Digest of Williamson v. Citrix Online, LLC, No. 2013-1130 (Fed. Cir. Nov. 5, 2014) (precedential). On appeal from C.D. Cal. Before Moore, Linn, and Reyna.
Procedural Posture: Plaintiff-appellant Williamson appealed the district court’s stipulated judgment of noninfringement and invalidity based on the district court’s alleged errors in claim construction. The Federal Circuit overruled the lower court’s construction of several claims, reversed the grant of summary judgment of invalidity and noninfringement, and remanded.
- Claim Construction: The district court improperly read limitations from the specification as requiring a “pictorial map” in the “graphical display” claim terms. Further, the district court erred in concluding that “distributed learning control module” is a means-plus-function claim term, because the strong presumption against invoking 35 U.S.C §112 ¶ 6 absent the word “means” was not overcome. Specifically, the Federal Circuit found that “module” denoted a structure, and is more than a nonce word for “means.”
- Claim Construction: The majority erred because repeated references in the specification and during prosecution to the visual representation of a classroom requires that the limitation “graphical display representative of a classroom” term include a visually depicted classroom. Further, the claim term “module” is a nonce word which lacks structure. Thus, claims including the “distributed learning control module” limitation are means-plus-function claims, for which the patent fails to disclose corresponding structure in the specification, and the claims are invalid as indefinite.