CAFC Reverses Judgment of Indefiniteness in Crop Harvester Patent Dispute

"The court determined that the district court improperly restricted the corresponding structure of a means-plus-function claim limitation to a structure that was not necessary to perform the recited function. The court also held that no algorithm disclosure was required, since an older version of the accused structure used logic circuitry rather than a microprocessor."

"Both sides agreed that the term is a means-plus-function limitation invoking 35 U.S.C. § 112(f). They also agreed that the claimed function is to raise and lower the header by a designated height above the soil. Furthermore, the sides agreed that the corresponding structure described in the specification includes a "controller interface 18," "head controller 20," and "hydraulic control system 38" in combination."

The Federal Circuit reversed a district court's invalidity judgment in a patent case involving crop harvester header control technology. The dispute centered on a means-plus-function claim limitation for "control means" in U.S. Patent No. 6,202,395. The court ruled that the district court improperly restricted the corresponding structure to only structures necessary for the recited function. The patent specification disclosed a controller interface, head controller, and hydraulic control system as the corresponding structure. The court determined that no algorithm disclosure was required since an older version of the accused structure used logic circuitry rather than a microprocessor, establishing that multiple structural implementations can satisfy the same functional requirement.

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