Precedential and Key Federal Circuit Opinions
1. GRAMM v. DEERE & COMPANY [OPINION] (2024‑1598, 03/11/2026) (Lourie, Reyna, Cunningham)
Reyna, J. The Court reversed the district court’s judgment that the asserted claims of U.S. Patent No. 6,202,395 are indefinite and remanded for further proceedings. The patent is directed to an “apparatus for maintaining the header of a crop harvester,” and the dispute centered on a means‑plus‑function limitation reciting “control means.”
The parties agreed that “control means” invokes § 112(f), that the claimed function is “raising and lowering the header . . . a designated height above the soil,” and that the corresponding structure in the specification was the combined disclosure of “controller interface 18,” “head controller 20,” and “hydraulic control system 38.” The primary dispute between the parties was whether the disclosure of “head controller 20” was sufficiently definite, with defendant arguing that it was not because the specification only disclosed “head controller 20” as a conventional “computer or processor” without a disclosure of the “algorithm by which the computer or processor works to accomplish the claimed function.” Agreeing with the defendant, the district court held the claim indefinite because the specification did not disclose an algorithm as part of the structure associated with “control means.” In reaching that conclusion, the district court excluded a commercially available controller (Dial‑A‑Matic Version #1) as corresponding structure because it lacked certain aspects of the function disclosed in the specification.
Although the Court held that the district court recited the proper two-step means-plus-function analysis and did not err in its determination of the claimed function, it held that the district court erred by importing an unclaimed function into the corresponding‑structure analysis. The specification’s disclosure that the controller could also perform the additional unclaimed function of controlling lateral position did not disqualify a structure that performs the claimed function of height control. Because Dial‑A‑Matic Version #1—concededly commercially available as of the priority date—performed the claimed function, it should have been considered in the identification of corresponding structure. Dial‑A‑Matic Version #1 used logic circuitry rather than a microprocessor, so it was “not a general-purpose computer” and thus no algorithm disclosure was required. By contrast, the Court determined that the district court did not clearly err by finding that Dial‑A‑Matic Versions #2 and #3, which used microprocessors to control header height, required an algorithm that the patent did not disclose.
Accordingly, the Court reversed the indefiniteness finding and remanded for further proceedings.
2. THE TRUSTEES OF COLUMBIA UNIVERSITY IN THE CITY OF NEW YORK v. GEN DIGITAL INC. [OPINION] (2024‑1243, 03/11/2026) (Dyk, Prost, Reyna)
Dyk, J. The Court reversed in part, vacated in part, and remanded the district court’s judgment arising from a jury verdict of infringement and willfulness concerning U.S. Patent Nos. 8,601,322 and 8,074,115, which are directed toward “[m]ethods, media, and systems for detecting anomalous program executions.” Specifically, the Court reversed the district court’s finding that the claims were not directed to an abstract idea and remanded for further proceedings as to step two of the Alice analysis. In the event that the district court were to find that the claims were valid, the Court upheld the denial of JMOL by the district court on the issues of infringement and willfulness, and reversed the denial of JMOL on damages resulting from foreign sales.
On patent eligibility, at Alice step one, the Court held that the asserted claims are directed to the abstract idea of comparing data against a model (created using different computers) to determine if it is anomalous. The Court rejected plaintiff’s reliance on the use of selective emulation, diversified models, and distributed sensors that were described in the specification, explaining that the claims themselves do not recite these requirements. At Alice step two, in response to the plaintiff’s argument that the claimed “model of function calls” feature could supply an inventive concept, the Court noted that it was reviewing an action by the district court at the pleadings stage and that the parties’ dispute over whether “model of function calls” was conventional is a question of fact that precludes judgment on the pleadings. The Court thus remanded for the district court to consider, at step two, the question of whether the claimed model of function calls feature was conventional.In the interest of judicial efficiency, the Court also addressed other issues that may be relevant on remand if the patent claims were determined to be patent eligible. It affirmed the district court’s construction of “emulator” as not requiring simulation and upheld the jury’s infringement and willfulness findings. However, the Court determined that the district court erred in denying JMOL of no damages for products sold to foreign customers that were made outside the United States. The Court explained that software copies installed abroad are not “made in” or “distributed from” the United States under § 271(a), consistent with the Supreme Court’s prior opinion in Microsoft Corp. v. AT&T Corp., 550 U.S. 437 (2006). The Court also vacated the district court’s award of enhanced damages and attorneys’ fees because the district court relied in part on a contempt finding that was reversed in a companion opinion that was decided on the same day. With respect to the enhanced damages award, the Court also found that the district court erred by limiting its analysis of the closeness of the case to the case as submitted to the jury and by failing to address whether the legal defenses raised by the defendant presented close questions even if they were unsuccessful.
3. APPLE INC. v. INTERNATIONAL TRADE COMMISSION [OPINION] (2024‑1285, 03/19/2026) (Lourie, Reyna, Stark)*
Stark, J. The Court affirmed the International Trade Commission’s determination that the respondent violated § 337 of the Tariff Act by importing products that infringed the complainant’s patents, and it upheld the Commission’s issuance of a limited exclusion order.
The Court rejected the respondent’s challenge to the Commission’s domestic industry finding. On the technical prong, the Court held that the domestic industry product identified by the complainant was not a “hypothetical” article and could be credited as the patent-practicing article. The Court determined that “the ALJ and the Commission appropriately treated the” complainant’s identified product “as the domestic industry article and viewed the CAD drawings contained in the complaint and the physical prototypes [complainant] produced in discovery as successive embodiments of that same article.” The Court further held that circumstantial evidence is a valid basis for establishing the existence of a patent‑practicing article at the time of the complaint. The Court also concluded that substantial evidence supported the Commission’s finding that, at the time of the complaint, the domestic industry product identified by the complainant met certain challenged limitations of the asserted claims. On the economic industry prong, the Court determined that the Commission committed no error in finding that the complainant’s “investment in an earlier generation prototype of a patent-practicing article” could be considered where “those investments led to specifically tailored, significant technical features of patent-practicing articles.”
The Court also affirmed the Commission’s infringement determinations, agreeing with the ALJ’s claim constructions of terms such as “over”/“above,” and “openings”/“through holes.” The Court upheld the Commission’s findings on written description and obviousness, concluding that they were supported by substantial evidence. Finally, the Court affirmed the Commission’s finding that prosecution laches does not bar the complainant from enforcing its patents.
