Williamson v. Citrix Online, LLC, No. 13-1130 (Fed. Cir. 2015)
Annotate this CaseWilliamson's patent describes methods and systems for “distributed learning” that utilize standard computer hardware and software linked by a network to provide a virtual classroom. The system includes a presenter computer that controls information that appears on the audience member’s computer screen, audience computers that display the presentation and can communicate with the presenter and other audience members, and a distributed learning server that implements a “virtual classroom” over a network, such as the Internet. Williamson asserted infringement based on defendants’ alleged manufacture, sale, use, and importation of systems and methods of online collaboration. The district court construed “graphical display representative of a classroom” and “first graphical display comprising . . . a classroom region” as requiring “a pictorial map illustrating an at least partially virtual space in which participants can interact, and that identifies the presenter(s) and the audience member(s) by their locations on the map.” The court concluded that the limitation, “distributed learning control module,” was a means-plus-function term under 35 U.S.C. 112(6) and that the specification failed to disclose necessary algorithms for performing all claimed functions, so that claims were invalid as indefinite. The Federal Circuit vacated. On rehearing, en banc, the court again vacated the judgment of non-infringement of certain claims, but found that the court correctly construed the limitation “distributed learning control module,” and affirmed the judgment of invalidity of other claim and remanded.
This opinion or order relates to an opinion or order originally issued on November 5, 2014.
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