Sony Prevails at CAFC in Decision Faulting Patent Owner's Means-Plus-Function Analysis

""Though we articulated a component-by-component analysis was unnecessary in Odetics, the patentee must still account for each element of the claimed structure in its equivalence analysis." - CAFC opinion The U.S. Court of Appeals for the Federal Circuit (CAFC) on Thursday issued a precedential decision finding Sony's Playstation controllers and consoles did not infringe Genuine Enabling Technology's (GET's) patent for computer input devices. GET alleged that Sony directly and indirectly infringed its U.S. Patent No. 6,219,730 via certain Playstation products."

""Literal infringement of a [means-plus-function] limitation requires that the relevant structure in the accused device perform the identical function recited in the claim and be identical or equivalent to the corresponding structure in the specification," wrote the CAFC, citing to Odetics, Inc. v. Storage Tech. Corp., 185 F.3d 1259, 1267 (Fed. Cir. 1999). Relying on its decision in Traxcell Techs., LLC v. Sprint Commc'ns Co., 15 F.4th 1121, 1127 (Fed. Cir. 2021), the Federal Circuit said that GET's expert failed to sufficiently describe the "'way' the 'encoding means' structure in the '730 patent performs its function.""

The Federal Circuit affirmed that Sony's PlayStation controllers and consoles did not infringe U.S. Patent No. 6,219,730 owned by Genuine Enabling Technology. GET alleged Bluetooth modules synchronized controller button input with sensor input to satisfy a claimed "encoding means." The district court construed the limitation as means-plus-function and granted Sony summary judgment of non-infringement. The CAFC held literal means-plus-function infringement requires the accused structure to perform the identical function and be identical or equivalent to the structure disclosed in the specification. The court found GET's expert failed to explain the 'way' the patented encoding structure performs its function, leaving structural equivalence unproven.

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