Federal Circuit Invalidates Claims under 112, 2nd paragraph

Late last week, the U.S. Court of Appeals for the Federal Circuit rendered the attached decision in the case of Advanced Ground Information Systems v. Life360, Inc. (I have highlighted relevant passages in the attached). In this case, the Federal Circuit upheld a district court’s determination that certain claims of the asserted patents were invalid under 35 U.S.C. § 112, second paragraph (now 35 U.S.C. § 112(b)) because the specification did not disclose sufficient structure (e.g., an algorithm) for performing the claimed function.

Specifically, the claims at issue recited a “symbol generator.” The Court determined that this feature was a functional term, and as a functional term was to be…

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