ALFRED E. MANN FOUNDATION v. COCHLEAR CORPORATION (Fed. Cir. 2016) (P) – Broad class of algorithms does not provide structure for computer-implemented means-plus-function elements

by Steve Driskill | Nov 17, 2016 | [sub] corresponding structure, Means Plus Function

A broad class of algorithms for performing the function of a computer-implemented means-plus-function element, as opposed to a single or small set of algorithms, is not sufficiently definite to provide the requisite algorithmic structure. Here, for example, the...

VOCALTAG LTD. v. AGIS AUTOMATISERING B.V. (Fed. Cir. 2016) (NP) – Algorithmic structure for a means-plus-function element need not be illustrated explicitly in the drawings

by Steve Driskill | Sep 1, 2016 | [sub] corresponding structure, Means Plus Function

Algorithmic structure corresponding to a means-plus-function element need not be illustrated explicitly in the drawings when the associated text of the specification makes clear that the claimed function is contemplated. Here, for example, an algorithm illustrated in...

ADVANCED GROUND INFORMATION v. LIFE360, INC. (Fed. Cir. 2016) (P) – A coined-term element is generally subject to a means-plus-function interpretation

by Steve Driskill | Jul 28, 2016 | [sub] invocation, Means Plus Function

A coined-term element is generally subject to a means-plus-function interpretation. Here, for example, the claimed “symbol generator” for plotting user locations on a map was found to invoke 35 U.S.C. § 112, ¶ 6 because its name was coined for the purposes of the...

MEDIA RIGHTS TECHNOLOGIES v. CAPITAL ONE FINANCIAL CORP (Fed. Cir. 2015) (P) – Inter-connection among components of a system is not by itself sufficient to avoid means plus function

by Steve Driskill | Sep 4, 2015 | [sub] invocation, Means Plus Function

Inter-connection among claimed components of a system is not by itself sufficient to avoid the application of § 112, ¶ 6. Here, for example, the claimed “compliance mechanism” was found to invoke application of § 112, ¶ 6 even though the specification describes how...

RICHARD WILLIAMSON v. CITRIX ONLINE, LLC (Fed. Cir. 2015) (P, en banc) – No heightened bar for overcoming presumption that a limitation without the word “means” escapes § 112, ¶ 6

by Steve Driskill | Jun 16, 2015 | [sub] invocation, Means Plus Function

Despite a decade of precedent to the contrary, the heightened bar to overcoming the presumption that a limitation expressed in functional language without using the word “means” is not subject to § 112, ¶ 6 has been overruled. Here, for example, the claimed...

EON CORP. IP HOLDINGS LLC v. AT&T MOBILITY LLC (Fed. Cir. 2015) (P) – The Katz exception to the algorithm rule does not extend to complicated, customized computer software

by Steve Driskill | May 6, 2015 | [sub] corresponding structure, Means Plus Function

The Katz exception to the algorithm rule permitting general-purpose processors to serve as the corresponding structure of computer-implemented means-plus-function elements for basic functions of a processor does not extend to complicated, customized computer software....