I further maintain that in computer-implemented inventions structure is inherent to function. I agree with NW@15. But I don’t think you have to be an EE Ph.D. to understand that.

Examples are provided of corresponding structure, material, or acts for different types of computer-implemented functional claim limitations, such as software modules, algorithms, data structures ...

Identifying Protocols by Name May Disclose Sufficient Structure for Computer-Implemented Means-Plus-Function Limitations James Hurt Sheppard Mullin Richter & Hampton LLP ...