Finally, we analyze three doctrines that constrain the DOE: the all-elements
rule, the public dedication doctrine, and prosecution history estoppel. The
all-elements rule has the desirable effect of preserving the narrow scope of
patents in fields crowded with prior art. Thus, this rule works to complement the
rule favoring application of the DOE to pioneers. Similarly, a disclosure that
trips the dedication doctrine reveals a low refinement cost. And we defend a
rigorous prosecution history estoppel doctrine because amendments or argu-
ments made during patent prosecution often show that the refinement cost is
low to literally claim patent scope sought through the DOE.