The latest example of the danger of drafting software patent claims to include means-plus-function limitations comes from Eon Corp. IP Holdings LLC v. AT&T Mobility LLC, No. 2014-1392 (Fed. Cir. May 6, 2015).
According to the court, the limitations in the claims required “special programming,” and were not simply an extension of the operation of a microprocessor. Because the claimed “means” were not described in the specification, the claims, all governed by 35 U.S.C. § 112, have been held invalid as indefinite.