直 Japanese PDF Font
  • Our Professionals
  • Our Work
  • Our Insights
  • Firm
  • Careers
Finnegan
    • At the PTAB Blog
    • European IP Blog
    • Federal Circuit IP Blog
    • INCONTESTABLE® Blog
    • IP Health Blog
    • Prosecution First Blog
  • Articles
  • IP Updates
  • Podcasts
  • Events
  • Webinars
  • Books

Federal Circuit IP Blog

Transaction Authentication Claims Using Known Computer Components Are Patent Ineligible

August 31, 2021

By Forrest A. Jones

Edited by Christina Ji-Hye Yang; Elizabeth D. Ferrill

In Universal Secure Registry LLC v. Apple Inc., No. 2020-2044 (Fed. Cir. Aug. 26, 2021), the Federal Circuit affirmed the district court’s determination that four patents related to securing credit card transactions without a credit card magnetic strip are patent ineligible under 35 U.S.C. § 101.

At the lower court, Apple moved to dismiss USR’s complaint, arguing all four patents claimed patent-ineligible subject matter. The magistrate judge initially found they are not, finding that “a more secure authentication system” is an improvement to computer functionality. However, the district court disagreed, finding that “the secure verification of a person’s identity” is an abstract idea and the remaining claim elements are not transformative.

The Federal Circuit agreed with the district court. Addressing each patent individually, at Alice Step One, the Federal Circuit determined each patent is directed to authentication, which is an abstract idea using “conventional tools” to perform “generic steps and results.” At Alice Step Two, the Court found the claim elements are not transformative because the specifications describe the individual elements as conventional, and there is no plausible indication that the combination of conventional techniques “achieves more than the expected sum of the security provided by each technique.”

Tags

United States Court of Appeals for the Federal Circuit (CAFC), patent ineligibility, patentable subject matter, subject matter eligibility, 35 U.S.C. § 101

Related Practices

Patent Litigation

Appeals

Related Industries

Electronics and Information Technology

Electronic Devices and Components

Related Offices

Washington, DC

Contacts

Forrest_Jones
Forrest A. Jones
Partner
Washington, DC
+1 202 408 4019
Email
Christina_Yang
Christina Ji-Hye Yang
Associate
Washington, DC
+1 202 408 4465
Email
Elizabeth D. Ferrill
Partner
Washington, DC
+1 202 408 4445
Email

Copyright © 2021 Finnegan, Henderson, Farabow, Garrett & Dunner, LLP. 


DISCLAIMER: Although we wish to hear from you, information exchanged in this blog cannot and does not create an attorney-client relationship. Please do not post any information that you consider to be personal or confidential. If you wish for Finnegan, Henderson, Farabow, Garrett & Dunner, LLP to consider representing you, in order to establish an attorney-client relationship you must first enter a written representation agreement with Finnegan. Contact us for additional information. One of our lawyers will be happy to discuss the possibility of representation with you. Additional disclaimer information.

Related Insights

Conference

IPBC Asia 2022

October 31 - November 2, 2022

Tokyo

Conference

2022 AIPPI World Congress

September 10-13, 2022

San Francisco

Lecture

Understanding Trademarks 2022

July 11-15, 2022

Montreal

Hybrid Conference

2022 Bench & Bar Conference

June 15-18, 2022

Sea Island

Webinar

Patent Drafting for Cryptocurrency Innovations: Overcoming Eligibility Challenges, Minimizing the Risks of Rejection

June 14, 2022

Webinar

Seminar

Practical Tips: European and US IP Practice Seminar

June 9, 2022

London

Webinar

Manufacturing Monetization: Due Diligence Before Licensing or Litigating Your Patent Portfolio

June 8, 2022

Webinar

Webinar

ITC Litigation: Current Trends, Developments, and Strategies for Litigants

June 7, 2022

Webinar

Virtual Seminar

Patent Year in Review: Key Decisions, Trends, and Strategies

June 3, 2022

Virtual

Due to international data regulations, we’ve recently updated our privacy policy. Click here to read our privacy policy in full.

We use cookies on this website to provide you with the best user experience. By accepting cookies, you agree to our use of cookies. Please note that if you opt not to accept or if you disable cookies, the “Your Finnegan” feature on this website will be disabled as well. For more information on how we use cookies, please see our Privacy Policy.

  • Privacy
  • Disclaimer
  • EEO Statement

© 2022 Finnegan, Henderson, Farabow, Garrett & Dunner, LLP