Ibormeith IP, LLC v. Mercedes-Benz USA, No. 13-1007 (Fed. Cir. 2013)
Annotate this CaseThe Ibormeith patent, entitled “Sleepiness Detection for Vehicle Driver or Machine Operator,” concerns the monitoring a vehicle driver’s sleepiness and issuing a warning to the driver. The monitor disclosed in the patent may take into account factors including natural body-clock (circadian) rhythm, the magnitude and number of corrective steering actions the driver takes, cabin temperature, monotony of the road, and how long the driver has been driving. Some factors involve actions or conditions at the moment, like steering and light conditions, which are measured by sensors in the vehicle. Others involve general or driver-specific background information, such as circadian rhythm or a driver’s recent sleep patterns and alcohol consumption, which must be input by other means (the programmer or driver). The factors are weighted, according to contributory importance, and combined in a computational decision algorithm or model, to provide a warning indication of sleepiness. The claims at issue contain a “computational means” element that is subject to 35 U.S.C. 112(f). Ibormeith sued Mercedes for infringement. Mercedes argued that the means-plus-function “computational means” limitations in two independent claims were indefinite. The district court entered summary judgment in favor of Mercedes. The Federal Circuit affirmed, noting that the specification does not contain an algorithm that adequately provides structure for the claimed functions.
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