Means-Plus-Function Treatment

In Massachusetts Institute of Technology & Electronics for Imaging, Inc. v. Abacus Software, Corel Corp. & Corel Inc., Microsoft Corp., and Roxio, Inc & MGI Software, Inc., the Federal Circuit vacated the district court's grant of summary judgment and remanded for further proceedings. The federal circuit court held that the district court erred in its construction of \'aesthetic correction circuitry,\' and erred in excluding Windows as an infringing product. At issue was U.S. Patent No. 4,500,919 (\'the '919 patent\') which discloses a color processing system for producing copies of color originals. The patent was designed to address a problem common to conventional color editing systems, namely, that \'the exact combination of colorants required for the match is not related, any simple way, to measurements which can be made on the original.\' MIT, the assignee of the '919 patent, granted an exclusive license to EFI. Plaintiffs MIT and EFI filed an amended complaint asserting infringement against 214 defendants. In the course of litigation, plaintiffs settled with some defendants and dismissed their claims against others, until only four remained: Microsoft, Corel, Roxio, and MGI Software. Ultimately, the parties stipulated to entry of final judgment of non-infringement of the '919 patent based on the court's claim construction. MIT appealed. Following a Markman hearing, three claim terms were relevant to the appeal to the Federal Circuit


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