Case: Patents/Obviousness (Fed. Cir.)

The Federal Circuit affirmed decisions of the Patent Trial and Appeal Board that challenged claims of United Services Automobile Association’s patents that disclose systems and methods for image monitoring and alignment of checks during mobile deposit are unpatentable as obvious over prior art, in inter partes reviews by PNC Bank N.A. The court rejected USAA’s argument that the board erred in issuing inconsistent IPR decisions without rational explanation. And the Federal Circuit said that substantial evidence supports the board’s findings that a skilled artisan would have been motivated to combine prior art references.