Zeroclick, LLC v. Apple, Inc

Federal Circuit’s recent reversal of the District Court’s invalidation of asserted patents in Zeroclick, LLC v. Apple, Inc potentially improves the strength of software patents and marks an important re-balancing of the Federal Circuit’s earlier decision in Williamson v. Citrix Online by re-emphasizing the presumption that 112(f) does not apply when the term “means” is not used in conjunction with functional language.