Fed. Circ. Guidance For Means-Plus-Function Software Claims
Law360, New York (May 22, 2015, 10:33 AM EDT) -- On May 6, 2015, the Court of Appeals for the Federal Circuit issued its decision in EON Corp. IP Holdings LLC v. AT&T Mobility LLC, No. 2014-1393, clarifying that for meeting the definiteness requirement of claims, a general purpose computer can provide sufficient structure for software-implemented means-plus-function claim elements only in very limited circumstances. As such, the court maintained its well-established rule from WMS Gaming "that the corresponding structure for a function performed by a software algorithm is the algorithm itself." In doing so, the Federal Circuit took a narrow view of its decision from In re Katz Interactive Call Processing...
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