Coolsavings.com wins in Catalina Marketing case

Catalina alleged infringement of claims of US 4,674,041 by coolsavings.com. In this second visit to the Federal Circuit (Catalina-I is 289 F3d 801 (CAFC 2002)), four claim terms were at issue. The Federal Circuit sustained the district court's interpretation and Catalina lost.

Two of the terms at issue were means plus function terms, and the (unpublished) decision illustrates how such claiming can be problematic when few structures are recited in the specification.