Takeaway: The Federal Circuit invalidated USAA’s mobile check deposit patent for claiming an abstract idea without inventive technology, reinforcing that using generic devices for routine tasks is not patent-eligible under § 101.

The Federal Circuit has reversed a major win for United Services Automobile Association (USAA), ruling that one of its key mobile check deposit patents is invalid under 35 U.S.C. § 101. In USAA v. PNC Bank N.A., the court held that U.S. Patent No. 10,402,638 covers an abstract idea and lacks the inventive concept required for patent eligibility.

USAA had sued PNC for infringing multiple patents related to mobile check deposit. While other patents were invalidated or dropped, the ‘638 patent remained at issue. The Eastern District of Texas had granted summary judgment for USAA, finding the claims eligible, and a jury later found PNC had infringed. PNC appealed, arguing the patent simply used generic mobile technology to perform routine banking steps.

The Federal Circuit agreed, applying the Alice framework and finding the claims abstract and implemented using conventional technology like mobile phones and OCR. Because the patent lacked any specific technological improvement, the court ruled it was ineligible.

With the patent invalidated, the court dismissed USAA’s cross-appeal over damages as moot. The ruling is a clear signal that abstract business methods, even when performed on mobile devices, are unlikely to survive § 101 scrutiny without concrete technical innovation.