Enfish, LLC v. Microsoft Corporation
Federal Circuit finds data storage claims subject-matter eligible based on clear divergence from traditional storage model and/or directive to solve computer-related problem
Federal Circuit finds data storage claims subject-matter eligible based on clear divergence from traditional storage model and/or directive to solve computer-related problem
In a precedential decision, the B.P.A.I. interprets various software-related recitations, including “system configuration generator” and “system builder”, as means-plus-function limitations and rejects the claims as indefinite for failing to provide sufficient corresponding structure—in this case, algorithms—for implementing the recited functions.
Copies of software made from a master disk or from an electronically exported version were not themselves components of computers on which the copies were made, in such a way that would give rise to liability under 35 U.S.C. §271(f).
When interpreting a means-plus-function claim, corresponding structure in a patent specification does not include software where only hardware elements are shown and described in the specification and there is no clear indication that would lead one of ordinary skill in the art to understand that software could be used to perform the specific function set forth in the claim element.