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June 14, 2025 11 mins

This is a Federal Circuit opinion regarding a patent dispute between United Services Automobile Association (USAA) and PNC Bank N.A., heard by the United States Court of Appeals for the Federal Circuit. The core of the appeal concerns the patent eligibility of USAA's "Digital Camera Processing System" patent, specifically U.S. Patent No. 10,769,598, U.S. Patent No. 10,402,638, and U.S. Patent No. 9,224,136, under 35 U.S.C. § 101. The court applied the two-step Alice test to determine if the patent claims were directed to an abstract idea and, if so, whether they contained an inventive concept. Ultimately, the court reversed the district court's summary judgment in favor of USAA, concluding that the asserted claim from the ’638 patent was directed to an abstract idea without an inventive concept, thus deeming it unpatentable.

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