PNC won a Federal Circuit eligibility ruling in its patent fight with USAA over mobile check-deposit technology.
The court focused on claims that used optical character recognition in the remote-deposit workflow. It found no genuine factual dispute blocking summary judgment under Section 101, noting evidence that OCR was already known in commercial check-deposit systems.
For fintech patent owners, the case reinforces the difference between a valuable banking workflow and a patentable technical improvement. Adding known OCR to a financial process may not supply the inventive concept needed under Alice.
For defendants, it is a reminder that eligibility can remain useful at summary judgment when the record confirms the relevant technology was conventional.