Immervision, Inc. v. Apple Inc.

Summary

The United States District Court for the District of Delaware adopts a magistrate judge’s report and recommendation and grants Apple Inc.’s renewed motion for judgment on the pleadings. The court holds that asserted patent claim 21 is a single-means claim and is invalid for lack of enablement under 35 U.S.C. § 112. The court overrules Immervision’s objections and denies the parties’ claim construction motions as moot.

Holdings

1. Claim 21 is a single-means claim because, under the parties' positions and the plain claim language, the optical-means limitation is the only actually claimed element; the additional language merely describes characteristics of that element or the lens's output.
2. Because claim 21 is a single-means claim, it is invalid for lack of enablement; a traditional fact-intensive enablement inquiry is unnecessary in this circumstance.
3. Apple's Rule 12(c) motion and briefing did not violate the claim-construction briefing limits or scheduling order, and the motion was properly considered.

Questions Presented

1. Whether claim 21 is a single-means claim under the means-plus-function requirements of 35 U.S.C. § 112.
2. Whether a single-means claim is invalid for lack of enablement without a traditional fact-intensive enablement inquiry.
3. Whether Apple's Rule 12(c) motion and briefing violated the claim-construction briefing limits or scheduling order.

Disposition

other