Can the Term “Receiver” be a Means-Plus-Function Claim Element?
Posted in Patents

It can sometimes be difficult to determine whether or not a certain term in a claim will be considered a means-plus-function claim element when the term is not in the typical “means for” format. The Federal Circuit recently provided some guidance related to making this determination in EnOcean GMBH v. Face Int’l Corp., where the term “receiver” was ruled to not constitute a means-plus-function claim element. 

Although the same claim terms can be interpreted differently in different patents due to, for example, differences in detail provided in the specification, EnOcean nevertheless provides patent practitioners with helpful guidance with respect to the commonly used term “receiver” as well as an informative review of means-plus-function analysis for claims lacking the typical “means for” language.

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