Mastermine Software, Inc. v. Microsoft Corp., No. 16-2465 (Fed. Cir. 2017)
Annotate this CaseMastermine’s patents disclose methods and systems “that allow[] a user to easily mine and report data maintained by a customer relationship management (CRM) application” and describe a process by which an electronic worksheet is automatically created. Within this electronic worksheet, a multi-dimensional analysis table, known as a pivot table, “allows the user to quickly and easily summarize[] or view large amounts of CRM data.” The patents further describe that a user is able to “analyze the captured CRM data and ‘mine’ the data for important insights” upon generation of the pivot table. In Mastermine’s infringement suit against Microsoft, the district court construed the term “pivot table” to mean “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” and entered a stipulated judgment of noninfringement and invalidity for indefiniteness. The Federal Circuit reversed and remanded as to indefiniteness. The claims do not improperly claim both an apparatus and a method of using the apparatus. The court found the district court’s claim construction supported by the intrinsic evidence.
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