Noah Systems, Inc. v. Intuit, Inc.

675 F.3d 1302, 102 U.S.P.Q.2d 1410 (2012)

From our private database of 46,500+ case briefs, written and edited by humans—never with AI.

Noah Systems, Inc. v. Intuit, Inc.

United States Court of Appeals for the Federal Circuit
675 F.3d 1302, 102 U.S.P.Q.2d 1410 (2012)

Facts

Noah Systems, Inc. (Noah) (plaintiff) sued Intuit, Inc. (defendant) in federal court for patent infringement of U.S. Patent No. 5,875,435 (the 435 patent). The 435 patent disclosed an automated system for accounting that allowed a person or business to connect a computer to another computer to transmit financial information. Noah alleged that certain Intuit accounting products infringed claims of the 435 patent containing a special-purpose, computer-implemented access-means limitation. Noah and Intuit agreed that the access-means limitation was written in means-plus-function form and that the two functions recited in the limitation were (1) allowing file access and (2) enabling the performance of operations. The specification for the 435 patent explained that data inputs could not be altered within the main system without a verified passcode, which was the algorithm for performing the file-access function. No algorithm in the specification disclosed how to perform the enabling-operations function. Intuit filed a motion for summary judgment of invalidity. The district court construed the claim and held that the 435 patent described no corresponding algorithm at all for performing the recited functions, rendering the claims of the 435 patent indefinite and the patent invalid. The district court granted summary judgment of invalidity to Intuit without permitting Noah to introduce expert testimony on the perspective of a person ordinarily skilled in the art. Noah appealed.

Rule of Law

Issue

Holding and Reasoning (O’Malley, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 832,000 law students since 2011. Some law schools even subscribe directly to Quimbee for all their law students.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

Here's why 832,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,500 briefs, keyed to 994 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 832,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,500 briefs - keyed to 994 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership