In Intellectual Ventures I LLC v. Canon Inc., et al., C.A. No. 11-792-SLR (D. Del. Apr. 10, 2014), Judge Sue L. Robinson construed a number of claim terms across six patents:
“Selecting for magnification a selected region of an original image in the graphical user interface”
“Logical operators to provide different blending/merging effects”
“Means for displaying a composite image … further wherein individual pixels of the means for displaying can be dedicated simultaneously to both the main image and the representation of at least one input zone”
“Enhancement layer having a doping concentration that is less than the first doping concentration”
“A silicide layer on a portion of the image sensor wherein an area overlying the pinned photodiode is devoid of the silicide layer”
“A field stop layer being formed beneath the field area and being wider than the field area in a direction towards the active area”
“A channel area having a bottle-neck structure connecting to the photodiode area and the floating diffusion area”
“Multi-layer interlayer insulating films … stacked in at least two layers of oxide film having different density and the refractive index so that the density and the refractive index of the upper interlayer insulating film becomes lower than that of the lower interlayer insulating film as the multilayer interlayer insulating films proceed upward”
“A light shield layer and an element protecting film sequentially stacked on the multi-layer interlayer insulating film”
“Wherein the density of the oxide films becomes higher in the order of PE-CVD<HDP-CVD<LP-CVD<thermal oxidations”
In its Order, the Court also held that certain claims of U.S. Patent No. 6,121,960 were invalid under Section 112. As to the claim term “clear space around a blended area to highlight the area of blending,” the Court found its claim was invalid as lacking written description and as indefinite. See id. at 3-4. The “clear space” limitation only appeared in the claim itself; the portion of the specification identified by plaintiffs in support did not indicate the meaning of this term.
The Court also found other claims of this patent invalid due to the indefiniteness of means-plus-function terms “a computing device for providing a main image” and “means for computing, the means for computing providing a main image.” See id. at 4-9.