In Research in Motion Corporation v. MobileMedia Ideas LLC, IPR2013-00117, Paper 65 (March 7, 2013), the Board terminated the Trial after determining that it could not construe the means-plus-function limitations in the claims.  The Board noted that the disclosure of a general purpose computer was insufficient to support computer-based means-plus-function elements without disclosure of the algorithm. The Board found that it could not evaluate the claims, if it could not construe them, and therefore terminated the trial.  While the Board cannot invalidate claims under Section 112 in an inter partes review, it has nonetheless, marked these claims for invalidation