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Despite the willingness of the U.S. Court of Appeals for the Federal Circuit to interpret means-plus-function claims under 35 U.S.C. 112, para. 6, that tribunal has practically gone out of its way to avoid interpreting step-plus-function claim limitations. Even though the court finally defined step-plus-function limitations nearly two years ago, [FOOTNOTE 1]no other Federal Circuit decision had revisited this issue until the recent ruling in Seal-Flex Inc. v. Athletic Track and Court Construction. [FOOTNOTE 2]

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