By: Mel R. Quintos

We explore how, both in form and in substance, the U.S. Court of Appeals for the Federal Circuit treats functional language in patent claims. The case at issue is Williamson v. Citrix Online, LLC, decided on June 16, 2015, Williamson being the party having an interest in enforcing U.S. Patent No. 6,155,840 (hereinafter, “the ‘840 patent”). The ‘840 patent is directed to methods and systems for “distributed learning” that use standard computer hardware and software linked by a network to simulate a “virtual classroom” environment to connect one or more classroom presenters with a geographically remote audience.

Facts

The relevant set of claims in the ‘840 patent includes claims 8-12, claim 8 being an independent claim. Independent claim 8, in pertinent part, recites:—click here to read more—