Federal Circuit Finds Means–Plus–Function Algorithm Claim Invalid for Indefiniteness
By Aditya Gupta – Edited by Kathleen McGuinness
Ibormeith IP, LLC v Mercedes-Benz USA, LLC
The Federal Circuit affirmed a district court’s holding that certain means-plus-function claims of Ibormeith’s patent - “Sleepiness Detection for Vehicle Driver or Machine Operator” – were invalid for indefiniteness under 35 U.S.C. § 112. The court also noted that Ibormeith’s arguments for the breadth of its disclosure, for the purpose of infringement, must be held as “binding admissions” when evaluating claim validity.