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Keywords

testimonypatent

patent

Related Cases

Lighting Ballast Control LLC v. Philips Elecs. N. Am. Corp., 498 Fed.Appx. 986, 2013 WL 11874

Facts

The patented technology relates to control and protection circuits for electronic lighting ballasts commonly used in fluorescent lighting. High levels of electric current are required to start a fluorescent lamp. The electronic ballast helps maintain a current level high enough to start the lamp while simultaneously preventing current from reaching destructive levels.

Issue

Whether the term 'voltage source means' in the claims of the _529 Patent is a means-plus-function limitation and whether the claims are invalid for indefiniteness.

Rule

Analysis

The court determined that the term 'voltage source means' triggers a presumption of means-plus-function claiming due to the inclusion of the word 'means.' The claim only describes the function of providing DC voltage without sufficient structural detail. Expert testimony suggested possible structures but did not establish that the specification disclosed any specific structure, leading to the conclusion that the claims were indefinite.

Conclusion

We hold that the _529 Patent fails to disclose structure capable of 'providing a constant or variable magnitude DC voltage between the DC input terminals.'

Who won?

Lighting Ballast Control LLC prevailed in the case as the court found the claims of the _529 Patent invalid for indefiniteness.

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Keywords

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