News & Analysis as of

Means-Plus-Function Software

Alston & Bird

Patent Case Summaries | Week Ending May 2, 2025

Alston & Bird on

Fintiv, Inc. v. PayPal Holdings, Inc., No. 2023-2312 (Fed. Cir. (W.D. Tex.) Apr. 30, 2025). Opinion by Prost, joined by Taranto and Stark. Fintiv sued PayPal for infringement of four patents directed to “cloud-based...more

McDermott Will & Emery

“Payment Handler”: A Nonce Term Without Instructions

The US Court of Appeals for the Federal Circuit affirmed a district court’s ruling that a software term was a “nonce” term that invoked 35 U.S.C. § 112, sixth paragraph (i.e., a means-plus-function claim element). The Court...more

BakerHostetler

Looking for Clarification on Means-Plus-Function Claiming? Here Are 4 Things You Should Know

BakerHostetler on

In Rain Computing, Inc. v. Samsung Elecs. Co., No. 2020-1646 (Fed. Cir. Mar. 2, 2021), the Federal Circuit reversed a judgment of non-invalidity and in doing so provided clarity to its post-Williamson (792 F.3d 1339 (Fed....more

McDermott Will & Emery

Indefiniteness of Means-Plus-Function Claims

Addressing both the circumstances that lead to a claim limitation invoking a means-plus-function construction and indefiniteness issues for means-plus-function claims, the US Court of Appeals for the Federal Circuit affirmed...more

McDonnell Boehnen Hulbert & Berghoff LLP

Eon Corp. IP Holdings LLC v. AT&T Mobility LLC (Fed. Cir. 2015)

On September 23, 2010, Eon filed suit against seventeen defendants in the District Court of the District of Delaware, alleging infringement of U.S. Patent No. 5,663,757. During the case, the '757 patent went through two...more

McDermott Will & Emery

What Was Old Is New Again for Means + Function Claim Elements

McDermott Will & Emery on

The U.S. Court of Appeals for the Federal Circuit, sitting en banc for the limited purpose of revisiting when claims invoke the means-plus-function language of 35 U.S.C. § 112, ¶ 6 (§ 112(6)) (now § 112(f)) replaced a part of...more

Wilson Sonsini Goodrich & Rosati

Federal Circuit Decreases Strength of Presumption Against Treatment of Patent Claims as Means-Plus-Function

Accused infringers challenging patent claims now have a new arrow in their quiver as a result of yesterday's holding in Williamson v. Citrix Online, et al. In an en banc decision, the Federal Circuit replaced an earlier...more

Kelley Drye & Warren LLP

En Banc Federal Circuit Broadens What Constitutes A Means-Plus-Function Limitation (Williamson V. Citrix)

Yesterday, the Federal Circuit issued a decision in Williamson v. Citrix that includes an en banc portion that broadens the circumstances in which claim limitations may be deemed means-plus-function limitations. This appears...more

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