While a highly fact specific inquiry here, in general, an element deployed for a specific purpose need not be directly used for that purpose. For example, a file format “for … display on a personal computer” covers various PC-compatible formats, even if further processing may ultimately be used to carry out the display of such files.
Background / Facts: The patent being asserted here discloses systems for collecting, processing, and delivering billing information from a service provider, such as a telephone company, to a customer, in a format appropriate for a personal computer. Among other features, the claims recite organizing summary reports “into a format for … display on a personal computer.” The accused devices generate summary report data in the form of text (.TXT) files, but further processing by a different system (using .FMT files) is performed to format the .TXT files before they are actually displayed on a PC.
Issue(s): Whether.TXT files can nevertheless meet the limitation of “a format for … display on a personal computer” by being in a format that at least allows them to be displayed on a PC.
Holding(s): Yes. At least at the summary judgment phase, the court agreed with the patentee that “the claims require only that the summary reports be in a PC-compatible format,” and that the accused device may “meet[] the ‘format for … display’ limitation because .TXT files contain PC-compatible ASCII text.” Although the accused devices use it, additional formatting using .FMT files may not necessarily be required to display a .TXT file on a PC. “Centillion created a genuine issue of material fact regarding whether Qwest’s eBC system meets the ‘format … for display limitation’ because a trier of fact may find that it organizes summary reports into a format for display, i.e., a .TXT file.”