Dyfan, LLC v. Target Corp., No. 21-1725 (Fed. Cir. 2022)
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The patents-in-suit, titled “System for Location-Based Triggers for Mobile Devices,” describe improved systems for delivering messages to users based on their locations. The shared specification discloses a communications system that provides users with information tailored to their particular interests or needs based on their presence within a specified location, such as a shopping center that has different retail stores within it. The district court held the claims invalid as indefinite under 35 U.S.C. 112 based on its view that certain claim limitations are in means-plus-function format and that the specification does not disclose sufficient structure corresponding to the recited functions.
The Federal Circuit reversed, holding that the “code”/“application” limitations are not written in means-plus-function format because they would have connoted sufficiently definite structure to persons of ordinary skill in the art.
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