Claims Defining System with Particular Capabilities or Function Did Not Render Patent Claim Indefinite

In Mastermine v. Microsoft, the Federal Circuit overturned a district court decision, which found patent claim indefiniteness. Specifically, the patent at issue claimed a system and methods “that allow a user to easily mine and report data maintained by a customer relationship management (CRM) application” by automatically creating an electronic worksheet that included a pivot table. The district court held that the claims were improperly directed to both an apparatus and a method, and as such were indefinite. The Federal Circuit disagreed…

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