The court reversed the District Court’s construction of the claim term “graphical display representative of a classroom” as requiring “a pictorial map,” because neither the claim nor the specification required such a “map” and the references in the specification to such a “map” were merely a preferred embodiment. The court also reversed the District Court’s holding that the term “distributed learning control mechanism” was a means-plus-function term under 35 U.S.C. 112(6), because the term “module,” which has a dictionary meaning connoting structure, is sufficient to overcome the presumption that means-plus-functions rules do not apply. The dissent believes that, as to the “classroom” term, the specification and prosecution history do require a “pictorial map,” and, as to the “module” term, a “module” is insufficient structure to keep the term outside of means-plus-function construction.
Williamson v. Citrix Online, LLC, Case No. 2013-1130 (November 5, 2014); Opinion By: Linn, joined by Moore; Reyna, dissenting; Appealed From: Central District of California, Matz, J.
The opinion can be found here.
