Universal Secure Registry LLC v. Apple Inc., No. 20-2044 (Fed. Cir. 2021)Annotate this Case
USR sued Apple for infringement of patents otherwise directed to similar technology, securing electronic payment transactions. The patents “address the need for technology that allows consumers to conveniently make payment-card [e.g., credit card] transactions without a magnetic-stripe reader and with a high degree of security.”
The district court found all claims of four asserted patents ineligible under 35 U.S.C. 101. The Federal Circuit affirmed. All claims of the asserted patents are directed to an abstract idea and contain no additional elements that transform them into a patent-eligible application of the abstract idea. Applying the Supreme Court’s “Alice” analysis, the court stated that sending data to a third party as opposed to the merchant is an abstract idea and cannot serve as an inventive concept, as is authenticating a user using conventional tools and generating and transmitting that authentication—without “improv[ing] any underlying technology.” Nothing in the claims is directed to a new authentication technique; rather, the claims are directed to combining longstanding, known authentication techniques to yield expected additional amounts of security.