Each week, Troutman Sanders' Federal Circuit review
summarizes the Federal Circuit precedential patent opinions from
the prior week.
This week:
-
Use of the Term "Module" Did Not Specify A
Means-Plus-Function Claim.
Use of the Term "Module" Did Not Specify A
Means-Plus-Function Claim.
Williamson v. Citrix Online, LLC, No. 2013-1130, 2014 U.S.
App. LEXIS 21114 (Fed. Cir. Nov. 5, 2014) (Linn, J.) (Reyna, J.,
dissenting). Click Here for a copy of the opinion.
Williamson sued several defendants for infringing a patent for a
"virtual classroom environment." The district court
construed two phrases in the claims that resolved the case against
Williamson. One was the phrase "distributed learning
control module," which the district court interpreted as a
means-plus-function claim. The specification failed to
provide any structure for the "module," and the district
court therefore held that several claims are invalid as
indefinite. The other phrase
