Today, Mon., Apr. 9, 2012, in Noah Sys. v. Intuit, No. 2011-1390, the Federal Circuit (Rader, O’Malley and Reyna) ruled that a special purpose computer-implemented means-plus-function limitation was indefinite because the patent specification did not disclose algorithms to all claimed functions. The Court ruled that expert testimony on the adequacy of the disclosure was not necessary where no algorithm was disclosed.