Southwestern Bell Telephone v. Collins (07-1577)
Collins is the owner of U.S. Patent No. 4,701,907. Southwestern Bell filed for a declaratory judgment of noninfringement and invalidity regarding the patent. As a result, the patent was found invalid by the district court because the claim term “means for measuring” could not be construed.
On appeal, the Federal Circuit agreed with the district court because Collins failed to provide a clear link or association between the “means for measuring” claim language and any corresponding structure in the patent specification. As previously stated several times by the Federal Circuit, when no structure in the specification is linked to the function in a means-plus-function claim element, that claim is indefinite.