The sufficient structure inquiry focuses on whether the claim recites sufficient structure to perform “the functions in question.” The more generic the function, the more generic the specific structure sufficient to perform it can be. In addition, it should be noted that the Federal Circuit has expressly recognized that “the term ‘digital logic’ designates structure to skilled artisans – namely digital circuits that perform Boolean algebra.”
Background / Facts: The patents here relate to providing security in a data network by nesting encrypted objects into other objects which are also encrypted. This allows a system to employ different security levels to restrict access to specific compartments of data. In this regard, the claims recite several means-plus-function limitations, including “system memory means” and “digital logic means” for performing various functions.
Issue(s): Whether the “system memory means” and the “digital logic means” recite sufficient structure to avoid treatment under § 112, ¶ 6.
Holding(s): Yes. As to the first term, “[a] ‘system memory’ is sufficient structure to perform the ‘storing data’ function. To those skilled in the art, a system memory is a specific structure that stores data.” While the court acknowledged that in a recent case it may have stated that this exact “system memory means” recitation is indeed a means-plus-function limitation, it nevertheless concluded here that “[t]his statement was not a holding; it was expressly dictum and thus not binding.” Moreover, the “system memory means” in the prior case performed a more specific function than simply storing data. “Here, it is beyond question that those of skill in the art would understand that a system memory is sufficient structure to perform the general function of ‘storing data.’” As to the second term, the court stated that “the term ‘digital logic’ designates structure to skilled artisans – namely digital circuits that perform Boolean algebra.” In addition, in this particular instance, “[t]he claim also recites that the digital logic means is comprised of structural elements, including a system memory and specific modules and subsystems. While the defendants assert that those elements are purely generic, we see no reason to hold that those elements are so devoid of structure as to implicate § 112, ¶ 6.”