Means-plus-function claiming has been disfavored (by and large) since at least 1994 when the Federal Circuit handed down its decision in In re Donaldson, where the Federal Circuit sitting en banc ...

Addressing the question of what corresponding structure must be disclosed to support a means-plus-function claim element, the U.S. Court of Appeals for the Federal Circuit upheld a district court ...

A long line of Federal Circuit precedent holds that a function in a software claim under 35 U.S.C. 112, sixth paragraph, must refer to a corresponding “algorithm” in the specification. Absence of an ...