Aristocrat Technologies Australia Pty Ltd. v. International Game Technology case brief

Aristocrat Technologies Australia Pty Ltd. v. International Game Technology case brief summary
521 F.3d 1328 (2008)

CASE SYNOPSIS

Plaintiffs, a company that owned U.S. Patent No. 6,093,102 ('102 patent) and its exclusive licensee, sued defendants, companies that manufactured and sold gaming products, alleging patent infringement. On summary judgment, the United States District Court for the District of Nevada found that the '102 patent was invalid for indefiniteness. The owner and the licensee appealed.

CASE FACTS
The owner submitted an application for a patent on an electronic slot machine that purportedly increased player interest by providing players with greater control over the definition of winning opportunities, and it received the '102 patent on that machine. The owner licensed the patent to another company and joined the other company in suing two companies that manufactured and sold gaming products, alleging patent infringement. The district court found that the '102 patent was invalid because the patent's claims lacked a specific algorithm or a step-by-step process for performing the claimed functions of controlling images on the slot machine's video screen.

DISCUSSION

• The court of appeals affirmed. 
• The patent did not disclose the required algorithm or algorithms the machine used to function, and a person of ordinary skill in the art would not have recognized the patent as disclosing any algorithm. 
• The owner did not dispute the fact that all of the claims it made were connected, and the patent was indefinite under 35 U.S.C.S. § 112, para. 2 because the means-plus-function limitations of claim 1 lacked sufficient disclosure of a structure under § 112, para. 6.

CONCLUSION

The court of appeals affirmed the district court's judgment.

Suggested Study Aids and Books