Justia Banking Opinion SummariesArticles Posted in Patents
Content Extraction & Transmission, LLC v. Wells Fargo Bank
CET owns the asserted patents, which share substantially the same specification. The four patents contain a total of 242 claims. The claims generally recite a method of extracting data from hard copy documents using an automated digitizing unit such as a scanner, recognizing specific information from the extracted data, and storing that information in a memory. This method can be performed by software on an automated teller machine (ATM) that recognizes information written on a scanned check, such as the check’s amount, and populates certain data fields with that information in a computer’s memory. CET asserted infringement by banking entities. Diebold, the manufacturer of ATMs used by the banking entities, sought a declaratory judgment that its ATMs did not infringe CET’s asserted patents and that CET’s patents were invalid and sought injunctive and monetary relief for tortious interference and violations of the Racketeer Influenced and Corrupt Organizations Act (RICO) arising from CET’s act of filing allegedly baseless infringement suits against its customers. The district court dismissed CET’s infringement action, holding that the claims of the asserted patents are invalid as patent-ineligible under 35 U.S.C. 101 and dismissed Diebold’s claims. The Federal Circuit affirmed. View "Content Extraction & Transmission, LLC v. Wells Fargo Bank" on Justia Law
CLS Bank Int’l v. Alice Corp. Pty. Ltd.
Alice Corporation owns three patents covering a computerized trading platform for exchanging obligations in which a trusted third party settles obligations between a first and second party so as to eliminate “settlement risk.” Settlement risk is the risk that only one party’s obligation will be paid, leaving the other party without its principal. The trusted third party eliminates this risk by either exchanging both parties’ obligations or exchanging neither obligation. CLS sought a declaration of invalidity; Alice counterclaimed infringement. The district court ruled in favor of CLS, holding that each asserted claim of the four patents is invalid for failure to claim patent eligible subject matter. The Federal Circuit reversed. The system, method, and media claims at issue are not drawn to mere “abstract ideas” but are directed to practical applications of invention falling within the categories of patent eligible subject matter defined by 35 U.S.C. 101. View "CLS Bank Int'l v. Alice Corp. Pty. Ltd." on Justia Law