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circuit for 以及 receiver,都是結構限制而不只是功能性敘述

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(1)

LINEAR TECHNOLOGY CORP. v. IMPALA LINEAR CORP.

 

United States Court of Appeals, Federal Circuit.

DECIDED: August 17, 2004.

 

disputed term: a first circuit for monitoring a signal

 

引用Apex, 325 F.3d at 1374: ”Moreover, every use of the term [`circuit'] in the asserted claims includes additional adjectival qualifications further identifying sufficient structure to perform the claimed functions to one of ordinary skill in the art.”

 

We hold that because the term "circuit" is used in each of the disputed limitations of claims 1, 44, 55, and 57 of the '178 patent with a recitation of the respective circuit's operation in sufficient detail to suggest structure to persons of ordinary skill in the art, the "circuit" and "circuitry" limitations of such claims are not means-plus-function limitations subject to 35 U.S.C. § 112 ¶ 6.

 

(2)

ENOCEAN GMBH v. FACE INTERNATIONAL CORPORATION

 

United States Court of Appeals, Federal Circuit.

Decided: January 31, 2014

 

disputed term: a signal receiver for receiving

 

The term “receiver” (i.e., the absence of the term means) presumptively connotes sufficiently definite structure to those of skill in the art. See Personalized Media, 161 F.3d at 703-04. And in this case, Face has not overcome that presumption. Indeed, the record indicates that the term “receiver” conveys structure to one of skill in the art—the Board itself made a factual finding that that the “skilled worker would have been familiar with the design and principles of the types of components utilized in the claimed invention, including . . . receivers.” J.A. 18.

 

We also come to this conclusion, in part, because EnOcean has provided extensive evidence demonstrating that the term “receiver” conveys known structure to the skilled person. See, e.g., J.A. 1772-73, 1947 (scientific literature demonstrating that the term “receiver” was well understood in the art); J.A. 1199-1220, 1377-87, 1434-35, 1654-64 (expert declarations addressing how well known the term “receiver” was); see also Inventio, 649 F.3d at 1356 (calling for courts to consider relevant extrinsic evidence to determine whether a claim term invokes § 112, ¶ 6).

 

Further, we are not persuaded by Face’s arguments that the term “receiver” is simply too broad to recite sufficiently definite structure. We have stated previously that just because “the disputed term is not limited to a single structure does not disqualify it as a corresponding structure, as long as the class of structures is identifiable by a person of ordinary skill in the art.

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