by Dennis Crouch Patent attorneys will recognize the case name Graham v. John Deere Co., 383 U.S. 1 (1966), as the Supreme Court's foundational statement on obviousness under 35 U.S.C. § 103. Sixty years later, a new case with nearly the same name has arrived at the Federal Circuit, though this one is spelled with two m's. Gramm v. Deere & Company, No. 2024-1598 (Fed. Cir. Mar. 11, 2026), involves neither obviousness nor the Graham factors. Instead, it offers an illustration of means-plus-function claiming under § 112(f) and the doctrinal hazards. The Federal Circuit, in a unanimous opinion by Judge Reyna joined by Judges Lourie and Cunningham, reversed the district court's indefiniteness finding and remanded for further proceedings.