"Gramm v. Deere & Company, No. 2024-1598 (Fed. Cir. Mar. 11, 2026), involves neither obviousness nor the Graham factors. Instead, it offers an illustration of means-plus-function claiming under § 112(f) and the doctrinal hazards."
Gramm v. Deere & Company, a Federal Circuit case decided in 2026, addresses means-plus-function claiming under 35 U.S.C. § 112(f). Despite its similarity to the landmark Graham v. John Deere Co. case from 1966, this case does not involve obviousness or Graham factors. Instead, it focuses on the doctrinal hazards associated with means-plus-function claims. A unanimous Federal Circuit panel, led by Judge Reyna and joined by Judges Lourie and Cunningham, reversed the district court's indefiniteness determination and remanded the case for further proceedings, providing important guidance on means-plus-function claiming requirements.
#means-plus-function-claiming #35-usc--112f #federal-circuit #patent-indefiniteness #claim-construction
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