In WILLIAMSON v. CITRIX ONLINE, LLC, Appeal No. 2013-1130, the Federal Circuit vacated and remanded a stipulated judgment of non-infringement and invalidity due to an incorrect claim construction.
The patent concerned a virtual classroom environment. The district court construed the term “graphical display” to require a “pictorial map.” The Federal Circuit disagreed, reasoning that the actual claim language did not require a pictorial map and the embodiments in the specification only “preferably” provided a pictorial map. Therefore, the construction requiring a pictorial map improperly imported a limitation from the specification into the claim.
The Federal Circuit also disagreed with the district court’s construction of the term “distributed learning control module” as a means-plus-function limitation for three reasons. First, dictionary definitions showed that the term “module” connotes either hardware or software structure to those skilled in the art. Second, the district court should have analyzed the phrase as a whole instead of inappropriately focusing on the single claim term “module,” without its modifiers. Third, the surrounding context of the claim term supported the conclusion that the term connotes structure.
Judge Reyna dissented and disagreed with of the majority’s means-plus-function analysis because the claim used the traditional means-plus-function format, substituting the term “module” for “means.” The dictionary definitions of the term “module” only recited function, and the context of the claim term provided no structural significance.