DCT
2:15-cv-00479
Finnavations LLC v. Alliance Bank
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Finnavations, LLC (Texas)
- Defendant: Alliance Bank (Texas)
- Plaintiff’s Counsel: BROWN FOX KIZZIA & JOHNSON PLLC
- Case Identification: 2:15-cv-00479, E.D. Tex., 04/13/2015
- Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas because the Defendant is deemed to reside in the district and has allegedly committed acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s online and mobile banking platform infringes a patent related to a system for capturing, categorizing, and transmitting detailed financial transaction data to a personal financial management application.
- Technical Context: The technology addresses the process of automatically capturing detailed item-level data from online purchases to populate personal finance software, aiming to improve upon systems that only record a transaction's total value and payee.
- Key Procedural History: Subsequent to the complaint’s filing, the patent-in-suit was the subject of an Inter Partes Review (IPR2016-01906), which resulted in the cancellation of all claims (1-20) in a certificate issued on February 15, 2018. Prior to the IPR conclusion, the patent owner filed a dedication on June 30, 2017, dedicating the remaining term of all claims to the public. These post-filing events render the patent unenforceable and would be expected to terminate the litigation.
Case Timeline
| Date | Event |
|---|---|
| 1999-09-22 | '720 Patent Priority Date |
| 2012-03-13 | '720 Patent Issue Date |
| 2015-04-13 | Complaint Filing Date |
| 2017-06-30 | '720 Patent dedicated to the public by patent owner |
| 2018-02-15 | IPR Certificate issued, cancelling all claims of the '720 Patent |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,132,720 - Financial Management System
The Invention Explained
- Problem Addressed: The patent describes a drawback in existing personal financial management systems (e.g., Quicken, Microsoft Money) where users must manually enter detailed information about online purchases. These systems fail to automatically capture data beyond the total transaction amount, making it difficult to track specific items purchased or create transaction reminders ('720 Patent, col. 1:49-62).
- The Patented Solution: The invention proposes a "Financial Assistant," which is a software component that operates in conjunction with an online transaction ('720 Patent, col. 3:12-18). After a user completes a purchase, the Financial Assistant generates a graphical user interface (GUI) that is pre-populated with transaction data (e.g., payee, amount). The user can then add further details, such as a spending category, before the enriched data is transmitted to their personal financial management program ('720 Patent, Fig. 3; col. 8:53-66).
- Technical Importance: The technology was designed to automate and enrich the data captured from e-commerce, bridging the informational gap between an online checkout process and a user's personal bookkeeping software ('720 Patent, col. 1:12-17).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 ('720 Patent, col. 7:46-col. 8:6).
- The essential elements of Claim 1 are:
- A personal financial management application configured to store transaction data.
- A "financial assistant" that includes three sets of executable code:
- Code to generate a GUI at the conclusion of an online transaction, which includes fields for purchase amount, date, payee, a category, and an "accept" button.
- Code to automatically populate the GUI fields based on received transaction data.
- Code to transmit the data from the GUI to the personal financial management application when the "accept" button is activated.
- The complaint does not explicitly reserve the right to assert dependent claims, but alleges infringement of "one or more claims" (Compl. ¶12).
III. The Accused Instrumentality
Product Identification
- Defendant’s "Online Banking" mobile and online banking platform (Compl. ¶12).
Functionality and Market Context
- The complaint alleges the accused platform provides a "financial management application showing a history of financial transactions" (Compl. ¶13).
- It is further alleged to provide a "financial assistant" that enables a user to "populate fields with transaction data" and, upon acceptance, that data "populates corresponding fields of the financial management application" (Compl. ¶13).
- The complaint does not provide sufficient detail for analysis of the product's commercial importance or market positioning.
- No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
'720 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a personal financial management application configured to store personal financial management application transaction data including purchase amount data, purchase date data, payee data, and card identification data... | Defendant provides a "financial management application showing a history of financial transactions." | ¶13 | col. 7:48-52 |
| and a financial assistant comprising: a set of graphical user interface generation executable code configured to generate a graphical user interface at the conclusion of the online transaction... | The platform provides "a financial assistant" that allows a user to "access a financial management application." | ¶13 | col. 7:53-57 |
| a set of graphical user interface population executable code that populates the purchase amount field, the purchase date field, the payee field, and the card identification field based on the received transaction data... | The financial assistant enables the user to "populate fields with transaction data." | ¶13 | col. 8:1-5 |
| and a set of personal financial management application transmission executable code that transmits the... transaction data from the fields of the graphical user interface to the personal financial management application when the accept button is activated. | "...upon acceptance of the transaction, the transaction data populates corresponding fields of the financial management application." | ¶13 | col. 8:6-12 |
Identified Points of Contention
- Scope Questions: The complaint alleges a single "platform" performs all functions. A potential issue for litigation is whether an integrated online banking portal can meet the claim's apparent architectural requirement for a "personal financial management application" and a separate "financial assistant," which the patent specification suggests are distinct components ('720 Patent, col. 3:12-18).
- Technical Questions: The complaint is silent on the mechanism and timing of data population. A central question is whether the accused "financial assistant" operates "at the conclusion of the online transaction" to intercept data from a third-party merchant, as the patent describes, or if it merely provides an interface for a user to view or manually categorize transaction data that has already settled and posted to their bank account.
V. Key Claim Terms for Construction
Term: "financial assistant"
Context and Importance: This term defines the core novel component of the claimed system. Its construction is critical because it determines whether the accused feature—described simply as a component of an "Online Banking" platform—performs the specific functions required by the claims. Practitioners may focus on this term because the infringement case depends on whether a feature within a standard banking application can be considered a "financial assistant" as envisioned by the patent.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims do not restrict the "financial assistant" to a specific software architecture, such as a browser plug-in, potentially allowing it to be an integrated feature of a larger application ('720 Patent, col. 7:53).
- Evidence for a Narrower Interpretation: The specification consistently describes the Financial Assistant as a discrete entity that "intercepts transaction data" as it flows between a user's terminal and a commercial web server, or as a component residing on an ISP server to monitor traffic ('720 Patent, col. 3:15-20; col. 3:45-54). This suggests a specific role as an intermediary, not just a feature in a destination application.
Term: "at the conclusion of the online transaction"
Context and Importance: This temporal limitation is key to defining when the GUI must be generated. The infringement analysis may turn on whether the accused platform's functionality occurs immediately after a purchase or at a later time, such as when a transaction posts to a bank statement.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The phrase itself is not explicitly defined, which could leave room for an interpretation that includes any time after a transaction is contractually complete.
- Evidence for a Narrower Interpretation: The detailed description and figures imply an immediate, post-purchase workflow where a user is prompted to categorize a purchase they have just made on a merchant's site ('720 Patent, Fig. 1; col. 3:31-35). This context suggests the "conclusion" is the point of sale itself, not a later accounting event.
VI. Other Allegations
Indirect Infringement
- The complaint makes a conclusory allegation of contributory and induced infringement (Compl. ¶12). It does not, however, plead any specific facts to support the knowledge and intent elements of these claims, such as referencing user manuals or other instructions provided by the Defendant to its customers.
VII. Analyst’s Conclusion: Key Questions for the Case
Given the subsequent cancellation of all patent claims in IPR proceedings and the dedication of the patent to the public, the primary question is procedural: on what basis, if any, could the lawsuit proceed or what damages could be recovered for the limited period before the patent became unenforceable?
Assuming the case had proceeded before those events, it would have likely turned on two key questions:
- A question of architectural scope: Can the Defendant's integrated online banking system be mapped onto the patent's claimed structure of a distinct "personal financial management application" and a "financial assistant," or does the claim language require two separate, interacting components?
- A question of technical operation: Does the accused platform's functionality to "populate fields" involve the near-real-time interception and categorization of third-party transaction data "at the conclusion of the online transaction" as described in the patent, or does it describe a conventional banking feature for viewing and managing transactions that have already posted?