RAIN COMPUTING, INC. v. SAMSUNG ELECTRONICS AMERICA, INC.

RAIN COMPUTING, INC. v. SAMSUNG ELECTRONICS AMERICA, INC., Appeal Nos. 2020-1646, -1656 (Fed. Cir. March 2, 2021).  Before Lourie, Dyk and Moore.  Appealed from D. Mass. (Judge Stearns).  (Means-Plus-Function)

Background:

Rain sued Samsung for infringing the claims of its patent directed to delivering apps to client terminals using web-based app stores.  The patent discloses using a user identification device, such as an IC card, provided to the user’s electronic device to authenticate the user and control the user’s access to the apps.

The district court construed the claim term “user identification module” as as a means-plus-function element but found the term to be sufficiently definite and thus valid due to the patent disclosing computer-readable media such as the IC card.  At the same time, the district court determined Samsung did not infringe any of the claims.  Rain then appealed the determination of noninfringement, and Samsung cross-appealed the determination of validity.

Issue/Holding:

Did the district court err in holding that the term “user identification module” is not indefinite? (continue reading)

Summary by:  Graham Nelson

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