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Explore the latest in patent, trademark, and copyright cases on the Merchant & Gould LLP blog. Stay informed with expert insights on intellectual property law updates.

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Last week, the U.S. Court of Appeals for the Federal Circuit issued a precedential opinion in <em>Gramm v. Deere &amp; Company</em>, No. 2024-1598 (March 11, 2026), reversing the district court's conclusion that the asserted claims of U.S. Patent No. 6,202,395 are invalid as indefinite and remanding for further proceedings.

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Richard Gramm invented and patented an apparatus for maintaining the header of a crop harvester at a designated height above the ground as the harvester traverses a field. Gramm and his exclusive licensee, Reaper Solutions, LLC, sued Deere for patent infringement. The parties agreed that the claim term "control means" is a means-plus-function limitation and that the claimed function is "raising and lowering the header . . . a designated height above the soil." The dispute centered on corresponding structure. The parties identified three commercially available head controllers used in Deere combines as of 1997—Dial-A-Matic Versions #1, #2, and #3—but Deere argued that only Versions #2 and #3, which could control both header height and lateral position, qualified as corresponding structure. Because Versions #2 and #3 used microprocessors, Deere argued the specification must disclose an algorithm, and, finding none, the district court held claim 12 indefinite.

The Federal Circuit reversed. The Court held the district court erred by excluding Dial-A-Matic Version #1 from its identification of corresponding structure based on Version #1's inability to control the lateral position of the header—an unclaimed function. Because Version #1 used logic circuitry rather than a microprocessor to raise and lower the header, no algorithm disclosure was required. The Court also found no clear error in the district court's determinations that Versions #2 and #3 trigger the algorithm requirement and that the specification lacks disclosure of an adequate algorithm for those versions to be considered a corresponding structure for the claimed "control means". The Court further rejected Reaper's equivalents argument, clarifying that the equivalents inquiry is an infringement question, not a claim construction question.

CAFC Reverses Indefiniteness Finding for Means-Plus-Function Claim

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