Tag: Indefiniteness
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TrackTime v. Amazon.com: Federal Circuit Requires Contextual § 112(f) Analysis for Software Claim Terms
The Federal Circuit’s decision in TrackTime, LLC v. Amazon.com Services LLC, Case No. 2024-1102 (Fed. Cir. July 2, 2026), clarifies how courts must determine whether software claim language invokes means-plus-function treatment under 35 U.S.C. § 112(f), particularly when a claim recites “executable program code” configured to perform specified operations. The court vacated a judgment that…
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Enviro Tech v. Safe Foods: Federal Circuit Invalidates “About” pH Range Claims as Indefinite
The Federal Circuit’s decision in Enviro Tech Chemical Services, Inc. v. Safe Foods Corp., Case No. 24-2160 (Fed. Cir May 4, 2026), adds another important chapter to the growing body of indefiniteness law applying Nautilus to “terms of approximation” such as “about,” “approximately,” and “substantially.” In a precedential opinion authored by Judge Lourie, the court…
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Gramm v. Deere: Federal Circuit Reverses Means-Plus-Function Indefiniteness Ruling
The Federal Circuit’s decision in Gramm v. Deere & Co., No. 24-1598 (Fed. Cir. Mar. 11, 2026) addresses a recurring issue in patent litigation: when a means-plus-function claim is sufficiently supported by corresponding structure in the specification. The case arises from agricultural technology used to maintain the proper height of a crop-harvesting header as the…
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Canatex Completion Sol’ns v. Wellmatics: When Judicial Claim Correction Saves Patent Claims from Indefiniteness
The Federal Circuit’s November 12, 2025 decision in Canatex Completion Solutions, Inc. v. Wellmatics, LLC, No. 2024-1466, provides a clear and disciplined application of the court’s demanding doctrine of judicial claim correction. Reversing a district court’s finding of indefiniteness, the panel held that an obvious drafting error in a patent claim could and should be…
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Barrette Outdoor Living, Inc. v. Fortress Iron, LP: Prosecution Disclaimer in a Later Continuation Can Narrow an Entire Patent Family
On October 17, 2025, the Federal Circuit issued a detailed and consequential opinion in Barrette Outdoor Living, Inc. v. Fortress Iron, LP, affirming a judgment of non-infringement while also affirming the district court’s rejection of indefiniteness challenges. The case provides a clear reminder that arguments made during prosecution of a later-filed continuation application can narrow…
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Fintiv v. PayPal: Payment Handler Terms Indefinite Under § 112(f)
In Fintiv, Inc. v. PayPal Holdings, Inc., No. 23-2312 (Fed. Cir. Apr. 30, 2025), the Federal Circuit affirmed the Western District of Texas’s ruling that the asserted patent claims were invalid as indefinite. The decision underscores the court’s continued enforcement of 35 U.S.C. § 112 ¶ 6 for software-related terms that fail to recite sufficient…
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Patent Law and Drug Innovation: Federal Circuit Upholds Rejection of ImmunoGen’s Patent Application
On March 6, 2025, the Federal Circuit issued its opinion in ImmunoGen, Inc. v. Stewart, affirming the district court’s ruling that denied ImmunoGen’s patent application for a dosing regimen of its antibody drug conjugate (ADC), IMGN853. The court’s decision, rooted in key principles of intellectual property law, particularly focused on the doctrines of indefiniteness and…
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Federal Circuit Overturns District Court’s Ruling on Indefiniteness in Teleflex v. Medtronic
In a significant decision for medical device patent litigation, the Federal Circuit vacated and remanded a district court’s ruling that had invalidated key claims in a patent dispute between Teleflex and Medtronic. The case centered on guide extension catheter technology used in cardiovascular procedures, with the core issue being whether the term “substantially rigid portion/segment”…