Tag: means-plus-function
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Socket Solutions v. Import Global: Federal Circuit Demands Doctrinal Discipline Before Granting Preliminary Patent Injunctions
The Federal Circuit’s decision in Socket Solutions, LLC v. Import Global, LLC, Case No. 2025-1121 (Fed. Cir. Aug. 4, 2026), illustrates that preliminary patent injunctions do not alter the governing standards of claim construction or equitable relief. Because a preliminary injunction can remove products from the marketplace long before infringement has been finally adjudicated, courts…
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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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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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Magnolia v. Kurin: Separately Listed Claim Elements Require Separate Structures
The Federal Circuit’s decision in Magnolia Medical Technologies, Inc. v. Kurin, Inc., No. 2024-2001 (Fed. Cir. Mar. 6, 2026) reinforces a claim construction principle that appears simple but has far-reaching consequences in patent litigation: when claim elements are listed separately, the ordinary implication is that the elements correspond to separate structures. The decision also illustrates the…
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Genuine Enabling Tech. v. Sony: Means-Plus-Function Claims Demand Full Structural Accounting
On February 19, 2026, the Federal Circuit issued a significant decision in Genuine Enabling Technology LLC v. Sony Group Corporation, No. 2024-1686, affirming summary judgment of noninfringement in favor of Sony. At first glance, the case involves familiar territory: PlayStation controllers, Bluetooth modules, and an aging patent directed to combining data streams. But the real…
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Optis Cellular Technology v. Apple Inc.: Federal Circuit Orders New Trial on Infringement and Damages Due to Unanimity Violation and Improper Evidence
The Federal Circuit’s June 16, 2025, decision in Optis Cellular Technology, LLC v. Apple Inc., Nos. 2022-1904, 2022-1925, vacates a $300 million damages judgment in a high-stakes standard-essential patent (SEP) case and mandates a new trial on both infringement and damages. The court found that the Eastern District of Texas violated Apple’s constitutional right to…
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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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Federal Circuit Weighs in on Gesture-Based Patent Dispute: Key Takeaways for IP Law
The Federal Circuit’s recent decision in Apple Inc. v. Gesture Technology Partners, LLC (March 2025) provides important insights into patent law, particularly in the context of inter partes review (IPR) proceedings and obviousness determinations. This ruling builds on the court’s earlier January 2025 decision in another dispute involving Gesture Technology Partners, reinforcing key legal principles…
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Federal Circuit Reverses JMOL in Steuben Foods Patent Case: Key Takeaways for IP Law
In Steuben Foods, Inc. v. Shibuya Hoppmann Corporation, the Federal Circuit issued a major decision addressing key intellectual property issues related to patent infringement, claim construction, and the reverse doctrine of equivalents (RDOE). The case centered on aseptic food packaging technology, with the court analyzing whether Shibuya’s P7 aseptic bottling line infringed Steuben’s patents. This…