SOLUTRAN, INC. v. ELAVON, INC.
- Jul 30 2019 |
- Category: CAFC Updates
U.S. Bancorp and its affiliate Elavon, Inc. (collectively, U.S. Bank) appeal the district court’s order denying U.S. Bank’s motion for summary judgment that claims of Solutran’s U.S. Patent No. 8,311,945 (relating to a system and method of electronically processing checks), are invalid under 35 U.S.C. §101 for failing to recite patent-eligible subject matter. In the first step of an Alice analysis, the CAFC concludes that the claims are directed to the abstract idea of crediting a merchant’s account as early as possible while electronically processing a check, and notes that the physicality of the paper checks being processed and transported is not by itself enough to exempt the claims from being directed to an abstract idea. In the second step of the Alice analysis, the CAFC disagrees with the district court that the ’945 patent claims contain a sufficiently transformative inventive concept so as to be patent eligible, finding that merely using a general-purpose computer and scanner to perform conventional activities in the way they always have does not amount to an inventive concept. Accordingly, the CAFC reverses.