This case concerns the patent eligibility of United Services Automobile Association's (USAA) mobile check deposit technology, specifically U.S. Patent No. 10,402,638 ('638 patent). The Federal Circuit reversed the District Court's finding of patent eligibility, concluding that the asserted claim (claim 20 of the '638 patent) is directed to an abstract idea and lacks an inventive concept under 35 U.S.C. § 101, as defined by the Supreme Court's Alice Corp. v. CLS Bank Int’l framework. The court held that merely implementing conventional banking processes (like reviewing, recognizing, error-checking, and storing check data) on a generic handheld mobile device, even with features like real-time error checking and OCR, does not transform an abstract idea into patent-eligible subject matter. Case summary: https://www.cafcnewsbriefs.com/post/usaa-v-pnc-bank-n-a-decided-june-12-2025
