QUESTION PRESENTED Section 112(a) of Title 35, United States Code, requires that a patent include a “specification,” which “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, or with which it is most nearly connected, to make and use the same.” The question presented is: Is the adequacy of the “written description of the invention” to be measured by the statutory standard of “in such full, clear, concise, and exact terms as to enable any person skilled in the art to make and use the same,” or is it to be evaluated under the Federal Circuit’s test, which demands that the “written description of the invention” demonstrate the inventor’s “possession” of “the full scope of the claimed invention,” including all “known and unknown” variations of each component?