by Dennis Crouch
WSOU Investments LLC v. Google LLC, Nos. 2022-1063, 2022-1065 (Fed. Cir. Oct. 19, 2023)
WDTX District Court Judge Alan Albright sided with the accused infringer in this case — holding that the asserted claims were invalid as indefinite. The setup here is a common scene: means plus function (MPF) claim limitations without adequate support in the specification.
Most commonly patentees draft claims that cover the physical structure of an invention or the particular steps taken in a process. However, the Patent Act also permits a patentee to claim the elements of an invention as “means for” accomplishing a specified function without actually claiming the structural components. Although a “means for holding hot coffee” appears potentially broader than claiming a “ceramic mug,” the statute itself places key limits on the scope of these so-called “means plus function” claims. In particular, a means for limitation is interpreted to only cover the “corresponding structure” disclosed in the specification and their equivalents. 35 U.S.C. § 112(f). And, a series of Federal Circuit cases have created a bright line rule that a means-plus-function limitation will render the entire claim invalid as indefinite in situations where no corresponding structure is provided in the specification. This is the case even in situations where various ways to perform the claimed means are well known to those of skill in the art. See, e.g., Williamson v. Citrix Online, LLC, 792 F.3d 1339, 1351-52 (Fed. Cir. 2015); Aristocrat Techs. Australia Pty Ltd. v. Int’l Game Tech., 521 F.3d 1328, 1337-38 (Fed. Cir. 2008). In this situation, my “means for holding hot coffee” might not even cover a ceramic mug if the specification itself only discloses paper cups. And, the claim would be invalid if it failed to disclose any particular embodiments of a hot-coffee-holding device.
A patentee intending to invoke 112(f) style claiming will typically use the magic words “means for …” However, the Federal Circuit concluded that claim meaning is a matter of objective analysis, rather than subjective intent. In MPF analysys, the court looks beyond the magic words and more generally ask whether the limitation recites a non-structural “nonce” word. A “nonce” word is a verbal construct that does not convey a particular structure, such as “element,” “device,” or other generic, non-structural terms. When a nonce word is interpreted in means plus function form, the corresponding structure in the specification must be something more than a repeat of the same nonce word — lest the claim be found invalid as indefinite.
In this case, the two patents at issue are related to image tracking technology (the ‘045 patent) and gesture control technology (the ‘825 patent). The following claim terms were the ones disputed:
- “a processor configured to …” (‘045 patent)
- “at least one memory and the computer program code are configured, with the at least one processor, to cause the apparatus to …” (”825 patent)
U.S. Patent Nos. 8,965,045 and 9,335,825.
Judge Albright found each of these underlined terms to be in “nonce” form and therefore applied MPF analysis. A processor is a means for processing; a memory is a means for storing data; etc. According to Judge Albright, the patent document did not provide any further structural disclosure beyond the functional words — thus rendering the claims indefinite.
On appeal, WSOU argued on appeal that the limitations were not means-plus-function limitations, and thus § 112, ¶ 6 did not apply. Alternatively, it argued the specifications disclosed adequate structure.
As to the ’045 patent, the Federal Circuit affirmed the district court’s determination that the “processor” limitation invoked § 112, ¶ 6 because in the context of the claims and specification it was described only functionally and generically. The court concluded that the patentee had focused its arguments on the processor being not-MPF and had waived any arguments regarding corresponding structure. “WSOU argues for the first time on appeal that the specification discloses corresponding structure.”
As to the ’825 patent, the Federal Circuit reversed. It held that the “memory,” “code,” and “processor” limitations in this patent, read in context of the claims and specification, would connote sufficient structure to avoid § 112, ¶ 6. The court distinguished the ’825 patent’s more specific description of these elements.
So, we have the word “processor” interpreted as a nonce word invoking MPF analysis in one patent; but a structural limitation in the second patent. The difference here is that in the ‘045 patent, the patentee “treats the word ‘processor’ so broadly as to generically be any structure that manipulates data” but without providing specific examples. On the other hand, the ‘825 patent included a much more concrete explanation of the term. The court explained:
In contrast to the ‘045 patent, the specification [in the ‘825 patent] describes the ‘processor’ as hardware that runs the computer program code. Specifically, the specification teaches that the term ‘processor’ is synonymous with terms like controller and computer and ‘should be understood to encompass not only computers having different architectures such as single/multi-processor architectures and sequential (Von Neumann)/parallel architectures but also specialized circuits such as field-programmable gate arrays (FPGA), application specific circuits (ASIC), signal processing devices and other devices.’
Thus, the intrinsic evidence from the specification justified the distinction. One odd note here is that I did read through the ‘045 patent and it does seem to include a bit more than what was suggested by the court. In particular, the ‘045 patent has the same quoted statement that a processor:
should be understood to encompass not only computers having different architectures such as single/multi-processor architectures and sequential (Von Neumann)/parallel architectures but also specialized circuits such as field-programmable gate arrays (FPGA), application specific circuits (ASIC), signal processing devices and other processing circuitry. …
‘045 patent. In addition, the ‘045 patent indicates that a processor could be configured as “processing circuitry” that includes a combination of implementations including microprocessor(s).
The Federal Circuit did not consider these factual similarities because, apparently the patentee raised them as to the ‘045 for the first time on appeal. If I were the patentee, I might review this decision carefully and consider whether a request for panel rehearing is appropriate — is it true that the patentee only preserved the structure argument as to one of the patents?
In any event, the case is interesting for the outcome — the Federal Circuit finding that Judge Albright is being too tough on patentees.
These are really bad holdings that extend Williamson and extend the made of doctrine of you don’t have to care about Phillips. Just horrendous that they are not interpreted the claims as one of ordinary skill in the art would. My classification: another anti-patent judicial activist holding that is counter to Phillips.
What they did was take the term “a collaborative application management processor” and try to say the phrase had to be supported in the specification with an algorithm. Reality: “collaborative application management” is just a name for the functional aspects: “to enable the user to select an electronic message from the inbox.” It is the game of using 112, 6 to invalidate claims because they recite a name to describe what a module does and then the word “module” or here “processor”. This should have been just construed as “one or more [[just a descriptive name]] processors configured to [[functional part]]”
One skilled in the art would construe this phrase as just a description of the functions to follow. Then the CAFC invalided the claim by saying that the descriptive name was not supported by an algorithm.
They extended Williamson and invalidated many thousands of patents because they have a descriptive phrase in front of the word “processor”. As if because you have a descriptive phrase in front of processor then you have to have an algorithm and description to support this new processor. Just absurd. People skilled in the art would not construe the claims as such nor would they need an express algorithm.
This is the holding:
Because the district court correctly construed the limitation “a collaborative application management processor configured to manage collaborative applications” to be in means-plus-function form, and because the specification
lacks corresponding structure, we affirm. We need not and do not address the district court’s holding of indefiniteness of the remaining limitations at issues.
… it comes down to the patent law notion of “ladders of abstraction.”
Some want unique ‘objective physical structure’ that is explicit in its physicality as to why it is not only different from, but non-obviously different from, any other explicit ‘objective physical structure,’ with that difference explicitly claimed.
That though is simply not a legal requirement.
Not just that anon. But a disclosure should be what is knew. A disclosure that explains how a known algorithm or method is modified is enough under Phillips. Williamson is saying that the judges are not construing the claims in accordance with Phillips but in accordance with their new made-up way.
My bet: The Supreme Court at some point will smack them down.
Betting on the Supreme Court to be pro-patent is a risky adventure.
A problem with the word processor is usually one would also like it to also cover neural networks or other alternatives to processors without it being considered a MPF term (this is likely to become more and more of an issue as – and if – neural network-AIs become more popular). In an ideal world, I suppose that such a minor variation would be covered by the breadth of the term or by the doctrine of equivalence. However, it is my impression that the current caselaw has unduly muddied that issue quite a bit. If it were only the word processor that faces this sort of issue, it would not be so bad, but I think the reality is that it is easy to be blind-sighted regarding the scope of a term/MFP/lack of doctrine of equivalence/lack of enablement.
When I was writing provisional applications for my boss to review and submit I always added an extra set of MPF claims at the end. I made sure the extra MPF claims had a section in the spec providing explicit structure for all elements because our patent attorney loved to use vague claim language and I worried that a situation like the one in WSOU v. Google would happen where the regular claims would be construed as indefinite or MFP. I argued that MFP claims where a way to get a quick allowance since examiners rarely examine those claims as closely since they are locked to the structure in the spec. Anybody out there do a belt and suspenders type prep and pros work to anticipate or avoid this kind of malpractice risk? Doing a little extra work up front in the application seems to be cheap insurance in my book. Any ideas or suggestions for boilerplate?
I typically found it rare that provisionals were written with anything but omnibus style claims.
It was not a practice that I liked or espoused, as I also viewed provisionals should not be treated as “quick and d1rty” just to draw a line in the timeline, but rather should have as much meat as necessary to validly support any “true” non-provisional that followed.
Unfortunately, there is a sizable contingent that view the cost/benefit aspect differently, and what the client would pay for was a Subaru rather than a Bentley.
I even have had to counsel clients to NOT claim priority to extremely p00rly written provisionals (written either in-house or by others, naturally), as language used contained mortally deficient statements.
One client said he wanted Cadillacs for the price of a Chevette after provisionals were implemented.
A not altogether too-rare occurrence, unfortunately – and an item that routinely calls for tact from practitioners to juggle scope creep and [the reason why I push for understanding that provisionals are NOT for ‘quick and d1rty’] proper legal coverage IN any provisional filing stage.
This is not to say that a client cannot change their aim along the way – only that a change from a chevette provisional to a Cadillac non-provisional will be taken at a Cadillac-plus price.
This is also the inflection point in which client counseling occurs based on possible “dings and dents” of that chevette provisional effort.
Frame by Fram: link to youtu.be
Again, what we have here is the anti-patent judicial activists trying to remove the any person of ordinary skill in the art. This is really sickening how far this has come.
No one who actually does this type of work would have any trouble understanding the metes and bounds of the claims based on the terms used. Nor would they have any trouble with enablement nor with written description.
A judge pretending that the specification is supposed to start from scratch and not from what is new and not from what a ordinary person skilled in the art already knows is sickening. Just not applying the law. Not even attempting to create jurisprudence for a stable patent system. Just decisions to weaken patents. Just disgusting.
People of ordinary skill in the art think in terms of Turing Machines and know all these machines are equivalent. And there is no reason we should have to have 5 or 10 pages of boilerplate language. Of course, all my applications have it those pages but they cost a lot of money.
We should be able to focus on the invention and what is new. Not try to CYA from these filthy judges who try to find some way to invalidate the patent that flies with English and gender study majors.
Thanks Obama for packing the CAFC with filth.
“from these filthy judges… with English and gender study majors.”
B-b-but “equity”
(not for you, but for those that place ‘equity’ over reason:
)
Just FYI, only one of the judges in this decision was appointed by Obama.
Also, two judges have Electrical Engineering degrees (where one worked for the Office of Naval Research) and the third has an MS in Organic Chemistry and a PhD in Chemistry.
They aren’t English and Gender Study Majors.
Let’s see what Google says. Gee, filth judges, seems like this is a common term that anyone skilled the art would understand. Meaning it should not have to be defined in the specification. Phillips. My bet is that the Supreme Court at some point will stomp on the CAFC again for this holdings were the person of ordinary skill in the art has been removed. The judges are just filth.
A processor is an integrated electronic circuit that performs the calculations that run a computer. A processor performs arithmetical, logical, input/output (I/O) and other basic instructions that are passed from an operating system (OS). Most other processes are dependent on the operations of a processor.
link to techopedia.com
A judge pretending that the specification is supposed to start from scratch and not from what is new and not from what a ordinary person skilled in the art already knows is sickening… Not even attempting to create jurisprudence for a stable patent system. Just decisions to weaken patents. Just disgusting.
Wait, so Alan Albright of the WD Tex is anti-patent? So why are so many patentees fighting so assiduously to have their cases in his courtroom?
This is coming from the CAFC. I don’t get either why Albright bought into this.
Maybe consider too that this is matter of picking the lesser of the evils.
Maybe too consider commenting on the substance of my post regarding whether the term “processor” should be a MPF or nonce word. Maybe consider not going down a tangent and addressing the issue.
Maybe too consider commenting on the substance of my post regarding whether the term “processor” should be a MPF or nonce word.
Fair enough. Good news for you: the opinion says quite explicitly (slip op. at 8) that “processor” is not a nonce word. Similarly, when faced with “processor” in a context in which the patentee did not give the word a crazy broad definition in the spec, the CAFC reversed Albright’s construction of “processor” under §112(f).
In other words, the CAFC—far from being “filthy judges who try to find some way to invalidate the patent”—are actually on your side of this debate. I happen to think that “processor configured to ____” should ordinarily get a §112(f) construction, but the CAFC held the opposite here. The patentee actually had to work fairly hard here (by putting a definition of “processor” that goes way beyond the structure that most skilled artisans would envisage when you say “processor”) to get “processor” construed under §112(f). Someone who avoids adding such absurd definitions in their spec has nothing to fear from this decision.
Yeah, he was blowing off a bit of steam that perhaps did not track to the facts of this particular case profile.
Actually, what I said does follow the facts. I read the opinion.
This is a twisted opinion that extends Williams, which does not follow Phillips.
I might write more later. But basically this invalidates probably about 10,000-100,000 patents out there. The old way of claiming was to name funcational aspects of the claim as they have done here. And then to deal with new case law we went to just “one or more processors configured to” or added intermediary language about instructions. The CAFC is using a few words before processor to invalidate the claims and requiring an algorithm like in Williamson.
The issue is that “processor” does connote the required structure despite the CAFC claim. And the issue is then whether the functions specified are enabled and the CAFC says no they need an algorithm per Williamson.
What Greg wrote is shear nonsense again.
Greg, what are you talking about? The DC holding was affirmed.
It was affirmed as to one patent (slip op. at 7-10) and reversed as to the other (slip op. at 10-12).
The reversed one was based on a minor disclosure of structure for a processor. Ridiculous. The terms are supposed to be interpreted as one of ordinary skill in the art would interpret them.
Just filthy, dirty judges.
Again, what we have here is the anti-patent judicial activists trying to remove the any person of ordinary skill in the art. This is really sickening how far this has come.
It sounds like you should be blaming WSOU for not putting forth evidence of what a person of skill in the art would know. How is a judge supposed to evaluate what a POSITA would know without such evidence?
No one who actually does this type of work would have any trouble understanding the metes and bounds of the claims based on the terms used. Nor would they have any trouble with enablement nor with written description.
A judge pretending that the specification is supposed to start from scratch and not from what is new and not from what a ordinary person skilled in the art already knows is sickening. Just not applying the law. Not even attempting to create jurisprudence for a stable patent system. Just decisions to weaken patents. Just disgusting.
You’re whining about Alan Albright, the most plaintiff friendly judge in the country.
And of course, your rant is completely untethered from the requirements of 112(f) and Williamson.
And tethered to Phillips.
“ No one who actually does this type of work would have any trouble understanding the metes and bounds of the claims based on the terms used.”
ROTFLMAO
I personally never construe “a processor configured to” in means-plus, but I do know of some examiners who do. Regardless, there is no sympathy from me as the issue is easily settled by including boilerplate that no claim language invokes means-plus unless it uses the term “means for.” The fact that boilerplate such as that is not routinely included suggests to me that the prosecutor is attempting to leave the door open for the litigator, so I have little sympathy if it ends up letting a draft in.
The rule actually is that the claim is not valid if you’re not including even vaguely particular algorithms for the functionality. The caselaw surrounding written description outside of means plus is just as d@mning as the caselaw surrounding definite disclosure for embodiments inside of means plus.
Maybe Eugene will share my story about why Cushing Dolan is not getting my Documents to me. And why Schoonover saw the need to use Patrick Egan and his TRUSTY TOOL PATENT to bring my stolen patent to MO from Canada with no prior art listed, and then have SCHOONOVER act as prosecuting atty. Priceless
Here, he erased it though.
Random, we should not have to use boilerplate language for what any person skilled in the art already knows.
I am a person skilled in the art of computer science and computer architecture as well as a patent attorney. It is just absurd to construe a processor as a MPF term or a nonce term.
Tell me what the alternatives are? What in the world could it mean other than what is in the all the boilerplate language. And let’s consider the cost of all this boilerplate language that is unnecessary.
Random, we should not have to use boilerplate language for what any person skilled in the art already knows.
It has nothing to do with what the art knows. It has to do with whether you are choosing to invoke a claim to one legal scope size or to another legal scope size.
It is just absurd to construe a processor as a MPF term or a nonce term.
The construction was based on the specification, and the applicant is entitled to set their own definitions.
Tell me what the alternatives are? What in the world could it mean other than what is in the all the boilerplate language. And let’s consider the cost of all this boilerplate language that is unnecessary.
Really? You write one paragraph one time and hit copy/paste into all your specs. I have seen those paragraphs, so clearly someone is willing to pay the exorbitant cost of thirty seconds of a lawyer’s time.
“Really?”
I chuckled as you show an almost unimaginable lack of understanding for your job as an examiner and deign to give advice to practitioners.
Just how high is your peak of Mount S?
+1
Courts routinely ignore boilerplate phrases and paragraphs like that when it suits them. Those kind of things look good in the specification when drafting and from the point of view of the patent owner, but judges seldom care. The best you’ll get is a presumption that something is not MPF, but a judge who knows next to nothing about technology is going to come to whatever conclusion he/she thinks is easiest for disposing of the case.
“The fact that boilerplate such as that is not routinely included suggests to me that…”
It suggests that you have exactly zero clue.
Please find some other occupation.
I do know of some examiners who [construe “a processor configured to” in means-plus].
Interesting. Can you point me to a file wrapper where you have seen this happen? I confess that I have never seen an examiner treat functional language under §112(f) unless the word “means” is involved (and often not even then). It is not consistent with the BRI to treat “processor” (or “binder,” or “linker,” etc) under §112(f).
[T)he issue is easily settled by including boilerplate that no claim language invokes means-plus unless it uses the term “means for.”
I share Dvan’s skepticism about the likely success of this approach. Courts are not overawed by boilerplate.
I’ve seen it happen, but it’s pretty rare, and it’s usually been in cases where the claim language recites an explicit nonce (e.g., module).
Interesting. Can you point me to a file wrapper where you have seen this happen? I confess that I have never seen an examiner treat functional language under §112(f) unless the word “means” is involved (and often not even then).
Not off the top of my head. I personally do means-plus if it is “code for” or (more commonly) “module for.”
It is not consistent with the BRI to treat “processor” (or “binder,” or “linker,” etc) under §112(f).
True, but the MPEP guides by saying only 2 of the 3 criteria need to be met for a means-plus interpretation. Processor configured to do a function doesn’t meet the nonce term, but does meet a linking word to function without sufficient structure to perform it.
The MPEP states that all three prongs of the test set out in 2181 must be met for a MPF limitation, whether it uses “means” or a nonce word. There’s nothing there saying you only have to meet two of the prongs.
Thanks – that section of the MPEP (emphasis added):
“Accordingly, examiners will apply 35 U.S.C. 112(f) to a claim limitation if it meets the following 3-prong analysis:
(A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function;
(B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; AND
(C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function.
Like most things of law, Random tends to make things up and has no issue with ‘interpreting’ “and” as “or” to reach his desired ends.
How many MPF cases have you read? I can’t see that boilerplate working, as it would overturn countless CAFC cases.
Your idea of an algorithm is correct, but the issue is that these can be difficult to provide. Consider this part of the claim:
a processor configured to move automatically a sub-set of
pixels defining a target captured image that corresponds
to the first picture, within a larger set of available pixels
in a direction of an edge of the target captured image
when a defined area of interest within the target captured
image approaches the edge of the target captured image
What’s the “algorithm” for this?
You can’t see the structure there? You must be some kind of Luddite from the Bronze Age.
^^^
Very serious.
“Preemptive user output”
Very serious.
As serious as Greg’s hidden links?
Panel composition is underrated: Stoll and Lourie seem to be very bad draws in appeals where Williamson issues arise. They both seem to read 112(f) very narrowly. But the opinion reads like they’re walking back Dyfan a little bit (especially after Judge Prost absolutely ripped the Dyfan decision at an oral argument earlier this year).
Also, I can’t believe that Google didn’t hire an expert for claim construction. It’s not always necessary, but best practice is to have an expert declaration if you’re arguing a term is means-plus-function and indefinite.
Specifically, the specification
teachesthat the term ‘processor’ is synonymous with terms like controller and computer.There, fixed it. First-graders would not be “taught” by that disclosure.
“First-graders would not be “taught” by that disclosure.”
That bar had already been lowered by the courts due to their insistence on patent profanity.
The more powerful the PHOSITA is for 103, the lower the bar for 112.
I know it must be difficult for you to see from that ditch you were tossed in fifteen years ago (from a moving vehicle, remember?) but the “profanity” is trying to pretend that logic has some objective non-abstract structure that is discernible from phrases like “provide a preemptive user output when a targeted picture edge limit determined”.
The responsibility for that “profanity” lies 100% on shameless patent huffers like you.
Malcolm, Malcolm, Malcolm.
(your feelings are noted)
It looks like Malcolm needs a refresher with his comment of, “but the “profanity” is trying to pretend that logic has some objective non-abstract structure that is discernible from phrases like…”
The particulars here are less important than the understanding from a factual and legal basis that the design choices of “wares” in the computing arts are – in fact – patent equivalent (hardware == software == firmware; ASICS and the like and all**)
This was shown in the Grand Hall experiment — which to this day has not been refuted.
** rest in peace, Martin Goetz
link to nytimes.com
The more powerful the PHOSITA is for 103, the lower the bar for 112.
What is the basis for this in law? Certainly it applies to enablement, but do you have a case that it applies to written description or, as here, to indefiniteness? One would think that the more powerful the PHOSITA is the harder it is for 112(b) in view of (f), since they can reason even more structures that may achieve the function, making it even harder to specifically point to a specification example. Written description is PHOSITA-agnostic, as the question is what views the patentee to have possessed vis-a-vis the scope claimed, not what is obvious to the PHOSITA.
Do you have a case saying that stronger PHOSITA = easier to show definite or possessed?
Basis in law….?
Are you really an examiner?
Serious question.
Description and possession are most definitely not PHOSITA-agnostic.
“Written description is PHOSITA-agnostic…”
Wow.
But I guess I shouldn’t be surprised at the ignorance of this statement given the source.
Here’s claim 1 of the ‘045 which looks like it was drafted by a team of kangaroos who’d spent all night licking cane toads:
1. An apparatus comprising:
a viewfinder display configured to display a first and second picture,
a processor configured to move automatically a sub-set of pixels defining a target captured image that corresponds to the first picture, within a larger set of available pixels in a direction of an edge of the target captured image when a defined area of interest within the target captured image approaches the edge of the target captured image [this paragraph is nonsense],
said processor configured to provide a pre-emptive user output when the sub-set of pixels approaches an edge of the set of available pixels,
and
the second picture corresponds to the larger set of available pixels [why not say this right off the bat?]
wherein the viewfinder display is configured to display the first picture within the second picture [repeated element -classy!].
The hotlink to the decision doesn’t work. Was it withdrawn?
Try this: link to cafc.uscourts.gov
Thanks!
Without diving into the spec (but reading the decision), there may well not be much to see here, given the admission on page 8 of the decision:
“To be sure, the term “processor” is not a nonce word and, in some circumstances, the term would connote sufficient structure…“
“ “To be sure, the term “processor” is not a nonce word and, in some circumstances, the term would connote sufficient structure…“
No doubt. Those circumstances are easy to describe, too. Hint: they don’t include the circumstances where the novelty lies in the logic processing functionality of the processor.
Absolutely – and repeatedly – incorrect from the multiple angles of fact, law and history.
But you (continue to) be you.
Not really where the law is on the specific issue of whether processor is a means-plus-function claim term: a couple of useful “tests” have arisen to assess the question of whether a processor is MPF, primarily out of ED Tex, and the more useful of the two is the “is the claimed processor defined by the function it performs?” test, from the St. Isidore case cited in the Fed Cir opinion. Under that test, a processor limitation is MPF if the only thing you can tell about the processor from the claim language is the function the processor is performing.
Review of district court case law I did a couple of years ago suggested that a processor was not a means-plus-function in about 80% of cases where the issue was raised.
The point of novelty argument you raise is an interesting one (and it stems from language in a fairly old SCOTUS case, IIRC), but it invites a dispute about what the novelty in a given claim is that can’t be litigated at claim construction.
“ the two patents at issue are related to image tracking technology (the ‘045 patent) and gesture control technology (the ‘825 patent).”
Oooh, you can just sense the super serious “tech” dripping off these patents. Can we see the claims? Monday laughs are some of the most important laughs of the week.
U.S. Patent Nos. 8,965,045 and 9,335,825.
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