Law360, New York ( May 22, 2015, 10:33 AM EDT) -- On May 6, 2015, the Court of Appeals for the Federal Circuit issued its decision in EON Corp. IP Holdings LLC v. AT&T Mobility LLC, No. 2014-1393, clarifying that for meeting the definiteness requirement of claims, a general purpose computer can provide sufficient structure for software-implemented means-plus-function claim elements only in very limited circumstances. As such, the court maintained its well-established rule from WMS Gaming "that the corresponding structure for a function performed by a software algorithm is the algorithm itself."[1] In doing so, the Federal Circuit took a narrow view of its decision from In re Katz Interactive Call Processing Patent Litigation, which held that a standard microprocessor can serve as sufficient structure for "functions [that] can be achieved by any general purpose computer without special programming."[2] That is, unless a claim limitation in means-plus-function form claims the most basic functions of a computer — such as storing, receiving or processing data — the specification must disclose an algorithm that implements the function. Even though means-plus-function claims are not as prevalent as they were at the turn of the century, patent applicants in the software industry could benefit from a resurgence in the claim format....