Williamson v. Citrix Online Does Not Require Reconsideration of Earlier Determination of No Indefiniteness

The court denied defendant's motion for leave to file a motion to reconsider an earlier decision denying defendant's motion for summary judgment of indefiniteness in light of a recent Federal Circuit decision. "[Defendant] points the court to the Federal Circuit’s recent decision in [Williamson v. Citrix Online, LLC, Case No. 2013-1130 (Fed. Cir. June 16, 2015) (en banc)] which overruled [Lighting World Inc. v. Birchwood Lighting, 382 F.3d 1354 (Fed. Cir. 2004)] and changed the presumptions that apply to means-plus-function claims. That is well and good. But the court denied the motion for summary judgment at-issue in light of its claim construction, where the court determined that the plain and ordinary meaning applies to the term 'data tracker.' Because the court had already decided that the term 'data tracker' was not indefinite, it denied the motion for summary judgment on that basis, rather than on the merits of Lighting World."

Good Technology Corporation et al v. MobileIron, Inc., 5-12-cv-05826 (CAND July 6, 2015, Order) (Grewal, M.J.)