Cox Communications, Inc. v. Sprint Communication Co., Case No.
16-1013 (Fed. Cir., Sept. 23, 2016) (Prost, CJ) (Newman, J,
dissenting).
Sprint sued Cox for patent infringement, asserting several
patents directed to developments in voice-over-IP technology. Among
the claims that Sprint asserted were method claims where certain
steps of the method were performed using a "processing
system." Cox moved for partial summary judgment on the ground
that the claim term "processing system" was indefinite.
The district court granted Cox's motion, finding the claims
indefinite because they functionally described the structural
"processing system" limitation. Sprint appealed.
The Federal Circuit reversed. The parties had previously agreed
that the term "processing system" was not a
means-plus-function term, so the Court analyzed whether
"processing system" rendered the claims indefinite under
the Nautilus v. Biosig Instruments framework (
IP Update, Vol. 17, No. 6). The Court