In This Issue:

• Indexing Not Required for Online Prior Art Publication

• Claim Indefinite for Not Disclosing Any Structure

• Aluminum Not Inherently Disclosed

- Excerpt from Claim Indexing Not Required for Online Prior Art Publication:

In Voter Verified, Inc. v. Premier Election Solutions, Inc., Appeal No. 2011 1553, the Federal Circuit affirmed the district court’s summary judgment of noninfringement and invalidity.

Voter Verified asserted a patent related to automated systems and methods for voting in an election. The patent disclosed a self-verification procedure by which machine and human error could be detected and corrected before tabulation. The district court held that the system claims were not infringed and not invalid and that the method claims were invalid. Voter Verified appealed and defendants cross-appealed as to the validity of the surviving claims...