As lower courts begin to apply the Supreme Court’s reworded standard for indefiniteness as set forth in Nautilus, Inc. v. BioSig Instruments, Inc., they have grappled with the question of where to draw the line between claims that are not indefinite and those that are. In a recent order by Judge Landya McCafferty, the New Hampshire federal district court denied a defendant’s motion for summary judgment of invalidity for indefiniteness, applying the Nautilus standard. The three patents in the case related generally to methods and apparatus for designing complex systems by way of computer aided design. The claims at issue recited a step of “mapping…components of geometrical information to a plurality of standard fittings” as a function of three criteria. In its motion, defendant Autodesk contended that the patent claims were indefinite because “the patent lacks information on what does or does not constitute” the mapping step.
The New Hampshire district court disagreed, finding that the patent specification did teach the reciprocal operation of “assign[ing] standard fittings to geometrical information” that would yield the same results as the recited “mapping” step. The court further noted that “while Autodesk argues that the patents-in-suit do not adequately disclose the boundaries of the claimed invention, it does not point to any spot on the boundary line that is sufficiently blurred that one could cross that boundary without knowing it.”
The case is East Coast Sheet Metal Fabricating Corp. v. Autodesk, Inc., 12-cv-517-LM (D.N.H.).