Cir. 2003)). Here, the structure corresponding to the means-plus-function limitations was held to be the core logic of a computer adapted to perform a specified program along with the protocol used to perform the program, and the Federal Circuit held that the “patent is not indefinite merely because
no specific circuitry is disclosed to show the modification”.
The most recent cases from the Federal Circuit related to the interpretation of computer-implemented functional language in mean-plus-function claims further highlight the confusing state of the law regarding claim definiteness under § 112, second paragraph vis-à-vis computer-implemented means-plus-function limitations as interpreted under § 112, sixth paragraph. These most recent cases could be characterized in at least the following three categories:
However, the In re Katz decision confused the requirement of disclosing the specific algorithm by allowing no disclosure of an algorithm when the function can be achieved by any general purpose computer without special programming. Specifically, in this case, the Federal Circuit criticized the lower court for interpreting the principles of WMS Gaming, Harris, and Aristocrat too broadly – the Federal Circuit stated that “[t]hose cases involved specific functions that would need to be implemented by programming a general purpose computer to convert it into a special purpose computer capable of performing those specified functions…By contrast, [in the claims at issue], Katz has not claimed a specific function performed by a special purpose computer, but has simply recited the claimed functions of “processing,” “receiving,” and “storing.”” – the Federal Circuit held that it was not necessary to disclose
more structure than the general purpose processor that performs those functions…because the functions of “processing,” “receiving,” and “storing” are coextensive with the structure disclosed, i.e., a general purpose processor.