Claims Incorporating Functional Language And A Means For Accomplishing The Function Must Supply A Related Structure For Doing So

Synchronoss Tech., Inc. v. Dropbox, Inc., Appeal No. 19-2196 (Fed. Cir. Feb. 12, 2021)

The patentee appealed the district court's decisions that all asserted claims from three patents are either invalid under 35 U.S.C. § 112, paragraph 2, or not infringed. The accused infringer cross-appealed, asserting that all claims at issue are patent ineligible subject matter under § 101. The patents relate to technology for synchronizing data across multiple devices.

The Federal Circuit reviewed de novo, as patent eligibility under § 101 is ultimately a question of law, which may contain underlying issues of fact. First, some of the terms at issue, deemed indefinite by the district court, were phrases incorporating functional language with terms appended to them such as “user identifier module,” “authentication module identifying a user coupled to the synchronization system,” and “transaction identifier module.” The Federal Circuit agreed that these terms were subject to 35