United Services Automobile Association v. PNC BANK N.A.,
Before Dyk, Clevenger, and Hughes. Appeal from the United States District Court for the Eastern District of Texas.
Summary: A claim that merely recites a system for conducting routine steps without providing sufficient specificity as to the technical improvement behind the claimed invention is patent-ineligible subject matter.
United Services Automobile Association (USAA) sued PNC Bank (PNC) alleging infringement of USAA’s patent describing a system for allowing a customer to deposit a check to a mobile banking application using a handheld mobile device and reviewing the deposited check for errors using optical character recognition (OCR). Both USAA and PNC filed for summary judgment motions seeking, respectively, judgement that the claim was or was not patent eligible under 35 U.S.C. § 101. The district court granted USAA’s motion and denied PNC’s, holding that the asserted claim was patent eligible under § 101. The district court concluded that the claim was not directed to an abstract idea and therefore did not meet the first step in the Alice analysis.
On appeal, the Federal Circuit reversed. First, the Federal Circuit held that the claim was directed to an abstract idea under Alice step one. The Federal Circuit explained the claim was directed to the abstract idea of depositing a check using a mobile device. The Federal Circuit reasoned that the steps for depositing a check using a mobile device were routine data collection and analysis steps (e.g., depositing checks, reviewing for errors, storing the data, etc.). The court further noted that, even if the implementation required the development of “non-obvious algorithms,” the claim required no particular configuration for the otherwise abstract steps. Thus, including a handheld device to carry out conventional steps without additional details did not make the claim any less abstract.
Editor: Sean Murray
