Noah Systems, Inc. v. Intuit, Inc.

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.