Williamson v. Citrix Online, LLC

792 F.3d 1339 (2015)

Purchase the Printed Copy at bsmsphd.com

Nature of the Case

To access this section all you need to do is click here and register.

Facts

The '840 patent describes methods and systems for 'distributed learning' that utilize industry-standard computer hardware and software linked by a network to provide a classroom or auditorium-like metaphor-i.e., a 'virtual classroom' environment. There are three main components of the distributed learning' system: (1) a presenter computer, (2) audience member computers, and (3) a distributed learning server. The distributed learning server implements a 'virtual classroom' over a computer network to facilitate communication and interaction among the presenter and audience members. The presenter computer is used to communicate with the audience members and control information that appears on the audience member's computer screen. An audience member's computer is used to display the presentation and can be used to communicate with the presenter and other audience members. P accused Citrix (Ds) of infringing the '840 patent. The district court issued a claim construction order, construing the following limitations of independent claims 1 and 17: 'graphical display representative of a classroom' and 'first graphical display comprising . . . a classroom region' (collectively, the 'graphical display' limitations). The court held that these terms require 'a pictorial map illustrating an at least partially virtual space in which participants can interact, and that identifies The court concluded that the limitation of claim 8, 'distributed learning control module,' was a means-plus-function term under §112, para. 6. The court concluded that it failed to disclose the necessary algorithms for performing all of the claimed functions. The district court thus held claim 8 and its dependent claims 9-16 invalid as indefinite under §112, para. 2. P appeals from the stipulated entry of judgment, challenging the claim construction rulings. P asserts that the district court erred in its construction of the graphical display terms by improperly importing an extraneous 'pictorial map' limitation into the claim.