“Disclosure of a class of algorithms that places no limitations on how values are calculated, combined, or weighted is insufficient to make the bounds of the claims understandable [under the definiteness requirement of 35 U.S.C. § 112(b)].” Further, the fact that a variety of such algorithms “may have been known to one of ordinary skill in the art does not rescue the claims” because “[a] bare statement that known techniques or methods can be used does not disclose structure.”
Background / Facts: The patent being asserted here is directed to three-dimensional user communication with a computer via an input device. In this regard, the claims recite use of “integrator means” for integrating acceleration signals over time. The parties agree that the means-plus-function structure corresponding to the “integrator means” is a conventional microprocessor.
Issue(s): Whether the patent’s reference to “numerical integration” constitutes an algorithm for performing the integrating function with enough specificity to render the claims discernible to a person of ordinary skill under the definiteness requirement of 35 U.S.C. § 112(b).
Holding(s): No. “[M]erely using the term ‘numerical integration’ does not disclose an algorithm—i.e., a step-by-step procedure—for performing the claimed function.” Rather, “numerical integration is not an algorithm but is instead an entire class of different possible algorithms used to perform integration” and “[d]isclosing the broad class of ‘numerical integration’ does not limit the scope of the claim to the ‘corresponding structure, material, or acts’ that perform the function, as required by section 112. Indeed, it is hardly more than a restatement of the integrating function itself.”