PTAB

CBM2019-00003

Wells Fargo Bank NA v. United Services Automobile Association

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and method for remote deposit capture
  • Brief Description: The ’517 patent describes a system for remote check deposit using a mobile device. The system generates an on-screen alignment guide to help a user correctly position a financial instrument before the device’s camera automatically captures the image for processing and transmission to a financial institution.

3. Grounds for Unpatentability

Ground 1: Obviousness over Ramachandran and Yoon

  • Legal Basis: Claims 1-2, 5-6, 9-13, 15-16, and 18-20 are obvious over Ramachandran in view of Yoon.
  • Prior Art Relied Upon: Ramachandran (Application # 2009/0114716), which incorporates Blackson (Patent 7,419,093), and Yoon (Application # 2007/0262148).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ramachandran taught the foundational system for capturing a check image with a mobile phone and transmitting it to a bank for deposit. This included using a phone’s camera and sending the image to an automated banking machine that could resolve MICR line data, as detailed in the incorporated Blackson reference. However, Ramachandran lacked a mechanism to ensure proper alignment during capture. Yoon was argued to supply this missing element by teaching a portable terminal that displays "reference boundary lines" (an alignment guide). Yoon's system monitors the camera's view, determines when the boundaries of a business card coincide with the guide, and then automatically captures the image.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would be motivated to improve the quality of check images captured by Ramachandran's system to meet the stringent image-quality requirements of the Check 21 Act. Poor alignment causes "document skew," a known problem that degrades image quality and could lead to transaction errors. A POSITA seeking to prevent skew would have found Yoon's alignment guide technique an obvious solution to apply to the analogous problem of check capture. This combination would improve image quality from the outset, reducing or eliminating the need for the post-capture "deskewing" software step taught by Ramachandran via the incorporated Blackson reference.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in applying Yoon's well-understood alignment guide technique for business card capture to the analogous and predictable task of check capture.

Ground 2: Obviousness over Ramachandran, Yoon, and Cho

  • Legal Basis: Claims 3-4, 7-8, 14, and 17 are obvious over Ramachandran in view of Yoon and further in view of Cho.
  • Prior Art Relied Upon: Ramachandran (Application # 2009/0114716), Yoon (Application # 2007/0262148), and Cho (Patent 7,120,461).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed dependent claims requiring an adjustable alignment guide. Building on the Ramachandran/Yoon combination, Petitioner argued that Cho taught the necessary modifications. Cho disclosed a camera phone with a customizable "composition guideline" to help users with difficult photo alignments. Cho taught that a user could select from pre-programmed guides or adjust a guide's type, shape, color, and coordinates via on-screen menus and direction keys.
    • Motivation to Combine: Petitioner contended that the system resulting from Ramachandran and Yoon would possess a static-sized alignment guide, limiting its utility for different-sized documents. A POSITA would recognize that checks, like other financial instruments, are not uniform in size. To enhance the system's "utility and flexibility," a POSITA would be motivated to incorporate Cho’s teachings on user-adjustable guides, allowing the system to accommodate various document types.
    • Expectation of Success: Implementing known user-input methods from Cho to adjust the alignment guide within the base system of Ramachandran and Yoon would be a predictable design choice with a high expectation of success.
  • Additional Grounds: Petitioner also asserted that claims 1-20 are unpatentable as directed to patent-ineligible subject matter under 35 U.S.C. §101 because the claims are directed to the abstract ideas of taking a better picture and depositing a check, implemented with generic computer components.

4. Key Claim Construction Positions

  • Petitioner argued for correcting an obvious drafting error in claim 12, which recites instructions "to clean the instrument." As dependent claim 13 specifies that "the cleaning of the information comprises at least cropping," it lacks a proper antecedent basis in claim 12. Given that the specification only discusses processing the captured image (e.g., by cropping) and not the physical instrument, Petitioner asserted a POSITA would understand the phrase in claim 12 should be construed as "clean the captured information of the instrument."

5. Relief Requested

  • Petitioner requested institution of a covered business method (CBM) review and cancellation of claims 1-20 of the ’517 patent as unpatentable.