Richard Gramm, the inventor, and his company Reaper Solutions LLC sued Deere & Company for infringing U.S. Patent No. 6,202,395, which covers an apparatus for maintaining a crop harvester header at a desired height above the ground. Deere challenged the patent's validity through inter partes review, and the dispute eventually reached the district court, which found the patent indefinite and entered judgment for Deere. The district court focused on a specific claim limitation using 'means-plus-function' language, specifically the 'control means' for raising and lowering the header. Deere argued that the patent specification failed to disclose a specific algorithm for the controller because it referenced a 'conventional' head controller that used a microprocessor. The district court agreed, concluding that because the specification did not describe the algorithm, the claim was invalid. Reaper appealed, arguing that the district court incorrectly excluded a commercially available controller that used simple logic circuitry rather than a microprocessor.
The Federal Circuit analyzed the case under the two-step process for means-plus-function claims: identifying the claimed function and then determining the corresponding structure in the specification. The court agreed with the district court on the first step, identifying the function as raising and lowering the header to a designated height. However, the court found clear error in the second step. The district court had excluded a commercially available controller, the Dial-A-Matic Version #1, from the list of corresponding structures because it could not control the lateral position of the header, an unclaimed function. The Federal Circuit held that a specification should not disqualify structure that meets the means clause's requirements simply because it also performs an added function. The court cited precedent stating that a claim is valid even if only one embodiment discloses corresponding structure. Since Dial-A-Matic Version #1 was commercially available and used logic circuitry rather than a microprocessor, it did not trigger the requirement for a disclosed algorithm. The court noted that the algorithm requirement applies only to general-purpose computers or microprocessors. Because the specification disclosed this non-microprocessor structure, the claim was not indefinite. The court also found no error in the district court's finding that other versions of the controller used microprocessors and lacked a disclosed algorithm, but since one valid structure existed, the claim survived.
The decision reverses the invalidity judgment, allowing the patent to proceed. The case is remanded to the district court for further proceedings consistent with the finding that the claims are definite. This ruling clarifies that patentees need not disclose algorithms for every possible commercially available embodiment if at least one embodiment uses non-computerized circuitry to perform the claimed function. It limits the scope of means-plus-function claims to the specific structure disclosed and its equivalents, rather than requiring the structure to perform every function mentioned in the specification.
Podcast (federal-narrative-summaries): Play in new window | Download