PTAB

CBM2019-00002

Wells Fargo Bank NA v. United Services Automobile Association

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Image Capture
  • Brief Description: The ’090 patent discloses systems and methods for remote check deposit using a mobile device. The technology monitors a check within the device's camera view against predefined criteria, provides feedback to guide the user in positioning the check, and automatically captures an image once the criteria are met to ensure the image is readable for financial processing.

3. Grounds for Unpatentability

Ground 1: Patent Ineligibility - Claims 1-20 are directed to ineligible subject matter under 35 U.S.C. § 101.

  • Prior Art Relied Upon: Not applicable (challenge based on abstract idea).
  • Core Argument for this Ground:
    • Petitioner argued that all challenged claims are directed to the patent-ineligible abstract idea of composing a good photograph. This fundamental, long-standing mental process involves monitoring a subject, determining if it meets certain criteria (e.g., proper framing and alignment), receiving mental feedback (e.g., "move closer"), and capturing the image.
    • The ’090 patent claims this abstract process but implements it using generic, conventional computer components like a mobile device, processor, and camera, which are described in the patent without any purported technological improvement. Petitioner contended that merely applying an abstract idea on a general-purpose computer does not confer patent eligibility, and the claims lack any inventive concept sufficient to transform the abstract idea into a patent-eligible invention.

Ground 2: Anticipation over Yoon - Claims 1, 2, 4, 5, 7, 10, 11, 12, 14, 15, and 17 are anticipated under 35 U.S.C. § 102 by Yoon.

  • Prior Art Relied Upon: Yoon (Application # 2007/0262148).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Yoon discloses a portable terminal for automatically photographing a business card, which meets all limitations of the challenged independent claims. Yoon's system uses a camera (image capture device) and a display (presentation device) to monitor the business card relative to "reference boundary lines" shown on the screen (a monitoring criterion). It provides feedback by changing the color of the boundary lines as they align with the card's edges.
    • Key Aspects: When all boundary lines coincide with the card's edges (determining the criterion is satisfied), Yoon’s system automatically captures the image. Petitioner argued this single reference teaches every element of the core claimed process: monitoring a document, providing feedback, determining criterion satisfaction, and capturing the image.

Ground 3: Obviousness over Yoon and Ramachandran - Claim 20 is obvious under 35 U.S.C. § 103 over Yoon in view of Ramachandran.

  • Prior Art Relied Upon: Yoon (Application # 2007/0262148) and Ramachandran (Application # 2009/0114716).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended that Ramachandran teaches the specific application of remote check deposit, wherein a user captures a check image on a mobile phone and transmits it to a bank. To address poor image quality, Ramachandran suggests post-capture software-based "deskewing." Yoon, in the context of business cards, teaches a pre-capture method for ensuring a high-quality, well-aligned image using on-screen guides.
    • Motivation to Combine: A POSITA developing a remote deposit system like Ramachandran's would be motivated by the strict image quality requirements of the Check 21 Act to ensure checks were captured correctly in the first instance. A POSITA would combine Yoon’s pre-capture alignment and feedback system with Ramachandran's check deposit application to improve image quality, reduce errors (like unreadable MICR data), and eliminate the need for inefficient post-capture deskewing.
    • Expectation of Success: A POSITA would have a high expectation of success in applying Yoon's alignment technique for rectangular business cards to the analogous task of aligning rectangular checks.

  • Additional Grounds: Petitioner asserted additional challenges, including that claims 3, 8, 9, 13, 18, and 19 are obvious over Yoon alone, and that claims 6 and 16 are obvious over Yoon in view of Mekuria (Patent 6,931,255) for adding audible feedback.

4. Relief Requested

  • Petitioner requests institution of a Covered Business Method review and cancellation of claims 1-20 of the ’090 patent as unpatentable.