Rain Computing, Inc. v. Samsung Electronics Co., Ltd., No. 20-1646 (Fed. Cir. 2021)Annotate this Case
Rain sued Samsung for infringement of claims of the 349 patent, which is directed to delivering software application packages to a client terminal in a network based on user demands. The claimed invention purports to deliver these packages more efficiently by using an operating system in a client terminal rather than a web browser. The district court found the patent not infringed and not indefinite.
The Federal Circuit reversed as to indefiniteness, 35 U.S.C. 112. The term “user identification module” fails to provide any structure for performing the claimed functions, has no commonly understood meaning, and is not generally viewed by one skilled in the art to connote a particular structure. The term is a means-plus-function term subject to section 112; the function of “user identification module” is “to control access to one or more software application packages to which the user has a subscription,” but nothing in the claim language or the written description provides an algorithm to achieve the “control access” function of the “user identification module.”