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Chief Judge Sleet construes terms in “camera-on-a-chip” patents

Chief Judge Sleet construed the following terms relating to several “camera-on-a-chip” patents in a recent Order in Sirona Dental Systems, Inc., et al. v. Danaher Corp., et al., C.A. No. 10-288 (GMS) (D. Del. Jan. 26, 2012):

“readout circuit”
“a photoreceptor”
“sensing node”
“signal controlling device”
“timing circuit”
“correlated double sampling”
“single chip camera device”
“control portion”
“noise reduction circuit”
“fixed pattern noise reduction circuits”
“a follower transistor, receiving information from said photoreceptor indicative of said light”
“a select transistor, selecting said each pixel cell for readout”
“associated device, associate[d] with processing said light from said photoreceptors”
“formed in substrate adjacent said plurality of pixel[] cells”
“image processing device”
The Court agreed with the defendant’s contention that “associated device, associate[d] with processing said light from said photoreceptors” was a means-plus-function term, despite the absence of the words “means for,” explaining that “here, the term ‘associated’ which modifies ‘device,’ is not defined in the specification and there is no suggestion that it has a generally understood meaning in the art. Therefore, the court finds that ‘associated device’ does not connote sufficient structure to a person of ordinary skill in the art ot avoid § 112 treatment.” Id. at 7-8 n.30. The Court rejected the defendant’s contention that “image processing device” also was a means-plus-function term, explaining “[a]lthough this term uses the word ‘device,’ the additional words ‘image processing’ add sufficient structure to overcome the presumption that § 112 applies. The claim makes clear that the image processing device is a particular type of device that connotes sufficient structure to a person of ordinary skill in the art.” Id. at 8 n.31.


Sirona Dental Systems, Inc. et al. v. Danaher Corp., et al., C.A. No. 10-288 (GMS) (D. Del. Jan. 26, 2012).

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