PNC Escapes ATM, Mobile Deposit Processing IP Suit

Law360, Los Angeles (July 31, 2013, 9:44 PM ET) -- A Delaware federal judge on Wednesday dismissed a suit in which Content Extraction and Transmission LLC accused PNC Bank NA of infringing four patents related to information processing in ATMs and mobile deposits, ruling that they covered abstract ideas that couldn't be patented.

U.S. District Judge Michael A. Shipp said that although Content Extraction's patents referenced a scanner and computer, which could have helped the patents pass a machine-or-transformation test required to establish patent validity, those devices weren't integral to the claims.

The judge said the...
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