Federal Circuit Affirms Noninfringement Where Expert's Analysis Of Means-Plus-Function Claim Failed To Account For Disclosed Structure

In Genuine Enabling Technology LLC v. Sony Group Corp., No. 24-1686 (Fed. Cir. Feb. 19, 2026), the Federal Circuit affirmed summary judgment of noninfringement, emphasizing that patentees' infringement analysis for means-plus-function claims must account for the disclosed structures.

Genuine Enabling Technology (“GET”) alleged that Sony's PlayStation controllers and consoles infringed a patent for combining multiple input data streams. The dispute centered on a means-plus-function term reciting “encoding means for synchronizing” multiple signals into a combined data stream. Although the specification disclosed a logic block containing multiple components that corresponded to this function, GET's initial expert report identified only three components to achieve the claimed synchronization function. At the Daubert hearing, GET argued that the expert's position was even narrower and that synchronization was achieved solely through a bit-rate clock signal. The district court excluded GET's expert's testimony for failing to adequately account for the additional components and granted Sony's motion for summary judgment of noninfringement based on insufficient evidence.

The Federal Circuit affirmed, explaining that GET failed to account for several components of the disclosed structure or explain why they could be disregarded. Without such analysis, GET could not establish that the accused products performed the claimed function in substantially the same way with equivalent structures. 

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