The Eastern District of Texas held that the only asserted claim of U.S. Patent No. 6,452,515 was indefinite because “the term ‘[means] for encoding these labels in a random order’” (alterations in original) invokes 35 USC § 112 ¶ 6, and “the specification of the ‘515 Patent does not disclose an algorithm for performing the encoding function required by this limitation.” Uniloc 2017 LLC v. Google LLC, No. 18-cv-00501-JRG-RSP (E.D.Tex. May 1, 2020). The asserted claim from the ‘515 Patent, claim 1, is reproduced here: 1. A video encoder for processing a sequence of animated pictures, said encoder comprising: means for dividing a screen window occupied by said sequence into X rows and Y columns; means for separately encoding each one of the X·Y parts of each picture of the sequence thus obtained; and means for associating, to each of said parts, a specific label indicating a…