Before § 101 got big in the early-to-mid 2010's, I recall there being a lot more discussion about construing claims—particularly software claims—to be means-plus-function claims, and then trying to get them invalidated under § 112 ¶ 6 for lack of corresponding structure.
Lately that issue seems to be litigated less frequently, but an order from Judge Andrews today shows that it hasn't faded away completely.
He looked at two claim elements:
a [] translator device adapted to translate data between the exercise communication protocol and the computer communication protocol.
and
translator devices are configured to communicatively couple the first and second exercise devices to the means for comparing so as to facilitate communication of data representative …