Bancorp Services, L.L.C., v. Hartford Life Insurance Company, et al.
Federal Circuit
March 1, 2004
U.S. Patent No. 5,926,792, the ’792 patent describes a system for administering and tracking the value of life insurance policies in separate accounts. The kinds of life insurance policies that are subject to the system claimed by the patent include separate account policies issued pursuant to Corporate Owned Life Insurance (“COLIâ€) and Bank Owned Life Insurance (“BOLIâ€) plans. The ’792 patent provides a system for administering variable life insurance policies, including those containing stable value protected investments. The patent provides a computerized means for tracking the book value and market value of the policies and calculating the credits representing the amount the stable value protected writer must guarantee and pay should the policy be paid out prematurely.
The trial court held all the independent claims of the ’792 patent invalid for indefiniteness because each of those claims used the term “surrender value protected investment credits,†which the court held was fatally indefinite (35 U.S.C. § 112, 2). The district court noted that the term “surrender value protected investment credits†was not defined in the patent, and after considering both the text of the patent and the extrinsic evidence proffered by the parties, the district court found the term to be so unclear in meaning as to render the patent claims invalid.
Federal Circuit concluded that the patent is not indefinite (the meaning of the term “surrender value protected investment credits†is reasonably discernible and that the asserted claims of the ’792 patent are therefore not invalid for indefiniteness…the components of the term have well-recognized meanings, which allow the reader to infer the meaning of the entire phrase with reasonable confidence), reversed the district court’s judgment and remanded for further proceedings.
Related posts:
