Thursday, January 27, 2022

CAFC reverses ND Cal in Nature Simulation. Indefiniteness not found.

Nature Simulation Systems, Inc. (“NSS”) is the owner of United States Patents No. 10,120,961 (“the ’961 patent”) and No. 10,109,105 (“the ’105 patent”), both entitled “Method for Immediate Boolean Operations Using Geometric Facets.” The patents relate to methods of packaging computer-aided data for three-dimensional objects.1 NSS brought suit for infringement against Autodesk, Inc. in the United States District Court for the Northern District of California. At issue are claims 1 and 8 of the ’961 patent and claim 1 of the ’105 patent. The district court held a claim construction (Markman) hearing, and ruled the claims invalid on the ground of claim indefiniteness, 35 U.S.C. § 112(b).2 That decision is the subject of this appeal. We conclude that the district court erred on the legal standard for claim indefiniteness, and that on the correct standard the claims are not indefinite. The decision of invalidity on this ground is reversed.

The subject matter herein is an improvement on the known Watson and Delaunay methods, and partakes of known usages for established technologies. Precedent teaches that when “the general approach was sufficiently well established in the art and referenced in the patent” this “render[ed] the claims not indefinite.” Presidio Components, Inc. v. Am. Tech. Ceramics Corp., 875 F.3d 1369, 1377 (Fed. Cir. 2017). The situation here is analogous, for the 1981 Watson method and the Delaunay method were known in the art. It is not disputed that the specification describes and enables practice of the claimed method, including the best mode. The claims, as amended during prosecution, were held by the examiner to distinguish the claimed method from the prior art and to define the scope of the patented subject matter. The district court made no contrary findings. Indefiniteness under 35 U.S.C. § 112 was not established as a matter of law.


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