Williamson v. Citrix Online, LLC
Where the word "means" is not actually recited in a
patent claim, case law provides a strong presumption that the claim
is not a means-plus-function claim under § 112(f). If it is
shown, however, that the claim uses language or a word—a
"nonce" word—that substitutes for the word
"means," the presumption can be rebutted. Addressing
whether the presumption was rebutted by use of the words
"module for . . . ," the U.S. Court of Appeals for the
Federal Circuit concluded that, in the context of the asserted
patent, it was not. Williamson v. Citrix Online, LLC, Case
No. 13-1130 (Fed. Cir., Nov. 5, 2014) (Linn, J.) (Reyna, J.,
dissenting).
The plaintiff, Richard A. Williamson, acting as trustee for the
bankruptcy estate of At Home Corporation Bondholder's
Liquidation Trust, asserted a patent against a number of
defendants, including Citrix. The patent relates to methods and
systems for "distributed learning," using networked
computer
