Magistrate Judge Mary Pat Thynge recently issued a report recommending the proper construction of claim terms relating to geolocation systems. TruePosition, Inc. v. Polaris Wireless, Inc., C.A. No. 12-646-RGA-MPT (D. Del. Feb. 4, 2014). The following claim terms of U.S. Patent No. 7,783,299 were construed by Judge Thynge:
“means for monitoring” (as used in claim 113 and as used in claim 114);
“means for detecting” (as used in claim 113 and as used in claim 114);
“means for initiating” (as used in claim 113 and as used in claim 114); and
“in response” (as used in each of claims 98, 113, and 114).
Magistrate Judge Thynge found that the ’299 patent “does not disclose an algorithm to perform the “means for detecting” function in claims 113 and 114 and, as a result, recommended that those claims be found invalid as indefinite under 35 U.S.C. § 112, ¶2.