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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)
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
Holding and Reasoning (Linn, J.)
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