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Content Extraction & Transmission LLC v. Wells Fargo Bank, N.A.

United States Court of Appeals for the Federal Circuit

December 23, 2014, Decided

2013-1588, 2013-1589, 2014-1112, 2014-1687

Opinion

 [*1345]  [***1356]   Chen, Circuit Judge.

Content Extraction and Transmission LLC and its principals (collectively, CET) appeal from the grant of a motion to dismiss under Rule 12(b)(6) of the Federal Rules of Civil Procedure (FRCP), in which the United States District Court for the District of New Jersey held that the claims of CET's asserted patents [**2]  are invalid as patent-ineligible under 35 U.S.C. § 101. Cross-appellant Diebold, Inc. (Diebold) appeals from the district court's dismissal of its tortious interference and Racketeer Influenced and Corrupt Organizations Act (RICO) claims against CET in a related action. We affirm the district court's dismissal of both CET's and Diebold's claims.

Background

CET owns U.S. Patent Nos. 5,258,855 ('855 patent), 5,369,508 ('508 patent), 5,625,465 ('465 patent), and 5,768,416 ('416 patent) (collectively, the asserted patents). The '508, '465, and '416 patents are continuations of the '855 patent, and share substantially the same specification. The four patents contain a total of 242 claims. The claims generally recite a method of 1) extracting data from hard copy documents using an automated digitizing unit such as a scanner, 2) recognizing specific information from the extracted data, and 3) storing that information in a memory. This method can be performed by software on an automated teller machine (ATM) that recognizes information written on a scanned check, such as the check's amount, and populates certain data fields with that information in a computer's memory.

Claim 1 of the '855 patent recites:

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776 F.3d 1343 *; 2014 U.S. App. LEXIS 24258 **; 113 U.S.P.Q.2D (BNA) 1354 ***; 2014 WL 7272219

CONTENT EXTRACTION AND TRANSMISSION LLC, Plaintiff-Appellant, v. WELLS FARGO BANK, NATIONAL ASSOCIATION, Defendant-Appellee, AND THE PNC FINANCIAL SERVICES GROUP, INC. AND PNC BANK, N.A., Defendants-Appellees.DIEBOLD, INCORPORATED, Plaintiff-Counterdefendant-Cross Appellant, v. CONTENT EXTRACTION AND TRANSMISSION LLC, Defendant-Counterplaintiff-,Appellant, AND MITCHELL MEDINA, CATHERINE ELIAS, AND JEAN-MARC ZIMMERMAN, Defendants, AND JOHN DOE COMPANIES 1-100, JOHN DOE COMPANIES 1-99, TD BANK GROUP, AND TD BANK, N.A. Third-Party Defendants.

Subsequent History: US Supreme Court certiorari denied by Content Extraction & Trans v. Wells Fargo Bank, 2015 U.S. LEXIS 6112 (U.S., Oct. 5, 2015)

Prior History:  [**1] Appeals from the United States District Court for the District of New Jersey in Nos. 12-CV-2501, 12-CV-6960, and 12-CV-7640, Judge Michael A. Shipp.

Content Extraction & Transmission LLC v. Wells Fargo Bank, 2013 U.S. Dist. LEXIS 107184 (D.N.J., July 31, 2013)

Disposition: AFFIRMED.

CORE TERMS

patents, district court, abstract idea, invalid, hard copy, infringement, tortious interference, patent-ineligible, documents, storing, recite, patent-eligible, extracting, processing, inventive, baseless, scanner, suits, technology, scanning, generic, memory, prong

Civil Procedure, Appeals, Standards of Review, De Novo Review, Defenses, Demurrers & Objections, Motions to Dismiss, Failure to State Claim, Patent Law, Jurisdiction & Review, Subject Matter, General Overview, Computer & Internet Law, Intellectual Property Protection, Patent Protection, Subject Matter, Infringement Actions, Claim Interpretation, Constitutional Law, Bill of Rights, Fundamental Freedoms, Freedom to Petition, Evidence, Inferences & Presumptions, Presumptions, Particular Presumptions