In A Means-Plus-Function Claim, The Use Of "Circuitry" As A Corresponding Structure Is Sufficient

The patent at issue on appeal claimed techniques for generating a power tracking supply voltage for a circuit that processes multiple radio frequency signals simultaneously. The Patent Trial and Appeal Board (PTAB) invalidated the patent as obvious, but the Federal Circuit vacated and remanded. The court found that the PTAB had not given adequate notice that it would depart from the parties' agreed construction of a key term, and so violated the patentee's procedural rights. The court vacated and remanded on those grounds.

However, the court affirmed the PTAB's construction of a means-plus-function term relating to a "power tracker." The court held that the corresponding structure for the power tracker is a circuit, rather than a general-purpose computer. Under well-established law, "[i]n a means-plus-function claim in which the disclosed structure is a computer, or microprocessor, programmed to carry out an algorithm, the disclosed structure is not the general