Software, Means-Plus-Function

User Identification Module Held Means-Plus-Function Element, Lacked Structure/Algorithm and Invalid

Manatt, Phelps & Phillips, LLP on 7/6/2021

In Rain Computing, Inc. v. Samsung Elecs. Am., Inc., the Federal Circuit held that the claimed language “user identification module” was a means-plus-function element with no corresponding structure disclosed in the...more

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

BakerHostetler on 3/4/2021

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

Indefiniteness of Means-Plus-Function Claims

McDermott Will & Emery on 9/3/2016

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

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

McDonnell Boehnen Hulbert & Berghoff LLP on 7/8/2015

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

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

McDermott Will & Emery on 6/19/2015

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

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

Wilson Sonsini Goodrich & Rosati on 6/19/2015

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

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

Kelley Drye & Warren LLP on 6/19/2015

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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