Epcon Gas Systems, Inc. v. Bauer Compressors, Inc.

279 F.3d 1022, 61 U.S.P.Q.2d 1470 (2002)

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Epcon Gas Systems, Inc. v. Bauer Compressors, Inc.

United States Court of Appeals for the Federal Circuit
279 F.3d 1022, 61 U.S.P.Q.2d 1470 (2002)

  • Written by Sara Adams, JD

Facts

Epcon Gas Systems, Inc. (Epcon) (plaintiff) sued Bauer Compressors, Inc. (Bauer) (defendant) for patent infringement in federal court. The district court determined that claim 2 and claim 16 of the Epcon patent required analysis under 35 U.S.C. § 112, paragraph 6, because claim 2, a method claim, contained a step-plus-function limitation and claim 16, an apparatus claim, contained a means-plus-function limitation. Epcon agreed with the district court that the apparatus claim included a means-plus-function limitation. However, Epcon appealed the court’s finding as to the method claim, arguing that no limitations in claim 2 were constructed in step-plus-function form. Specifically, claim 2 of the Epcon patent recited a series of steps but did not include a function or any language such as “a step for” that would indicate a step-plus-function claim. Epcon argued that because claim 2 was not written with a step-plus-function limitation, it was improperly reviewed by the district court under the framework of § 112, paragraph 6.

Rule of Law

Issue

Holding and Reasoning (Linn, J.)

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Casebooks

Patent

Key Terms

  • 35 U.S.C. § 112(f)[35 U.S.C. § 112, paragraph 6 pre-America Invents Act] A patent-law provision stating that a claim element for a combination may be stated as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and the claim must be construed to cover the corresponding structure, material, or acts described in the specification and equivalents.
  • Method ClaimA patent claim in which the product is defined, at least in part, in terms of the method or process by which it is made. This type of patent claim is sometimes referred to as a product-by-process claim.
  • Patent InfringementUnder the general infringement section of 35 U.S.C. § 271, a person who imports, sells, offers to sell, or uses in the United States without authorization a patented invention, process, machine, or manufacture is chargeable with infringement of the patent.

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