Apex, Inc. v. Raritan Computer, Inc.
United States Court of Appeals for the Federal Circuit
325 F.3d 1364, 66 U.S.P.Q.2d 1444 (2003)
- Written by Eric Miller, JD
Facts
Apex, Inc. (plaintiff) sued Raritan Computer, Inc. (Raritan) (defendant), alleging infringement of three patents held by Apex on computer switching systems. Though none of the claims at issue used the word “means,” the district court held that the claims relied on means-plus-function language—i.e., claims that were described in functional terms without reciting the structures for performing their functions. However, the court found the patents’ use of means-plus-function language acceptable under 35 U.S.C. § 112 because the invention’s underlying structure was sufficiently described in the specification. The court’s conclusion was reached with reference to individual words within the claims—for example, “circuit”—as opposed to the language of the claims as a whole—for example, “circuit” as modified by adjectives like “interface.” The district court therefore granted summary judgment of noninfringement. Raritan appealed to the United States Court of Appeals for the Federal Circuit.
Rule of Law
Issue
Holding and Reasoning (Gajarsa, J.)
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