Aristocrat Technologies Australia Pty Ltd. v. International Game Technology
United States Court of Appeals for the Federal Circuit
521 F.3d 1328 (2008)
Aristocrat Technologies Australia Pty Ltd. (“Aristocrat”) (plaintiff) held the ‘102 patent related to an electronic slot machine. International Game Technology (“IGT”) (defendant) manufactured similar gaming products and was sued by Aristocrat for infringement of the ‘102 patent in the U.S. District Court for the District of Nevada. The key question was the definiteness of the term “game control means” in claim 1 of the ‘102 patent. The parties agreed that the term was a means-plus-function term which invoked 35 U.S.C. § 112, paragraph 6. Consequently, the claim limitation’s scope had to be defined by the structure disclosed in the specification, plus any equivalents, or else the limitation would lack specificity, rending the claim invalid for indefiniteness under 35 U.S.C. § 112, paragraph 2. Aristocrat argued that the invention was a standard microprocessor-based gaming machine with “appropriate programming,” but the district court concluded that the specification contained no guidance to determine the meaning of “standard microprocessor” or “appropriate programming.” The court said that the ‘102 patent lacked a “specific algorithm” or any step-by-step process for performing the claimed functions of the slot machines. The district court held that all of the ‘102 patent claims invalid for indefiniteness and Aristocrat appealed.
Rule of Law
Holding and Reasoning (Bryson, J.)
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