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Rain Computers sued Samsung last year claiming the Korean tech giant infringed its app store patent (US patent number 9,805,349), which details a method of delivering apps to devices from a web store.
The United States District Court of Massachusetts ruled on February 12, 2020, that the Rain Computers patent was not indefinite, but also ruled that Samsung did not infringe. This prompted Rain to appeal the case with the Federal Circuit.
At the appeals court, Samsung argued against the district court’s decision that the claim was not indefinite, citing that a key phrase in the Rain patent—“user identification module”—rendered the claim indefinite.
The appeal board concluded in a precedential ruling: “Because we hold ‘user identification module’ renders the asserted claims indefinite, we reverse the district court’s judgment that the asserted claims of the ’349 patent are not invalid as indefinite and dismiss Rain’s appeal as moot.”
“User identification module” was found to be a “means-plus-function term”, which describes a technical feature in general language, relying on the patent specification to describe the function.
Rain argued that an amendment to the patent during the prosecution, which changed the wording from “a user identification module for accessing” to “a user identification module configured to control access of”, prevented “user identification module” from being a means-plus-function term.
As the three judges could not identify the relevant function in the specification, the district court decision was reversed.
The ruling comes off the back of a similar federal circuit decision in Synchronoss Techs v Dropbox, decided on February 12, which also ruled “user identifier module” as a means-plus-function term that did not correspond to any structure found within the specification.
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Samsung, Rain Computers, Federal Circuit, Dropbox, Synchronoss Techs