Federal Circuit Affirms Summary Judgment Of Non Infringement For Failure To Prove Structural Equivalence Under § 112(f)

On February 19, 2026, the U.S. Court of Appeals for the Federal Circuit affirmed the District of Delaware’s grant of summary judgment of non infringement in favor of defendants in Genuine Enabling Tech. LLC v. Sony Corp., No. 17-CV-135, 2024 WL 1255513 (D. Del. Mar. 25, 2024). The Federal Circuit held that patentee failed to present sufficient evidence that the accused components were structurally equivalent to the disclosed structure of a means plus function limitation under 35 U.S.C. § 112(f).... By: A&O Shearman