Eplus, Inc. v. Lawson Software, Inc., 700 F.3d 509

This is an appeal and cross-appeal from a jury verdict that Lawson infringed ePlus's method and system claims; Lawson challenges indefiniteness of system claims and sufficiency of infringement evidence for method claims.
Patents at issue are U.S. 6,023,683 (’683) and 6,505,172 (’172) directed to electronic sourcing, with Core Procurement, Punchout, RSS, and EDI modules forming accused configurations.
ePlus alleged infringement by Lawson through direct and indirect (induced) use of Lawson’s software, including services selling, installing, and maintaining the accused systems.
The district court denied Lawson’s indefiniteness motion at summary judgment, barred damages evidence (Daubert and Rule 37 rulings), and later entered a permanent injunction against infringing configurations.
The jury found infringement for certain claims; the district court’s JMOL denial and injunction scope are challenged on appeal, and the case is remanded for injunction adjustments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Indefiniteness of system claims	Lawson waived nothing; means-for-processing lacks disclosed structure.	Indefiniteness pleading was not properly raised at trial.	System claims indefinite; no adequate disclosed structure for means for processing.
Infringement of claim 26	Lawson or its customers perform every step, including determining inventory availability.	Customers only provoke inventory checks via vendors; not all steps performed.	Claim 26 infringed by Lawson directly/indirectly; substantial evidence supports infringement.
Infringement of claims 28 and 29	Accused systems convert data via UNSPSC codes; defendants perform converting step.	No proof that any user performed the converting step; UNSPSC evidence insufficient.	No substantial evidence of infringement for claims 28 and 29; JMOL reversed on those claims.
Injunction scope	Injunction appropriately prevents ongoing infringement; damages not at issue.	Injunction is too broad by preventing servicing pre-injunction sales.	No abuse of discretion on injunction; remanded to adjust terms consistent with opinion.

Typhoon Touch Technologies, Inc. v. Dell, Inc., 659 F.3d 1376 (Fed. Cir. 2011) (algorithm disclosure sufficiency, not mere conceptual description)
Aristocrat Techs. Australia Pty Ltd. v. Int’l Game Tech., 521 F.3d 1337 (Fed. Cir. 2008) (means-plus-function structure must be disclosed; algorithm disclosure context)
Noah Sys., Inc. v. Intuit Inc., 675 F.3d 1302 (Fed. Cir. 2012) (waiver and indefiniteness defenses in claim construction context)