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 | 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 | 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...

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 | 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....

TOMITA TECHNOLOGIES USA, LLC v. NINTENDO CO., LTD. (Fed. Cir. 2014) (NP) – Black box element requires articulated and distinct structure for means-plus-function interpretation

by | Dec 8, 2014 | [sub] corresponding structure, Means Plus Function

Although a means-plus-function element may be illustrated in black box form, the corresponding structure must be clearly articulated in the specification—the black box itself is not sufficient—and clearly distinguished from other embodiments in order to provide...

TRITON TECH OF TEXAS, LLC v. NINTENDO OF AMERICA, INC. (Fed. Cir. 2014) (P) – Classes of algorithms are not corresponding structure for means-plus-function elements

by | Jun 13, 2014 | [sub] corresponding structure, Means Plus Function

“Disclosure of a class of algorithms that places no limitations on how values are calculated, combined, or weighted is insufficient to make the bounds of the claims understandable [under the definiteness requirement of 35 U.S.C. § 112(b)].” Further, the fact that a...

UNIVERSITY OF PITTSBURGH v. VARIAN MEDICAL SYSTEMS (Fed. Cir. 2014) (NP) – Computer-implemented means-plus-function algorithm structure breadth

by | Apr 10, 2014 | [sub] corresponding structure, Means Plus Function

For computer-implemented means-plus-function elements relying on algorithm structure, “[t]he algorithm need only include what is necessary to perform the claimed function.” It “[does] not need to include every possible implementation of the function, so long as it...