News & Analysis as of

Patent Invalidity Appeals Means-Plus-Function

Schwabe, Williamson & Wyatt PC

Latest Federal Court Cases: Fintiv, Inc. v. Paypal holdings, Inc.

Fintiv, Inc. v. Paypal holdings, Inc., Appeal No. 2023-2312 (Fed. Cir. Apr. 30, 2025) In its only precedential patent opinion last week, the Federal Circuit affirmed a district court’s determination that the terms “payment...more

McDermott Will & Emery

Logic to Modify: Even Deceptive Intent Does Not Bar Inventorship Correction

McDermott Will & Emery on

The US Court of Appeals for the Federal Circuit vacated a district court invalidity determination finding that judicial estoppel prevented a patent owner from relisting an inventor previously removed for strategic litigation...more

Jones Day

Indefinite Patent at the ITC May Survive in District Court

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In a recent order issued in the Northern District of Texas, Judge Godbey denied a Defendant’s Rule 12(b)(6) motion despite the Federal Circuit’s holding that the asserted patent was invalid as indefinite. Hyosung TNS, Inc. v....more

Mintz - Intellectual Property Viewpoints

District Court denies motion to dismiss despite Federal Circuit’s finding of patent invalidity in appeal of parallel ITC...

On December 5, 2019, Judge David C. Godbey of the Northern District of Texas denied the defendant Diebold Nixdorf, Inc.’s (“Diebold”) motion to dismiss under Rule 12(b)(6), in Nautilus Hyosung Inc. v. Diebold, Inc. et al.,...more

Knobbe Martens

Federal Circuit Review - September 2018

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Federal Circuit Finds Claims Issued from Reexamination Co-Pending with Appeal Ineligible Where the Changes Did Not Affect Section 101 Eligibility - In SAP AMERICA, Inc. v. InvestPic, LLC, Appeal No. 2017-2081, the...more

Knobbe Martens

Diebold Nixdorf, Inc. v. ITC

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Federal Circuit Summary - Before Prost, Bryson, and O’Malley. Appeal from the United States International Trade Commission (“ITC”). Summary: Evidence intrinsic to a patent may be sufficient to overcome the presumption...more

Knobbe Martens

Zeroclick, LLC v. Apple Inc.

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Federal Circuit Summaries - Before Reyna, Taranto, and Hughes. Appeal from the Northern District of California. Summary: Failure to use the word “means” creates a rebuttable presumption that the term is not a...more

Schwabe, Williamson & Wyatt PC

2017 Supreme Court and Precedential Patent Cases From the Federal Circuit, With Some Significant Cases from 2016

Arbitration - Waymo v. Uber Technologies, 870 F.3d 1342 (Fed. Cir. 2017) - Waymo sued Uber and others for trade secret misappropriation and patent infringement. Uber contends that Waymo should be compelled to...more

Knobbe Martens

Federal Circuit Review - August 2017

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District Court Abused Discretion in Ignoring Federal Circuit Mandate to Reconsider Attorneys’ Fees Under Octane Fitness - In Adjustacam, LLC v. Newegg, Inc., Appeal No. 2016-1882, the Federal Circuit held that a district...more

McDermott Will & Emery

Skky Found the Limit for “Means” Terms

The US Court of Appeals for the Federal Circuit agreed that the Patent Trial and Appeal Board (PTAB) did not err in its conclusions that a claim element reciting “means” did not invoke § 112 ¶ 6 and that the challenged claims...more

Knobbe Martens

Federal Circuit Review | July 2015

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Nunc Pro Tunc Assignments Insufficient To Confer Retroactive Standing - In ALPS SOUTH, LLC v. OHIO WILLOW WOOD CO., Appeal Nos. 2013-1452, 2013-1488, 2014-1147, and 2014-1426, the Federal Circuit reversed the denial of a...more

McDermott Will & Emery

Only Basic Functions of a Processor Avoid Need for Disclosed Algorithm - EON Corp. IP Holdings LLC v. AT&T Mobility LLC

Addressing the question of what corresponding structure must be disclosed to support a means-plus-function claim element, the U.S. Court of Appeals for the Federal Circuit upheld a district court finding that eight...more

Ballard Spahr LLP

Fed Circuit Decision Gives Broad Patents New Concerns

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The Federal Circuit Court of Appeals overruled prior precedent this week in Williamson v. Citrix Online, LLC and lowered the standard for patent invalidity under 35 U.S.C. § 112 (f)—the statute that requires functional claims...more

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