In Fintiv, Inc. v. PayPal Holdings, Inc., the Federal Circuit ruled that Fintiv's patent claims were invalid for indefiniteness, emphasizing that key terms such as "payment handler" should be evaluated under 35 U.S.C. § 112(f). The court applied a two-step analysis that determined these terms lacked inherent structural meaning and found insufficient support in the specification. This case illustrates ongoing challenges in claim construction for software patents and highlights the need for precise language in patent documentation to prevent indefiniteness.
The Federal Circuit affirmed the invalidation of Fintiv's claims based on indefiniteness, as terms lacked inherent structural meaning under means-plus-function limitations.
In applying 35 U.S.C. § 112(f), the court determined that Fintivâs claim terms did not have sufficient structural support in the specification.
The ruling underscores the importance of clearly defining claim terms in patent applications to avoid indefinite claims, particularly in dynamic fields such as software.
Fintiv's case underscores the complexity of claim construction in software patents and the necessity for precise phrasing related to functionality.
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