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Keywords

appealpatent

patent

Related Cases

Ergo Licensing, LLC v. CareFusion 303, Inc., 673 F.3d 1361, 102 U.S.P.Q.2d 1122

Facts

Ergo Licensing, LLC, the patent owner, brought an infringement action against CareFusion 303, Inc. regarding U.S. Patent No. 5,507,412, which describes an infusion system for delivering fluids to patients. The district court found that the terms 'control means' and 'programmable control means' were indefinite due to a lack of corresponding structure disclosed in the patent specification. Ergo appealed this decision, arguing that the specification adequately described the control device as a known structure.

Issue

Whether the means-plus-function claims in the patent were indefinite due to a failure to disclose corresponding structure.

Rule

Analysis

The court analyzed the specification and determined that the term 'control device' did not provide sufficient structure to perform the function of 'controlling the adjusting means.' The court noted that while a general-purpose computer could perform the function, the specification failed to disclose a corresponding algorithm, which is necessary for computer-implemented means-plus-function claims. Ergo's argument that the control device was a known structure was rejected, as the court found that the specification did not adequately describe how the control device would operate.

Conclusion

The Court of Appeals affirmed the district court's ruling that the means-plus-function claims were indefinite due to the lack of disclosed structure.

The district court correctly determined that the 'control means' terms are indefinite for failure to disclose corresponding structure.

Who won?

CareFusion prevailed in this case as the court upheld the district court's finding of indefiniteness regarding the means-plus-function claims.

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