Fintech companies often build value by taking a financial process that used to happen in person or on paper and moving it into a faster, more convenient digital environment. Mobile banking, remote check deposit, automated payments, digital wallets, fraud detection, and financial dashboards can all provide real business value.
But under patent law, not every useful financial technology is patent eligible.
The Federal Circuit’s 2025 decisions in the USAA/PNC mobile deposit litigation are an important reminder that software and fintech patent claims need to do more than automate a known financial process using conventional technology.
The USAA/PNC Mobile Deposit Dispute
In one of the Federal Circuit decisions, United Services Automobile Association v. PNC Bank N.A., No. 23-1778, 2025 U.S. App. LEXIS 14443, 2025 WL 1662737 (Fed. Cir. June 12, 2025), the court addressed patents directed to mobile remote deposit capture technology. The patents involved systems for remotely depositing checks using general-purpose consumer electronics, such as mobile devices.
The asserted patents included U.S. Patent Nos. 10,013,605, 10,013,681, and 10,482,432. These patents generally related to capturing and transmitting check images so that a check could be deposited remotely.
The Federal Circuit held that the asserted claims were patent ineligible under 35 U.S.C. § 101. The court concluded that the claims were directed to the abstract idea of remotely depositing a check by capturing and transmitting an image of the check, and that the claims lacked an inventive concept sufficient to transform that abstract idea into patent-eligible subject matter.
Automating a Financial Process May Not Be Enough
The key issue was not whether mobile check deposit is useful. It clearly is. The issue was whether the patent claims recited a patent-eligible technological invention.
The Federal Circuit concluded that the claims were written at a functional level and relied on generic technology, such as mobile devices and conventional image capture and transmission. In the court’s view, the claims did not recite a specific technological improvement or explain how the claimed system improved the operation of the device, the image processing technology, or another technical component.
That distinction is critical for fintech patents.
A claim that says, in substance, “perform this financial process on a mobile device” may be vulnerable under § 101. A stronger claim should identify the specific technological problem and the specific technical solution.
The Importance of Claiming the Technical Improvement
The Federal Circuit also noted that technical features described in a patent specification may not save the patent if those features are not actually claimed. That is an important drafting lesson.
Patent applications often describe useful technical details in the written description. But for patent eligibility, courts focus heavily on the claims. If the claims are drafted broadly as results or functions, without reciting the technical mechanism that achieves the improvement, the patent may be more vulnerable.
For fintech inventions, the application should explain and claim the technological contribution. That may include, for example:
- a specific image-processing improvement;
- a particular data-validation technique;
- an unconventional device architecture;
- a technical fraud-detection mechanism;
- a specific improvement to transaction security;
- reduced processing latency;
- improved error detection;
- improved mobile-device operation;
- a specific way of transforming or verifying data.
The point is not merely to say that the invention is faster, more convenient, or more automated. The point is to show how the technology itself is improved.
Why This Matters for Fintech Companies
Fintech inventions often sit close to the line between business methods and technical solutions. A digital banking tool, payment workflow, risk-scoring system, or transaction platform may be commercially valuable, but the patent claims must be drafted carefully.
The USAA/PNC mobile deposit decisions show that courts may treat claims as abstract when they simply take a known financial activity and implement it using ordinary computers, mobile devices, cameras, or networks.
That does not mean fintech patents are impossible. It means the patent strategy should focus on the technical implementation.
For example, a weaker framing might be:
A mobile device captures an image of a check and transmits it for deposit.
A stronger framing would explain the specific technical process that improves image capture, validation, authentication, transmission, error reduction, or computer operation.
Related USAA/PNC Litigation
The USAA/PNC dispute involved multiple related appeals and patents. In a related Federal Circuit decision, United Services Automobile Association v. PNC Bank N.A., 139 F.4th 1332 (Fed. Cir. 2025), the court also addressed patent eligibility issues involving mobile deposit technology. The Supreme Court later declined review in that related appeal, leaving the Federal Circuit’s ruling in place. The Supreme Court docket was United Services Automobile Association v. PNC Bank N.A., No. 25-853 (U.S. May 18, 2026).
For practical purposes, the broader lesson from the litigation family is the same: fintech patents need to be drafted around the technological improvement, not merely the financial result.
Practical Takeaway
The USAA/PNC mobile deposit litigation is a warning for fintech companies, software developers, banks, startups, and inventors. A patent application should not merely describe a financial process performed on a computer or mobile device.
Instead, the application should answer several important questions:
- What technical problem is being solved?
- What specific technology solves that problem?
- How does the claimed invention improve the device, system, network, data processing, security, image analysis, or transaction workflow?
- Are those technical improvements actually reflected in the claims?
Fintech innovation can still be patentable. But the claims need to be more than a business result implemented with conventional technology. They need to capture the technical solution.
