In re Knowlton

Citation: In re Knowlton, 481 F.2d 1357, 178 U.S.P.Q. (BNA) 486 (C.C.P.A. 1973).

Knowlton invented a method for digital computer processing of linked list files with variable length records, and claimed it as a "rnachine" in means-plus-function language. The specification disclosed block diagrams and program listings.

The Government's position was based solely on citations of prior art and Section 112 objections, the Board of Appeals having reversed subject matter objections by the examiner, perhaps on the strength of earlier C.C.P.A. cases. The C.C.P.A. rejected the "multiple recitation” attack on the claim language. An effort by the Government to burden program-related apparatus claims with heavy disclosure requirements also suffered defeat.

The Board of Appeals had acted on the Knowlton case before the decision in Gottschalk v. Benson. The Patent Office thereby lost an excellent opportunity to extend the Benson holding to apparatus claims, since the essential facts in Knowlton seem to fall squarely within the Supreme Court's reasoning.