Law360, New York (May 6, 2015, 10:21 AM EDT) -- The patent world has made much of the U.S. Supreme Court's recent decision in Teva v. Sandoz, and perhaps rightly so.[1] After all, Teva changed the law that had held across three decades treating so-called "factual" questions relating to claim construction as just another part of the legal inquiry, subject to de novo review on appeal. But while Teva ruled that such subsidiary fact findings on claim construction should now receive deference, it did so in the context of considering expert testimony, a source of evidence that courts have long categorized as "extrinsic." The related question that Teva and the case law to date have not explicitly addressed is: Will a district court's reliance on "extrinsic" dictionaries for claim construction likewise be treated as a type of "fact" determination entitled to deference?...