June 27, 2014

Federal Circuit Decisions for Week Ending June 20, 2014

Gemalto S.A. v. HTC Corp. (June 19, 2014) (precedential) Patent Nos. 6,308,317, 7,117,485, 7,818,727

Key points:

  • Literal scope of claims may be constrained by specification and prosecution history.
  • Doctrine of equivalents cannot be applied to encompass the prior art.

Augme Technologies, Inc. v. Yahoo! Inc. (June 20, 2014) (precedential) Patent Nos. 6,594,691, 7,269,636, 7,640,320

Key points:

  • Claim terms should be given their plain meaning unless specification and prosecution history supports deviation from the plain meanings.
  • A computer-implemented means-plus-function element is indefinite if the specification does not disclose an algorithm for performing the claimed function.

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