Rain vs. Samsung: Fed. Cir. reversed District Court Judgment on Indefiniteness

Rain vs. Samsung: Fed. Cir. reversed District Court Judgment on Indefiniteness

Federal Circuit reversed the District Court's judgment on indefiniteness on the claim of Patent being filed by Rain Computing. The decision comes up when Defendant Samsung Electronics cross-appeal the District Court judgment asserting the claims to be indefinite.

Rain's US Patent 9,805,349 is used for delivering the apps via a computer network using web store and server authentication. The claim says that it requires "a user identification module configured to control access of said one or more software application packages." The claims are generally being used for substantiating the actual structure of the invention.

This case refers to the understanding of 35 USC § 112(f) which states that an element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.

But this statute is silent on the specification which does not correspond to any structure. Therefore, the court held that those claim which lacks the corresponding structure will be deemed to be invalid for indefiniteness, this being a means-plus-function claim. This means-plus-function (MPF) claim generally relates to the thin disclosures which are narrowly claimed and are invalidated. Nevertheless, these claims were also been held to broad interpretation by the inventor and were rarely invalidated.

In Williamson vs. Citrix Online, the Federal Circuit held that if the claim terms fail to recite sufficiently definite structure or else recites function without reciting sufficient structure for performing that function" will also be interpreted as a means-plus-function term.

The Court drew the same understanding of the claim of Rain Computing that the "user identification module" does not ascertain with any corresponding structure. The Court further states, "Nothing in the claim language or the written description provides an algorithm to achieve the "control access" function of the "user identification module." When asked at oral argument to identify an algorithm in the written description, Rain could not do so. Without an algorithm to achieve the "control access" function, we hold the term "user identification module" lacks sufficient structure and renders the claims indefinite."

Moreover the Court stated, "Likewise, "module" here does not provide any indication of structure, and Rain fails to point to any claim language providing any structure for performing the claimed function of being configured to control access. Nor does the prefix "user identification" impart structure because it merely describes the function of the module: to identify a user. The structure disclosed in the specification is a corresponding structure only if the specification or prosecution history links or associates that structure to the function recited in the claim."

Finally, the Court revised the decision of the District Court, stating the claims to be indefinite and giving the judgment in favour of Samsung.