The court denied defendant's motion for summary judgment that plaintiff's call processing patent was indefinite because it failed to disclose an algorithm. "[T]he Federal Circuit clarified when an algorithm is required for a means plus function limitation (whose corresponding structure is a general purpose processor). The Court said that algorithms are not required when the recited function does not require a special purpose computer. Thus, for simple functions like 'processing,' 'receiving,' and 'storing,' the specification did not need to disclose an algorithm. . . . Here, the recited function is simply receiving a form of data, namely cues."
Ronald A. Katz Technology Licensing L.P. v. Comcast Corporation, et. al., 2-07-cv-06996 (CACD September 29, 2011, Order) (Klausner, J.)