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Judge Robinson grants summary judgment of invalidity.

Judge Sue L. Robinson recently issued a claim construction decision for three patents relating to real-time online transactions. Pi-Net Int’l Inc. v. JPMorgan Chase & Co., C.A. No. 12-282-SLR (D. Del. May 14, 2014). The following claim terms appearing in one or more of U.S. Patents No. 8,108,492, 5,987,500, and 8,037,158 were considered by the Court:

“real-time:”
“value-added network (VAN) switch.” (found to be indefinite)
“switching.” (found to be indefinite)
“service network.” (found to be indefinite)
“transactional services:”
“web transaction:”
“point-of-service application[s]” and “transactional application[s]”
“web application” and “network application”
“said user application”
“back-end transactional application[s],” and “the selected back-end transactional application:”
“object routing:”
“a routed transactional data structure that is both complete and non-deferred, in addition to being specific to the point-of-service application:”
“keeping a transaction flow captive:”
“value-added network service provider:”
“value-added network system:”
“transaction link:”
The Court also construed several means-plus-function claim terms:

“means for switching to a transactional application in response to a user specification from a network application.”
“means for transmitting a transaction request from said transactional application.”
“means for processing said transaction request.”
“computer system executing the back-end transactional application for processing the transaction request in real-time.”
The Court found each of these mean-plus-function claim terms indefinite because the the specification failed to provide sufficient structure or an algorithm to disclose how the function is performed.

In a separate opinion, and as a result of the Court’s rulings on claim construction, the Court granted the defendants’ motion for summary judgment of invalidity for indefiniteness, and also for lack of enablement, and lack of written description.

Pi-Net Int’l Inc. v. JPMorgan Chase & Co., C.A. No. 12-282-SLR (D. Del. May 14, 2014).

Pi-Net Int’l Inc. v. JPMorgan Chase & Co., C.A. No. 12-282-SLR (D. Del. May 14, 2014).

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