MasterMine Software, Inc. v. Microsoft Corp.
874 F.3d 1307 (Fed. Cir. 2017)
Authored by Amanda Irwin
Statement of Facts: MasterMine Software Inc. (“MasterMine”) brought a patent infringement action alleging Microsoft Corporation infringed two of its related patents, U.S. Patent Nos. 7,945,850 (“the ’850 patent”) and 8,429,518 (“the ’518 patent”). These patents describe a process by which a user of a customer relationship management (“CRM”) program can automatically generate an electronic worksheet in a spreadsheet application (such as Microsoft Excel). These electronic worksheets, known as pivot tables, “allow[] the user to quickly and easily summarize or view large amounts of CRM data” to mine for important insights in the customer data. 874 F.3d 1307, 1309. Microsoft sought a declaration that claims 8 and 10 of the ’850 patent and claims 1, 2, and 3 of the ’518 patent were invalid for indefiniteness because each claim covered two different classes of patentable subject matter.
Procedural History: The United States District Court for the District of Minnesota held that the term pivot table means “an interactive set of data displayed in rows and columns that can be rotated and filtered to summarize or view the data in different ways” Id. at 1312. Additionally, the district court held MasterMine’s claims 8 and 10 of the ’850 patent and claims 1, 2, and 3 of the ’518 patent were invalid for indefiniteness because they improperly claimed two different subject-matter classes. MasterMine appealed both the claim construction and indefiniteness determinations.
Questions Presented: First, whether the district court correctly defined pivot table. Second, whether the district court properly found the various MasterMine patent claims invalid for indefiniteness.
Holdings: The Federal Circuit affirmed the construction of pivot table but reversed the district court’s indefiniteness determination. The Federal Circuit held that Claims 8 and 10 of the ’850 patent and claims 1, 2, and 3 of the ’518 patent contained proper functional language, and remanded for further proceedings.
Reasoning: First, the Federal Circuit reviewed the claim construction de novo based solely on intrinsic evidence because “[t]he ultimate construction of the claim is a legal question” not a factual one. Id. at 1310. MasterMine argued that the district court improperly construed the term pivot table because the district court’s definition only recognizes tables that contain data and excludes similar devices that are empty or not yet filled. However, the claim language supports the district court’s construction because each time the claim references a pivot table, it refers to the data contained within. Additionally, the specifications in the patent further reinforce the district court’s definition, as they explain the concept and purpose of pivot tables as enabling a user to view and interact with the data gathered from the CRM program. MasterMine’s arguments that portions of the relevant code allow for the production of an empty pivot table were unpersuasive because both sides agree that the code is inoperable on its own. In light of the claim language, specification, and prosecution history, the court concluded that the district court properly construed pivot table.
Next, the court held that the district court had misapplied the precedent of a prior Federal Circuit case IPXL Holdings, LLC v. Amazon.com, Inc. Therefore, claims 8 and 10 of the ’850 patent and claims 1, 2, 3 of the ’518 patent were not invalid for indefiniteness. The Federal Circuit emphasized that since IPXL, it has repeatedly held that “while a claim directed to both a method and an apparatus may be indefinite, apparatus claims are not necessarily indefinite for using functional language.” Id. at 1313. The court distinguished MasterMine from IPXL precedent. Unlike IPXL, MasterMine did not claim to have patented the method for using the software, which would be impermissibly indefinite. Rather, MasterMine merely used permissible functional language to describe the capabilities of the claimed system.
Ultimately, finding all claims valid, the court remanded the case to the district court for additional proceedings.