Intellectual Property News and Reports

PNC Bank, N.A. appeals the U.S. District Court for the Eastern District of Texas’s grant of United Services Automobile Association’s motion for summary judgment of patent eligibility under 35 U.S.C. § 101. This appeal concerns U.S. Patent No. 10,769,598, U.S. Patent No. 10,402,638, and U.S. Patent No. 9,224,136. We limit our discussion to the ’638 patent because we have separately affirmed an inter partes review of the ’598 patent finding the asserted claims unpatentable under 35 U.S.C. § 103, see United Services Automobile Ass’n. v. PNC Bank N.A., No. 23-2171, 2025 WL 339662 (Fed. Cir. Jan. 30, 2025), and an inter partes review of the ’136 patent also finding the asserted claims unpatentable under 35 U.S.C. § 103, see United Services Automobile Ass’n. v. PNC Bank N.A., No. 23-2244, 2025 WL 706080 (Fed. Cir. Mar. 5, 2025).1 Because the asserted claim of the ’638 patent is directed to an abstract idea and does not contain an inventive concept, we reverse.

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