Mitek Systems, Inc. v. United Services Automobile Association, No. 21-1989 (Fed. Cir. 2022)
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USAA, a reciprocal inter-insurance exchange organized under Texas law with its principal place of business in San Antonio, owns the four patents, which address the use of a mobile device to capture an image of a bank check and transmit it for deposit. Mitek filed suit in the Northern District of California, seeking a declaratory judgment (28 U.S.C. 2201(a)), that Mitek and its customers have not infringed, either directly or indirectly, any valid and enforceable claim of USAA’s patents. USAA moved for dismissal of the complaint, arguing that there was no case or controversy between USAA and Mitek and that the court should exercise discretion not to hear Mitek’s claim. In the alternative, USAA requested the transfer of the action to the Eastern District of Texas under 28 U.S.C. 1404. The California court, without ruling on the dismissal motion, ordered the case transferred to Texas.
The Texas court dismissed for want of a case or controversy, stating that, even if jurisdiction existed, it would exercise its discretion to decline to entertain the action. The Federal Circuit vacated the Texas court’s dismissal and remanded, affirming the California court’s transfer order. To make the “case or controversy” determination, the district court’s primary task will be to ascertain the alleged role of the Mitek technology in the banks’ applications and the alleged role that the Mitek technology plays in infringement claims.
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