This morning, the Federal Circuit released three opinions in patent cases appealed from the Eastern District of Texas. Two were precedential and one was nonprecedential. The precedential opinions address subject matter jurisdiction in a declaratory judgment action and patent eligibility, respectively. The nonprecedential opinion addresses patent eligibility. Notably, all three opinions address patents asserted by United Services Automobile Association, and the two opinions addressing eligibility invalidate the asserted patents. Here are the introductions to the opinions.
Mitek Systems, Inc. v. United Services Automobile Association (Precedential)
Mitek Systems, Inc. (Mitek) appeals the decision of the United States District Court for the Eastern District of Texas, which dismissed Mitek’s declaratory judgment action of non-infringement against United Services Automobile Association (USAA) concerning U.S. Patent Nos. 8,699,779 (’779 patent), 9,336,517 (’517 patent), 9,818,090 (’090 patent), and 8,977,571 (’571 patent) (collectively, patents-in-suit). Mitek Sys., Inc. v. United Servs. Auto. Ass’n, No. 20-CV-00115, 2023 WL 2734372 (E.D. Tex. Feb. 23, 2023) (Decision).
This case returns to us for the second time, now with an expanded record. In the first appeal, in relevant part, we vacated the district court’s original dismissal for lack of subject-matter jurisdiction, as well as its alternative discretionary dismissal, and remanded for further proceedings. See Mitek Sys., Inc. v. United Servs. Auto. Ass’n, 34 F.4th 1334, 1349 (Fed. Cir. 2022) (Mitek I). On remand, the district court again determined that it lacked subject-matter jurisdiction over Mitek’s action, and, even if jurisdiction existed, it would exercise its discretion to decline to accept jurisdiction. See Decision, 2023 WL 2734372, at *28. For the reasons explained below, we affirm.
United Services Automobile Association v. PNC Bank N.A. (Precedential)
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). Because the asserted claim of the ’638 patent is directed to an abstract idea and does not contain an inventive concept, we reverse.
United Services Automobile Association v. PNC Bank N.A. (Nonprecedential)
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, as well as the district court’s denial of PNC’s post-trial motions. This appeal concerns U.S. Patent No. 10,013,605, U.S. Patent No. 10,013,681, U.S. Patent No. 10,482,432, U.S. Patent No. 8,977,571, U.S. Patent No. 8,699,779, and U.S. Patent No. 10,621,559. We limit our discussion to the ’605 patent, the ’681 patent, and the ’432 patent because we have separately affirmed an inter partes review of the ’571 patent and the ’779 patent finding the asserted claims unpatentable as obvious, see United Services Automobile Ass’n. v. PNC Bank N.A., No. 23-2124, 2025 WL 370141 (Fed. Cir. Feb. 3, 2025), and an inter partes review of the ’559 patent also finding the asserted claims unpatentable as obvious, see United Services Automobile Ass’n. v. PNC Bank N.A., No. 23-1920, 2025 WL 341868 (Fed. Cir. Jan. 30, 2025). Because the asserted claims of the ’605, ’681, and ’432 patents are directed to an abstract idea and do not contain an inventive concept, we reverse.