Invalidity dossier
US 11120413
Monetary transaction system
Current assignee: Fintiv, Inc.
Added 9/24/2026, 4:16:52 AM
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Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
I'll research this patent number through web searches, then cross-reference against the full patent text provided.
Let me dig into the granted claims text and litigation/docket status specifically for this patent number.
I have good primary results. Let me now pin down the exact granted claim set of the '413 patent and check for any 2026 docket activity.
US 11,120,413 B2 — "Monetary Transaction System"
Method note: I searched the exact string 11120413/11,120,413. The granted claim text was not included in the patent document supplied to me (the provided Google Patents text is the description/definitions portion and cuts off before the claims), so I reconstructed the claim story from the Federal Circuit opinion and secondary sources, and I flag every place where I could not verify something first-hand. Two of my searches returned items that merely contain the digit string "11120413" (an HRRMC hospital charge document, and a Unified Patents page showing a US-11120413-B2 entry with a 2011‑06‑02 priority date) — I have not treated those as authority on the patent itself.
1. Bibliographic data (from the patent front page / Google Patents)
| Field | Value |
|---|---|
| Patent number | US 11,120,413 B2 |
| Title | Monetary transaction system |
| Inventors | Michael A. Liberty (Orlando, FL); Felipe Fernandes (Austin, TX) |
| Applicant / Assignee | Fintiv, Inc., Austin, TX (US) — originally Mozido, Inc. per the assignment records on the Google Patents page ("CHANGE OF NAME … Assignors: MOZIDO, INC.", July 16, 2020) |
| Application no. | 16/569,348 |
| Filing date | September 12, 2019 |
| Issue date | September 14, 2021 |
| Prior publication | US 2020/0005257 A1 (Jan. 2, 2020) |
| Priority | June 3, 2011 (provisional), with a later Aug. 10, 2011 provisional in the same chain; Google Patents lists 2011‑06‑03. This is a continuation of 15/809,872 (filed Nov. 10, 2017), which is a continuation of the earlier chain leading back to the '845 patent |
| Claim count | 7 claims, 46 drawing sheets |
| Terminal disclaimer | Yes — the front page carries "*" and "This patent is subject to a terminal disclaimer"; § 154(b) extension = 0 days |
| Anticipated expiration (Google Patents) | May 30, 2032 |
| Classifications | G06Q20/00, G06Q20/0855, G06Q20/322, G06Q20/3255, G06Q20/326, G06Q20/36, G06Q20/401, G06Q20/405, G06Q40/02, G06F9/546, H04L63/101 |
| Legal status listed | Active (Google Patents) — but see § 4 below; this status label does not reflect the 2023/2025 claim-invalidity rulings |
| Attorney / firm | Workman Nydegger |
Priority-date discrepancy to flag: the authoritative documents (the patent itself, Fintiv's own complaint, and the Federal Circuit) say the '845/'386/'413 provisionals were filed June 3, 2011 and August 10, 2011. Two third-party aggregator pages (Unified Patents, and a Fintiv-related listing) displayed 2011‑06‑02 for US‑11120413‑B2. I regard June 3, 2011 as correct and the 2011‑06‑02 entries as database artifacts, but I cannot rule out a time-zone/record-keeping basis for the one-day difference.
2. Abstract (verbatim structure, as printed on the patent)
"Embodiments are directed to monetary transaction system for conducting monetary transactions between transaction system subscribers and other entities. In one scenario, the monetary transaction system includes a mobile device that runs a monetary transaction system application. The monetary transaction system also includes a subscriber that has a profile with the system. The subscriber indicates a transaction that is to be performed with the monetary transaction system. The system further includes a monetary transaction system processor that performs the transactions specified by the subscriber including communicating with a monetary transaction database to determine whether the transaction is permissible based on data indicated in the subscriber's profile. The monetary transaction system also includes at least one entity that is to be involved in the specified transaction, where the entity has a profile with the monetary transaction system. This entity may be a person, a retail store, an agent or other entity."
Source: https://patentimages.storage.googleapis.com/b9/0c/c0/76d488038dfca2/US11120413.pdf
3. What the patent describes (plain language)
The '413 shares a specification with the '386 patent (Federal Circuit: "The '386 and '413 patents share a common specification"). It describes a mobile wallet / "mFS" platform for banked and unbanked users, built from modular back-office components (Fig. 1):
- Integration tier 101 — manages mobile-wallet sessions, keeps transaction integrity, exposes a web-services API to accept messages from channels 111 (including ISO 8583 for POS/ATM and AMQP for queue interfaces).
- Notification services 102 — SMS (SMPP), e-mail (SMTP), etc.
- Service connectors 103 to third-party systems 113; business process services 104 for workflows/audit; payment handler 105 — described in only one sentence: "Payment handler 105 is configured to wrap APIs of different payment processors, such as, for example, banking accounts, credit/debit cards or processor 121. Payment handler 105 exposes a common API to facilitate interactions with many different kinds of payment processors."
- Security services 106 (subscriber authentication), authorization services 107 (ACL-based), database 108 (customer/company accounts, transaction history, profiles, dictionaries, money containers), rules engine 109 (fees, bonuses, limits/velocity, license constraints), name matching engine 110, and transaction processor 121 (holds/loads/withdraws/deposits funds, can delegate to an external card processor or bank clearing house).
The description walks through ~30 flows (Figs. 3–19B, 20A–22J): cash-in/cash-out at agent branches, subscriber-to-subscriber and subscriber-to-non-subscriber transfers (domestic and international, using remittance firms such as MoneyGram® and MGRNs), airtime top-up, bill pay, retail purchase, micro-loans, employer direct deposit, government welfare payments, agent-administrator float distribution, agent company deposits/withdrawals, prepaid-card/PIN-based deposits, ATM withdrawals, and adding platform, third-party, bank/credit-union, and debit/credit-card accounts to a wallet. "eMoney" is the internal value representation; funds only move through the partner bank's master account for cash-in/cash-out or movement to non-participants. A recurring architectural motif is the secure, perishable withdrawal/purchase code presented to an agent branch, plus limit checks and velocity checks driven by the rules engine.
4. Independent claims — plain-language overview
Verified: the patent has 7 claims; claim 1 is independent and was the claim asserted against PayPal (complaint ¶ 69); and both claim 1 and claim 2 recite a "payment handler" term. The Federal Circuit quoted the term as it appears in the '413:
"a payment handler configured to use APIs of different payment processors including one or more APIs of banks, credit and debit cards processors, and bill payment processors." — '413 claim 1 ("see also id. claim 2 (similar)")
Source: https://cases.justia.com/federal/appellate-courts/cafc/23-2312/23-2312-2025-04-30.pdf
Claim 1 (independent, system/apparatus) — In substance: a monetary transaction system comprising (i) one or more processors; (ii) a storage system storing financial transaction details, customer profiles and money containers; (iii) an integration tier that manages mobile-wallet sessions and includes a communication API and other mechanisms to accept messages from channels; (iv) notification services that send notifications over different notification channels; (v) a payment handler configured to use APIs of different payment processors (banks, credit/debit-card processors, bill-payment processors); (vi) a security service for subscriber authentication; (vii) an entity profile for an entity involved in the specified transaction; and (viii) computer-readable media whose instructions cause the system to receive a communication message from a mobile device over one of a plurality of channels (received by the integration tier) indicating the subscriber wants to perform a digital financial transaction, validate the status of the subscriber's account by having the integration tier query account attributes from the storage system, and receive confirmation that the transaction has been performed. The "payment handler" element is the hook that decided the case (see §5).
Claim 2 (independent, method) — A method counterpart of claim 1, reciting substantially the same elements as steps ("initiating" the storage system, notification services, payment handler, security service, entity profile; receiving the communication message at the integration tier; validating the subscriber's account via the storage system; receiving confirmation) and including the same "payment handler … configured to use APIs of different payment processors" limitation.
Claims 3–7 — I could not verify the exact text of these claims first-hand from the sources retrieved. On the face of the CAFC opinion, only claims 1 and 2 are expressly identified as containing "payment-handler" terms; the opinion separately notes the payment-handler terms also "appear in Figures 1 and 20A–22J in the '413 patent." I therefore cannot state with confidence which of claims 3–7 (if any) are independent or how they depend. A closely related Fintiv application in the same family, US 2021/0350342 A1 (application 17/380,839, filed July 20, 2021, i.e., after the '413) publishes a claim set with the same "payment handler configured to use APIs …" wording in claim 1 and analogous independent claims 2 (method) and 3 (system) plus claim 4 (computer-readable media) — but I am expressly not asserting that the '413's claims 3–7 are coextensive with that publication. Treat claims 3–7 of the '413 as unverified.
5. Litigation / docket status (this is the decisive part of the patent's history)
District court (W.D. Tex., Judge Albright):
- Fintiv, Inc. v. PayPal Holdings, Inc., Civil Action 6:22-cv-00288-ADA — asserted U.S. Patents 9,892,386, 11,120,413, 9,208,488, and 10,438,196 (Fintiv's own complaint also listed 8,538,845, addressed separately/severed).
- Fintiv asserted at least claim 1 of the '413 (Compl. ¶ 69), accusing "PayPal's servers and Backend System that interacts with mobile devices."
- Judge Albright construed the "payment handler" / "payment handler service" terms as means-plus-function under pre-AIA 35 U.S.C. § 112 ¶ 6, found the specifications did not disclose sufficient corresponding structure, and held the asserted claims invalid as indefinite (Claim Construction Order, 2023 WL 5423082 (W.D. Tex. July 21, 2023)). Fintiv's motion for reconsideration was denied July 21, 2023; final judgment for PayPal entered July 28, 2023, each party bearing its own costs.
- A later action, 6:23-cv-00490 (Fintiv v. PayPal Holdings, W.D. Tex.), is also on the '413's Google Patents "family has litigation" list.
Federal Circuit:
- Fintiv, Inc. v. PayPal Holdings, Inc., appeal No. 23-2312 — decided April 30, 2025 (precedential; Judges Prost, Taranto, Stark). The court affirmed that the payment-handler terms invoke § 112 ¶ 6 and that the claims are invalid as indefinite under § 112 ¶ 2. Notably, the court equated "handler" with the nonce term "module," rejected Fintiv's extrinsic-evidence and "two-step algorithm" arguments, and emphasized that the only textual support is "nearly identical to the claim language."
On your specific request re: CAFC 2026 dockets — I found no 2026 Federal Circuit docket or decision specific to patent 11,120,413. The identified appellate proceeding for this patent (23-2312) was decided April 30, 2025. Two 2026 Federal Circuit items surfaced in my searches and are not about the '413:
- A Feb. 11, 2026 Law360 report that the Federal Circuit upheld Apple's PTAB win over Fintiv patent claims — this arose from Apple's IPRs (e.g., IPR2022-00976 on the '386 patent; IPR2023-00399 on the '488 patent), i.e., sibling patents; I did not confirm any Apple IPR against the '413.
- Feb. 13, 2026 coverage of the Federal Circuit upholding the USPTO's discretion to deny IPR institution under the "Fintiv rule" (the Apple v. Fintiv, IPR2020-00019 precedent, litigated by Intel/Google/Tesla at the Supreme Court in Nos. 26-73, 26-136). That "Fintiv" is the PTAB precedential decision named after the same company, not a docket for patent 11,120,413.
Other proceedings: PTAB IPR2023-00744 (PayPal Holdings v. Fintiv) appears in the record with demonstrative exhibits discussing the '845 patent's claims and the '488 patent; I did not verify that any IPR petition was filed against the '413 specifically, and I found none in the results retrieved.
6. Bottom line and confidence levels
- High confidence: patent number, title, inventors, assignee, application number, filing date (Sept. 12, 2019), issue date (Sept. 14, 2021), abstract, claim count (7), terminal disclaimer, the architecture described in the specification, and the fact that claims 1 and 2 recite a "payment handler" term.
- High confidence: the 23-2312 Federal Circuit affirmance (Apr. 30, 2025) and the July 2023 W.D. Tex. indefiniteness judgment invalidating the asserted '413 claims.
- Moderate confidence: the precise wording of claim 1 (reconstructed from the CAFC's quotation plus a sibling application's published claim set) and the identification of claim 2 as an independent method claim.
- Low confidence / unresolved: the exact scope and dependency structure of claims 3–7, whether every one of the 7 claims contains a payment-handler limitation, and whether any IPR has ever been instituted against the '413.
- Caveats on my sources: I worked from the patent document supplied (Google Patents text, which omits the claims) plus secondary sources; I could not query USPTO Patent Center or Patent Public Search directly in this session, so I have not independently confirmed the current USPTO assignment record, fee/maintenance status, or the complete litigation docket.
Generated 9/29/2026, 10:23:32 AM
Cases on file (1)
Group view →Specific litigation cases in our database that name US patent 11120413. The free-form analysis below may also discuss cases beyond this list.
- Fintiv, Inc. v. PayPal Holdings, Inc.filed Mar 17, 20226:22-cv-00288-ADAU.S. District Court for the Western District of Texas, Waco Divisionterminated Jul 28, 2023judgment
Defendants: PayPal Holdings, Inc.
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
I'll research litigation involving US 11,120,413 through web searches, focusing on litigation databases and court records.
Let me get more detail on the specific case numbers and filing dates, and check for any other defendants.
Let me confirm the current status of the 2023 case and check for any other defendants or 2026 developments.
Litigation involving US patent 11,120,413
Method note / caveat: I could not query PACER or the Unified Patents litigation portal directly in this session, and my last three search attempts hit a step limit. The following is built from the sources I did retrieve (Justia/CourtListener copies of the CAFC opinion, the W.D. Tex. complaint text via ai-lab.exparte.com, IPWatchdog's March 2022 docket roundup, Winston & Strawn's April 2025 client note, PatSnap's PACER-based summary, and the litigation links printed on the Google Patents front page of US 11,120,413 itself). Where sources disagree on a docket number I say so rather than picking one.
I found no litigation against any defendant other than PayPal asserting the '413, and no litigation filed in 2026 involving it. The related Apple and Walmart Fintiv disputes concern other Fintiv patents/trade secrets (e.g., the '125 patent, the '386/'488 patents) and are not '413 litigation, so I have excluded them per your instruction.
Case 1 (primary enforcement action)
| Field | Detail |
|---|---|
| Plaintiff | Fintiv, Inc. (Delaware corp., principal office Austin, Travis County, Texas) |
| Defendant | PayPal Holdings, Inc. |
| Jurisdiction | U.S. District Court for the Western District of Texas, Waco Division — Judge Alan D. Albright |
| Case No. | 6:22-cv-00288-ADA |
| Filed | March 17, 2022 (complaint dated March 17, 2022; case reported in the week of March 24, 2022) |
| Patents asserted together | U.S. 8,538,845 ('845); 9,892,386 ('386); 11,120,413 ('413); 9,208,488 ('488); 10,438,196 ('196) |
| '413-specific pleading | Count V — direct infringement of the '413 (and a corresponding indirect-infringement count); Fintiv asserted at least claim 1 of the '413, accusing "PayPal's servers and Backend System that interacts with mobile devices" |
| Outcome / status | Final judgment for PayPal entered July 28, 2023. On claim construction, Judge Albright held the "payment handler"/"payment handler service" terms to be means-plus-function under pre-AIA 35 U.S.C. § 112 ¶ 6 and, finding no adequate corresponding structure, held the asserted claims of the '386, '413, '488 and '196 patents invalid as indefinite under § 112 ¶ 2. Fintiv's motion for reconsideration was denied July 21, 2023. Each party bore its own costs. |
Case 2 (Federal Circuit appeal of Case 1)
| Field | Detail |
|---|---|
| Parties | Fintiv, Inc. v. PayPal Holdings, Inc. |
| Court | U.S. Court of Appeals for the Federal Circuit |
| Appeal No. | 23-2312 |
| Decided | April 30, 2025 (precedential; Judges Prost, Taranto, Stark) |
| Outcome | Affirmed. The court held the payment-handler terms invoke § 112 ¶ 6 and that the '413 claim 1 (and claim 2, "similar") is indefinite because the specification discloses no structure/algorithm beyond language "nearly identical to the claim language." This is the decision that effectively forecloses Fintiv from re-asserting the '413. |
Case 3 (related W.D. Tex. action also linked to the '413)
| Field | Detail |
|---|---|
| Parties | Fintiv, Inc. v. PayPal Holdings, Inc. |
| Jurisdiction | W.D. Tex., Waco Division |
| Case No. | 6:23-cv-00490 |
| Filed | 2023 (exact filing date not confirmed in the sources I retrieved) |
| '413 relevance | The complaint in 6:23-cv-00490 pleads the '413 ("The '413 Patent is titled 'Monetary Transaction System' … filed on September 12, 2019 … issued on September 14, 2021") alongside the '845/'386/'488/'196 patents |
| Status | Appears to be the same Fintiv-PayPal dispute; Winston & Strawn and PatSnap attribute the indefiniteness judgment and the 23-2312 appeal to 6:23-cv-00490, whereas the March 17, 2022 complaint (served as an IPR exhibit) sits in 6:22-cv-00288. Both numbers appear in the "Family has litigation" list on the Google Patents page for US 11,120,413. |
Contradiction flagged: the previously generated section of this analysis treated 6:22-cv-00288 as the operative case and 6:23-cv-00490 as merely "a later action." The April-2025 secondary sources (Winston & Strawn; PatSnap's PACER-derived summary) instead tie the July 2023 judgment and the 23-2312 appeal to 6:23-cv-00490. I could not resolve this first-hand. Treat the two docket numbers as two entries on the same Fintiv-PayPal W.D. Tex. docket family and do not assume which one generated the appealed judgment.
Related but not '413-specific
- PTAB IPR2023-00744, PayPal Holdings, Inc. v. Fintiv, Inc. — a post-grant challenge in the same Fintiv-PayPal dispute. Per Winston & Strawn, this PTAB proceeding invalidated a fifth patent ("Winston also invalidated the fifth patent at the PTAB"), i.e., not the '413 (the '386, '413, '488 and '196 were invalidated in district court). The appeal of that Final Written Decision is Fintiv v. PayPal, Fed. Cir. No. 25-1225 (pending as of the April 2025 reporting). I found no IPR or PGR petition ever instituted against the '413 itself.
- The Apple IPRs (e.g., IPR2022-00976 on the '386 patent) and the Fintiv v. Apple trade-secret/patent suits target other Fintiv assets, not the '413 — excluded.
Bottom line
The only litigation involving US 11,120,413 / 11120413 is the Fintiv–PayPal dispute: W.D. Tex. case 6:22-cv-00288-ADA (filed March 17, 2022) and/or the related 6:23-cv-00490, both before Judge Albright, resulting in the '413 claims being held indefinite/invalid, final judgment for PayPal (July 28, 2023), affirmed by the Federal Circuit in No. 23-2312 on April 30, 2025. I found no other defendants, no other jurisdictions, and no 2026 filings naming this patent.
Confidence: High that the sole accused infringer is PayPal and that the outcome is indefiniteness/invalidity affirmed on appeal. Moderate as to which of the two W.D. Tex. docket numbers is the operative vehicle for that judgment (sources conflict, as flagged). Low on the exact 2023 filing date of 6:23-cv-00490 and on any post-April-2025 docket activity, which I could not verify because I was unable to reach PACER, the Unified Patents portal, or Docket Navigator directly.
Generated 10/1/2026, 1:04:33 PM
Proceedings on file (0)
All PTAB activity →AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.
Current assignee: Fintiv, Inc.
No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.
PTAB challenges
AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.
I'll verify the ODP's "no PTAB activity" result against public sources before writing this up.
Let me run two final confirmation searches on the '413 specifically.
PTAB / AIA Trial Analysis — US 11,120,413 B2 ("Monetary transaction system," Fintiv, Inc.)
Sourcing note: The canonical list supplied for this analysis — the USPTO Open Data Portal structured block — returns no AIA trial proceedings for US 11,120,413. I ran independent web searches to test that result (PTAB docket mirrors, Unified Patents' PTAB case list, Federal Circuit opinions, and law-firm case reports on the Fintiv portfolio) and found no IPR, PGR, or CBM petition ever filed against the '413. I did not fabricate any proceeding numbers. Where I could not verify an outcome first-hand, I say so.
Proceedings overview
There have been zero AIA trial proceedings on US 11,120,413 — no IPR, no PGR, no CBM — so the breakdown is 0 active / 0 claims invalidated at the PTAB / 0 claims sustained / 0 settled / 0 institution denials. The bottom line for a defendant is therefore not the usual "PTAB killed it / PTAB hardened it" story: the '413's asserted claims were instead invalidated by a district court (W.D. Tex., Fintiv, Inc. v. PayPal Holdings, Inc., No. 6:22-cv-00288-ADA, 2023 WL 5423082, 2023-07-21, final judgment 2023-07-28), a ruling the Federal Circuit affirmed on 2025-04-30 in Fintiv, Inc. v. PayPal Holdings, Inc., No. 23-2312 (Prost, Taranto, Stark, JJ.) — holding the "payment handler" terms means-plus-function under pre-AIA § 112 ¶ 6 with no corresponding structure disclosed, hence indefinite under § 112 ¶ 2. So the defensive posture is closer to "the asserted claims are dead, but they died in Article III, not at the Board — and because no IPR was ever instituted on this patent, no § 315(e)(2) estoppel attaches to the '413."
That distinction matters, and I flag it explicitly because it contradicts the framing that a PTAB-invalidated claim is the operative one: for the '413 the PTAB did nothing. The invalidity precedent you rely on is a court judgment plus a precedential CAFC opinion.
Proceedings on US 11,120,413
None. There is no docket entry, no petition, no institution decision, no Final Written Decision, and no Federal Circuit appeal arising from an AIA trial on this patent. Because there are no proceedings, there are no panels, grounds, FWD dispositions, or § 315(e)(2) estoppel effects to report for the '413 itself. The subject-matter sections below (panels, grounds, FWD text, appeals) have no content to populate and I am not inventing any.
For completeness on why the record is empty: the '413 issued 2021-09-14. Its PGR window closed 2022-06-14 (nine months, § 321(c)) with no petition. CBM review was never available against it — the AIA § 18 transitional program barred new CBM petitions after 2020-09-16, before this patent even issued. So the only AIA vehicle that ever could have been used against the '413 was an IPR, and none was filed.
Adjacent Fintiv-family proceedings (context only — NOT proceedings on the '413)
I include these because a defendant facing a Fintiv demand letter will be handed the family enforcement history, and because the same defendants and the same specification are in play. Every item below is on a different patent. Do not cite any of them as PTAB rulings on the '413.
IPR2023-00744 — PayPal Holdings, Inc. and PayPal, Inc. v. Fintiv, Inc.
- Type: Inter Partes Review
- Patent challenged: U.S. 8,538,845 B2 (the '845 — same "Monetary Transaction System" family/specification lineage as the '413)
- Filed: 2023-03-24
- Status (verbatim from ODP/Unified Patents list): Final Written Decision — gloss: FWD entered; all challenged claims held unpatentable; now on appeal
- Judge panel: Kristen L. Droesch, Michael R. Zecher, George R. Hoskins
- Petition grounds: challenged claims 1–3 and 5–7 of the '845 on § 102/§ 103 grounds over Tumminaro, Keena, and related references (the trial record also devotes substantial argument to claim construction of "unbanked subscriber," the "specified payment method," and limit/velocity-check limitations). I did not retrieve the verbatim list of all Grounds numbers — do not treat the reference identification above as exhaustive.
- Institution decision: Instituted 2023-10-19 as to all challenged claims and all grounds; the Board found a reasonable likelihood PayPal would prevail on at least one of claims 1–3 and 5–7. Fintiv filed a Request for Rehearing by the Director (Paper 12, 2023-11-01) arguing the Board relied on claim constructions and arguments not set out in the Petition.
- Final Written Decision: 2024-10-02 — "Final Written Decision Determining All Challenged Claims Unpatentable 35 U.S.C. § 318(a)"; all of claims 1–3 and 5–7 of the '845 held unpatentable. Panel reasoning centers on the "unbanked subscriber" construction (the specification's explicit definition — "a subscriber that does not have (or does not have access to) a bank account or credit union account" — read in light of the intrinsic record) and the mapping of Tumminaro/Keena to the limit-check and velocity-check limitations.
- Settlement / termination: none disclosed; the case went to FWD.
- Appeal: yes. Patent Owner's Notice of Appeal filed 2024-11-25; the appeal is docketed at the Federal Circuit as No. 25-1225 (per the ex-parte case page and Winston & Strawn's April 2025 client note, which described Fintiv's appeal of the '845 FWD as "pending"). I did not verify a 2026 disposition of 25-1225 — treat its status as open.
- Defensive value: High for the '845 and its claim family, zero for the '413. § 315(e)(2) estops PayPal/PayPal, Inc. as to the '845 claims; it does not touch the '413.
IPR2022-00976 — Apple Inc. v. Fintiv, Inc.
- Type: Inter Partes Review
- Patent challenged: U.S. 9,892,386 B2 ('386 — the '413's shared-specification sibling; the CAFC in 23-2312 states "The '386 and '413 patents share a common specification")
- Filed: 2022-05-16 · Instituted: 2022-11-15 · FWD: 2023-11-08
- Status (verbatim): Final Written Decision — gloss: claims held unpatentable
- Judge panel: not verified in this session (the '744 institution decision references this petition only as a related matter)
- Petition grounds: challenged claims 1–3 of the '386; exact art/statutory basis not verified here
- Final Written Decision: held claims 1–3 of the '386 unpatentable (as reported by multiple secondary sources and by the CAFC, which describes "a final written decision by the Patent Trial and Appeal Board holding claims 1–3 of U.S. Patent No. 9,892,386 … unpatentable"). I did not retrieve the FWD text to confirm the claim-by-claim breakdown or the panel's verbatim reasoning.
- Settlement / termination: none disclosed
- Appeal: yes — Fintiv, Inc. v. Apple Inc., No. 24-1345 (Fed. Cir.). The Federal Circuit dismissed the appeal as moot on 2025-04-30, the same day it decided 23-2312, because the court's holding that claims 1–3 of the '386 are invalid as indefinite in the PayPal case left the PTAB appeal with no live controversy: "There is no dispute that our affirmance in the related case compels dismissing as moot this appeal." Source: https://fedcircuitblog.com/2025/04/30/opinions-orders-april-30-2025/ and https://cases.justia.com/federal/appellate-courts/cafc/23-2312/23-2312-2025-04-30.pdf
- Defensive value: The same "payment handler" indefiniteness theory that killed the '413's claims also produced a PTAB loss on the '386's claims 1–3. Estoppel runs against Apple on the '386, not the '413.
IPR2023-00398 — Apple Inc. v. Fintiv, Inc.
- Type: Inter Partes Review
- Patent challenged: U.S. 10,438,196 B2 ('196)
- Filed: 2022-12-22 · Instituted: 2023-07-10 · FWD: 2024-05-23
- Status (verbatim): Final Written Decision
- Judge panel: opinion opens "Before MICHAEL R. ZECHER, GEORGE R. [Hoskins]…" — full panel not verified
- Petition grounds: challenged all claims 1–22 of the '196 (claims 1, 8, 16, 21, 22 independent); grounds asserted art-based unpatentability — specific references/basis not verified
- Final Written Decision: Petitioner failed entirely. The FWD is captioned "Determining No Challenged Claims Unpatentable 35 U.S.C. § 318(a)" and states: "We determine Petitioner has not shown by a preponderance of the evidence that any of those claims are unpatentable." Source: https://www.docketalarm.com/cases/PTAB/IPR2023-00398/Apple_Inc._v._Fintiv_Inc/docs/05-23-2024-Board/Final_Written_Decision__original-31-Final_Written_Decision__original.pdf
- Settlement / termination: none; FWD on the merits
- Appeal: not verified in this session
- Defensive value: A patent-owner win — evidence that Fintiv's portfolio was not uniformly vulnerable at the Board on § 102/§ 103, and that PTAB success was achievable only on the indefiniteness flank (which IPRs can reach under Samsung v. Infobridge/§ 112 jurisprudence) or in court.
IPR2023-00399 — Apple Inc. v. Fintiv, Inc.
- Type: Inter Partes Review
- Patent challenged: U.S. 9,208,488 B2 ('488 — parent of the '196)
- Filed: 2022-12-22 · Instituted: 2023-07-10 · FWD: 2024-05-23
- Status (verbatim): Final Written Decision
- Judge panel / grounds: not verified
- Final Written Decision: A FWD was entered on 2024-05-23 (same day as the '398 FWD; the '398 FWD notes the '488 FWD is "being issued on the same day as the present Decision"). I could not verify the claim-level outcome of the '399 FWD in this session — do not assume it mirrors the '398 result.
- Settlement / termination: none disclosed
- Appeal: not verified; note that my prior section referenced a February 2026 report of the Federal Circuit upholding Apple's PTAB win over Fintiv claims on a sibling patent (
'488/'386lineage). I have not confirmed that report or its disposition here. - Defensive value: Marginal for the '413; relevant only as family lore.
Strategic summary
Claim status — the '413 was narrowed to zero by litigation, not by the Board. Because no AIA trial on the '413 ever reached institution, no claims of the '413 are CANCELED at the PTAB, none are SUSTAINED at the PTAB, and none are UNTESTED at the PTAB — the Board simply never spoke. The operative invalidity holding is judicial: the W.D. Tex. found the "payment handler" terms in '413 claim 1 (and claim 2, which the CAFC describes as "similar") means-plus-function under pre-AIA § 112 ¶ 6 with inadequate corresponding structure, and held the asserted claims invalid as indefinite; the Federal Circuit affirmed on 2025-04-30. Note the asymmetry for a defense team: the PTAB cancellation in the family covers '845 claims 1–3, 5–7 and '386 claims 1–3, while the court judgment covers the '413. And because the patent carries a terminal disclaimer and an anticipated expiration of 2032-05-30, there is no realistic path to the '413 being revived by Fintiv. The '413 remains nominally "Active" on Google Patents' status label, but that label reflects administrative status, not enforceability — and, per my earlier section, the exact text and dependency structure of claims 3–7 of the '413 remains unverified, so do not assume the indefiniteness holding reaches every claim without reading the Claim Construction Order and the 23-2312 opinion against the claim set.
Estoppel landscape — this is the single most important practical point. Section 315(e)(2) estops a petitioner (and its privies) from asserting in a civil action any ground "raised or reasonably could have been raised" in an IPR that was instituted and resulted in a FWD. No IPR was instituted on the '413, so no IPR estoppel attaches to the '413 for anyone — not PayPal, not Apple, not any third party. Conversely, the estoppel that does exist runs on other patents: PayPal is estopped as to '845 claims 1–3 and 5–7 (IPR2023-00744 FWD, subject to the pending 25-1225 appeal) and Apple is estopped as to '386 claims 1–3 (IPR2022-00976 FWD, appeal dismissed as moot). For a defendant currently receiving a demand on the '413, essentially the entire universe of prior-art grounds is still theoretically available at the Board — subject to the two-year/one-year bars and the discretionary-denial risk below.
Pattern signals. Three things stand out. (1) Same-defendant clustering: PayPal filed one IPR (on the '845) and Apple filed three (on the '386, '196, '488) — but nobody ever petitioned on the '413, even though it was in the same W.D. Tex. case and shares the '386's specification. The likely explanation is defensive economics, not ignorance: the '413 wasn't asserted until the 2022 case, PayPal's filing window was constrained, and the district court's indefiniteness ruling on 2023-07-21 mooted the need. (2) The patent owner litigated aggressively: Fintiv appealed both the district court judgment (23-2312, lost) and the '845 FWD (25-1225, pending), and also filed a Request for Rehearing by the Director in IPR2023-00744. (3) No defensive aggregator in the chain — I found no Unified Patents or other aggregator petition on any Fintiv patent; the challengers were the accused infringers themselves. (4) The irony worth flagging to clients: the "Fintiv" discretionary-denial doctrine is named after Apple Inc. v. Fintiv, Inc., IPR2020-00019 — a case involving this same patent owner, but a different patent. Do not conflate the doctrine with any proceeding on the '413.
Recommended next steps
If you are a defendant and the demand letter cites US 11,120,413, do not buy an IPR — buy a copy of the CAFC opinion. The patent's asserted claims are already invalid: quote Fintiv, Inc. v. PayPal Holdings, Inc., No. 23-2312 (Fed. Cir. 2025-04-30), which affirmed that the payment-handler terms invoke § 112 ¶ 6 and that the claims are indefinite — https://cases.justia.com/federal/appellate-courts/cafc/23-2312/23-2312-2025-04-30.pdf. Pull the underlying Claim Construction Order (2023 WL 5423082 (W.D. Tex. 2023-07-21)) and the docketalarm mirror of the '845 FWD for cross-family consistency: https://www.docketalarm.com/cases/PTAB/IPR2023-00744/PayPal_Holdings_Inc._v._Fintiv_Inc/docs/10-02-2024-Board/Final_Written_Decision__original-29-Final_Written_Decision__Final_Written_Decision_Determining_All_Challenged_Claims_Unpatentable_35_USC_sec_318a.pdf?download=true (third-party mirror; prefer PTAB E2E, https://ptacts.uspto.gov/ptabweb/, and CourtListener for the authentic records). If you share privity with PayPal or Apple, brief issue preclusion on the indefiniteness holding in addition to the precedent.
Do not file a new IPR on the '413 without a discretionary-denial analysis. A petition filed now faces a materially hostile § 314(a) environment: the USPTO rescinded the June 2022 Vidal interim guidance on 2025-02-28, restored the Fintiv framework, and the 2025-03-26 Acting Director memorandum expressly invites the Director to consider "whether the PTAB or another forum has already adjudicated the validity or patentability of the challenged patent claims" and the "settled expectations of the parties, such as the length of time the claims have been in force." The '413's claims have been judicially adjudicated invalid and have been in force since 2021 with a 2011 priority date. That combination is close to a template for discretionary denial — which would burn fee and estoppel-free status for no benefit. If a filing is nonetheless required, note that the one-year § 315(b) bar and any § 325(d) exposure must be checked against the prosecution history, and confirm the current status of the Fintiv-family appeals (25-1225; the '399 appeal) before relying on any of them.
If your goal is claim-level completeness, resolve the open items I could not verify. Specifically: (i) the verbatim text and dependency structure of '413 claims 3–7; (ii) the claim-by-claim disposition and panel for IPR2023-00399 ('488) and IPR2022-00976 ('386); (iii) the 2026 status of Federal Circuit No. 25-1225. None of these are answerable from the ODP block supplied, and none should be assumed.
If no assertion against you exists yet, the absence of PTAB activity is itself the signal. In a portfolio this heavily litigated — four separate IPRs across four sibling patents, two Federal Circuit appeals, a precedential indefiniteness ruling — the total absence of any petition against the '413 is best explained by the claims having been invalidated in court before anyone needed to file. That is a defensive asset, not a gap in the record.
Generated 10/1/2026, 1:04:42 PM
Assignment history
Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.
I'll research the assignment chain for US 11,120,413 through multiple sources.
Found the core chain-of-title statement. Now let me pin down the specific reel/frames for the '413 and check for later liens or transfers.
Let me verify the '413's own file-wrapper chain-of-title statement and check for post-issuance transfers.
Assignment & Ownership Analysis — US 11,120,413 B2
Method caveat (read first): I could not execute a live query against USPTO Assignment Center in this session — I have web search only, and no browser session against assignmentcenter.uspto.gov. Every reel/frame below is therefore taken second-hand from primary documents in the public record (the 37 CFR 3.73(b)/(c) chain-of-title statements filed in this family, PTAB and district-court exhibits containing Mozido/Fintiv file-wrapper pages, and Google Patents legal-events listings). The reel/frame numbers are reliable as what the recorded documents say; they are not a substitute for a direct Assignment Center pull, and I flag two internal contradictions below. Verify at https://assignmentcenter.uspto.gov/ (patent number 11120413) or the legacy index at https://assignment.uspto.gov/patent/index.html.
Inventors
| Inventor | Residence (per patent) | Employer at filing | Notes |
|---|---|---|---|
| Michael A. Liberty | Orlando, FL | Mozido (founder; the applicant is "In re application of Mozido, LLC / Mozido, Inc." throughout the family) | Liberty founded Mozido in 2008 and was its public face and chairman. He is the assignor of record on the very first link in the chain (reel 044096/0448, eff. 2013-11-07). He was indicted in the District of Maine in February 2019 for investment fraud relating to his Mozido fundraising, and the SEC had charged him in 2018. He was no longer a Mozido/Fintiv officer when the corporate name change to Fintiv was signed. He reportedly remains a Fintiv shareholder. |
| Felipe Fernandes | Austin, TX | Mozido (Austin HQ; specific title not verified) | Unlike Liberty, Fernandes does not appear as an assignor in the 2013 links. His inventor assignment to Mozido, Inc. is recorded at reel 051882/0018 with an effective date of 2020-02-03 — roughly 9 years after the 2011 priority date and after the Mozido→Fintiv rename (see timeline). |
Unusual pattern — flag: The two inventors' rights were not cleaned up at the same time. Liberty assigned in 2013, but Fernandes' assignment carries a 2020 effective date and was recorded into the same 2019–2020 cluster (reel 051882/0018). Combined with the corporate rename recorded at reel 051276/0649, this is the classic standing/ownership clean-up that precedes assertion — Fintiv sued Apple in December 2018 and PayPal (naming this patent) in April 2022. I found no evidence of either inventor departing the assignee within 12 months of filing in a way that preceded a fire-sale; the distortion here is the reverse — the corporate entity shed the operating business while the inventors' paper trailed behind. Note also that by the time the Fernandes assignment was recorded, the assignee it names ("Mozido, Inc.") had already been renamed Fintiv, Inc. — see contradiction #2 below.
Original assignee
Entity named on the face of the issued patent: Fintiv, Inc., Austin, TX. Because the patent issued 2021-09-14, the assignee printed on the front page is the post-rename entity; the original assignee at filing (provisional 2011; application 2012) was Mozido, LLC, converted/renamed to Mozido, Inc.
- What Mozido was: a mobile-payments / mobile-wallet and loyalty company that built the "mFS" platform described in this specification. It was briefly a high-flying fintech: it raised roughly $300 million, was reported valued at about $5.6 billion, acquired the Chinese payment processor PayEase and SK C&C's CorFire subsidiary (both 2014), and was engaged in discussions with Walmart/MCX. Investors included funds managed by Wellington Management and Julian Robertson; former Google CEO Eric Schmidt was associated with its funding.
- Did it ship a product embodying the claims? It built and marketed a commercial mobile payments/loyalty product (the CorFire mobile-wallet business), so on the looser reading there was an operating business. However, I could not verify any shipping product that practices the specific "payment handler" limitation of claim 1 — the limitation the courts held indefinite.
- Current status: operating in a reduced, enforcement-oriented form. Mozido sold its most meaningful unit, PayEase, in 2018 to repay a debt obligation; founder Liberty was indicted in 2019; the entity was renamed Fintiv (Delaware filing signed by president Charlie Wiggs, after the SEC charged Liberty). Fintiv today describes itself as continuing mobile payments/loyalty products but has publicly "formed a division to consolidate its patents and enforce them." Forbes, 2019-03-25 (link).
- Bankruptcy / dissolution: Not established. I found evidence of severe financial distress and multi-front litigation (including Texas state-court litigation with Walmart/MCX), but no Chapter 7/11 filing for Mozido and no bankruptcy-court transfer recorded against the '413. Do not assert bankruptcy without a docket.
- Pennsylvania note: Fintiv, Inc. was later identified as the company behind the PTAB's "[NHK-]Fintiv rule." Separately, Donald Trump Jr. reportedly owns 5% of Fintiv (ip fray, 2025, link, citing The Information).
Assignment timeline
The recorded chain, as recited in Fintiv's own STATEMENT UNDER 37 CFR 3.73(b) (child application 13/484,199, "Monetary Transaction System," signed /John C. [Stringham], February 20, 2020) and in Google Patents legal-events listings for this family, is:
2013-11-07 (executed) / recorded 2019–2020 — Reel 044096/0448
- Conveyance: Assignment of assignor's interest
- Assignor: Michael A. Liberty
- Assignee: Mozido, LLC
- Correspondent: John C. Stringham, Reg. No. 40,831, Workman Nydegger, Salt Lake City, UT (Customer No. 22913, 801.533.9800). Recurs on every link in this chain and on the underlying prosecution — see signal 3.
- Context: Founding/startup assignment — the inventor's rights go into the operating company (Mozido, LLC).
2013-11-23 (executed) / recorded 2019–2020 — Reel 051265/0352
- Conveyance: Assignment
- Assignor: Mozido, LLC
- Assignee: Mozido, Inc.
- Correspondent: John C. Stringham, Workman Nydegger. Recurrence.
- Context: Internal reorganization — LLC to Inc. conversion/transfer within the same enterprise.
2019-04-18 (effective) / recorded on or before 2020-02-20 — Reel 051276/0649
- Conveyance: CHANGE OF NAME (not an assignment)
- Assignor: Mozido, Inc.
- Assignee: Fintiv, Inc.
- Correspondent: John C. Stringham, Workman Nydegger. Recurrence.
- Context: Change of name only — same Delaware corporation, rebranded from Mozido to Fintiv after the founder's SEC/criminal exposure; functionally the pivot from operator to enforcer, but legally not a transfer of title.
2020-02-03 (executed) / recorded ~2020-07-16 — Reel 051882/0018
- Conveyance: Assignment of assignor's interest (inventor)
- Assignor: Felipe Fernandes
- Assignee: Mozido, Inc. (as named in the recording)
- Correspondent: presumably John C. Stringham, Workman Nydegger (same Customer No. 22913 family of filings). Recurrence.
- Context: Standing/ownership clean-up — the second inventor's rights are papered 9 years after priority, in the same 2019–2020 recording cluster, after the corporate rename.
No post-issuance assignment to any litigation entity was found. Fintiv, Inc. remains the assignee of record as of the sources retrieved (Google Patents: "Current Assignee: Fintiv Inc"; the 2025 N.D. Ga. RICO/trade-secret complaint lists Fintiv at 801 Barton Springs, Austin, TX 78704). That is itself a finding: there is no "Fintiv IP Holdings LLC" or similar shell in the recorded chain.
Two contradictions to resolve at Assignment Center
- Duplicate reel/frames for the same two 2013 links. The 3.73(b) statement filed 2020-02-20 cites Liberty→Mozido, LLC at reel 028698/0135 and Mozido, LLC→Mozido, Inc. at reel 031769/0677, whereas the Google Patents legal-events listing for this family cites the same two transactions at reel 044096/0448 and reel 051265/0352. These look like two separate recordation events (the originals recorded ~2012/2014 for application 13/484,199; re-recorded 2019/2020 across the continuation family including 16/569,348). Confirm which reel/frame actually bears the '413's application number.
- Date of the change-of-name recording. Google Patents shows the Mozido, Inc.→Fintiv, Inc. CHANGE OF NAME event dated 2020-07-16, but the 3.73(b) statement dated 2020-02-20 already cites that exact document (reel 051276/0649) as recorded, and a third-party docket index shows a 2019-12-26 recording date for the Fintiv rename across the portfolio. The executed/effective date is 2019-04-18. Treat 2020-07-16 as Google's indexing artifact and flag for verification.
Also noted: the '413's own Google Patents legal events list the Fernandes assignment and the change of name both with a 2020-07-16 date, i.e. the same date — consistent with a single batch recording rather than independent transactions.
Timeline diagram
timeline
title Ownership of US 11120413
2011 : Priority provisional filed by Mozido
2013 : Liberty assigns rights to Mozido LLC
: Mozido LLC transferred to Mozido Inc
2019 : Mozido Inc renamed Fintiv Inc
: Continuation filed as 16 569 348
2020 : Fernandes assignment confirmed to Mozido
: Chain of title statement filed
2021 : Patent issued on September 14
2022 : PayPal suit asserts the 413
2025 : Federal Circuit affirms invalidity
NPE / troll-pattern signals
1. Shell-entity transfer — not present (as recorded). The only link to the enforcement entity is a Delaware change of name, reel 051276/0649 (eff. 2019-04-18) — the same legal person, not an LLC formed to hold title. No "IP / Patents / Licensing / Holdings / Ventures" suffix appears anywhere in this chain, and no post-issuance transfer exists to score. Caveat for the record: the business was wound down and the shell repurposed, but the recorded instrument is a name change, and the instructions say not to score on naming alone.
2. Known asserter in the chain — present. Fintiv, Inc. is the assignee of record (reel 051276/0649) and is a well-known high-frequency plaintiff: eponym of the PTAB "Fintiv rule" (Apple v. Fintiv, IPR2020-00019); asserted the '413 against PayPal in 6:22-cv-00288-ADA (W.D. Tex., Apr. 2022) and the sibling '386 against Apple in 1:21-cv-00896; described by Forbes (2019-03-25) as having "formed a division to consolidate its patents and enforce them" and by ip fray (2025) as a "patent licensing firm that actively enforces." The '413's own Google Patents page carries Unified Patents litigation links to 6:22-cv-00288, 6:23-cv-00490 (W.D. Tex.) and CAFC 23-2312. It is not on the classic Acacia / Marathon / IV / Pendrell lists, so I score this as one strong signal, not two.
3. Repeat correspondent across the chain — present, strongly. John C. Stringham, Reg. No. 40,831, of Workman Nydegger (Customer No. 22913, 801.533.9800) is correspondent of record on every recorded document in this chain — reels 044096/0448, 051265/0352, 051276/0649, 051882/0018 (and the parallel 028698/0135 and 031769/0677 recordations) — and also on the underlying prosecution (e.g., app 13/680,824, filed via "Filer: John C. Stringham/Rachelle Turner," Apr. 14, 2014). He personally signed the 3.73(b)/(c) chain-of-title statements. Precision note required by the brief: Workman Nydegger is a large general-practice IP firm that does substantial operating-company work, so a single appearance would prove nothing — the finding here is the recurrence across all four links plus prosecution under one attorney and one Customer Number.
4. Cascading transfers — present. Four recorded instruments move this family from Liberty → Mozido, LLC → Mozido, Inc. → Fintiv, Inc., plus the Fernandes inventor assignment, and all of them were recorded in a single 2019–2020 cluster even though two carry back-dated 2013 effective dates (2013-11-07; 2013-11-23). Same correspondent, same Customer No. 22913. That is a textbook pre-assertion housekeeping sweep.
5. Pre-litigation transfer — not present on the strict six-month test. The last recorded link (Fernandes, reel 051882/0018, eff. 2020-02-03) was on the record ~21 months before Fintiv v. PayPal (Apr. 2022), the first suit naming the '413; the name change (eff. 2019-04-18) preceded it by ~3 years. So the chain is pre-assertion housekeeping, not a filing-eve scramble. Score not present and do not stretch the date.
6. Bankruptcy fire-sale — unclear / not established. Mozido was in acute distress (PayEase sold in 2018 to repay debt; founder indicted Feb. 2019; SEC action; Texas litigation), but no Mozido Chapter 7/11 filing and no bankruptcy-court transfer appears in this chain. The recorded path runs through a name change, not a receivership sale. Do not score without a docket.
7. Privateering — not present. There is no separate operating-company benefactor asserting through a proxy: Mozido and Fintiv are the same Delaware corporation, and Fintiv litigates in its own name. (The inverse — an operator renaming itself and pivoting to enforcement — is what Forbes and ip fray describe, but that is not classic privateering.)
8. Defensive aggregator — not present. No RPX / AST / LOT / Unified / OIN entity appears anywhere in the chain. The '413 is being actively asserted, and its siblings' claims have been invalidated at the PTAB and affirmed by the Federal Circuit rather than neutralized by aggregation.
Verdict
NPE — high confidence.
The assignee of record is Fintiv, Inc., established by the Mozido, Inc. → Fintiv, Inc. change of name at reel 051276/0649 (eff. 2019-04-18) and recited as the third link in Fintiv's own 37 CFR 3.73(b) chain-of-title statement filed 2020-02-20 — an entity that has publicly reorganized around patent enforcement and has asserted this patent against PayPal and its siblings against Apple and Walmart. Two strong signals are satisfied: known asserter (Fintiv, the eponym of the Fintiv rule and a Unified Patents–tracked repeat plaintiff) and repeat correspondent (Workman Nydegger's John C. Stringham on all four recorded links plus prosecution), reinforced by the cascading/pre-assertion recording cluster of reel 044096/0448, 051265/0352, 051276/0649 and 051882/0018. The verdict is high rather than merely moderate because the enforcement posture is corroborated by public reporting and by the litigation record itself, not merely inferred from corporate names.
Verify the reel/frame entries and the two flagged contradictions (duplicate 2013 reel/frames; the 2019-04-18 vs 2020-07-16 recording date) at: https://assignmentcenter.uspto.gov/ — search patent number 11120413.
Generated 10/1/2026, 1:05:07 PM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll search for the granted claims and cited references for this exact patent number.
Let me pull the actual "References Cited" table for this exact patent number.
Let me drill into the patent's own citation table, including the Google Patents/Justia reference lists.
Method note and what I could / could not verify — read this first
I was asked to search the USPTO database. I do not have direct query access to USPTO Patent Center, Patent Public Search (PatFT/AppFT), or the USPTO Open Data API in this session — consistent with the caveat recorded in my earlier sections of this analysis. What I did do this round:
- Retrieved the front-page "References Cited" block of US 11,120,413 B2 from the scanned/published patent PDF (
patentimages.storage.googleapis.com/b9/0c/c0/76d488038dfca2/US11120413.pdf) — this is the authoritative (56) list, printed on the face of the patent. - Retrieved the Justia record page for patent 11120413 (
patents.justia.com/patent/11120413), which reproduces the foreign-document and non-patent-literature citation lists and prosecution History/Office Action list. - Did not retrieve the full, untruncated two-column U.S. patent list (the OCR snippet I recovered cuts off mid-column at "7,1…").
Three caveats you must carry through the analysis below:
- Citation ≠ rejection. Everything in section A–C is a document cited (mostly by the examiner) during prosecution, prior to grant. I found no § 102 rejection that carried into the granted claims; the patent issued over these references. The reference set tells you what the examiner thought was relevant, not what anticipates.
- I could not read the substance of most references. Where I am not confident of a reference's technical content, I say so and decline to invent a description or a claim mapping. That is why several rows in the table below have "content not verified" rather than a fabricated summary.
- Two citation universes must not be conflated. (i) References on the face of the '413. (ii) Prior art asserted against the '413's siblings in IPR/litigation (e.g., Tumminaro/Obopay in IPR2023‑00744 against the '845). They overlap only partly, and I could not verify whether Tumminaro is on the '413's own front page.
Correction to a previously generated section (flagged per instructions)
My earlier litigation section stated the W.D. Tex. indefiniteness holding came from a single Claim Construction Order dated July 21, 2023. The PACER/PubSnap record surfaced this round refines that and I flag the contradiction:
- Claim Construction Order: January 9, 2023 (6:22‑cv‑00288, D.I. 60) — found "payment handler"/"payment handler service" indefinite for '386 claims 1–3, '413 claims 1–2, '196 claim 1 (the '488 claim 1 was added later).
- July 7, 2023 — unopposed motion granted severing the '386, '413, '488, '196 into 6:23‑cv‑00490 (D.I. 103).
- July 21, 2023 — Memorandum denying reconsideration, this time also listing '488 claim 1 (6:23‑cv‑00490, D.I. 105).
- July 28, 2023 — final judgment; the operative sentence names "'413 patent claims 1‑2" as invalid under § 112 ¶ 6.
Two things follow that matter for your question. First, the '413's adjudicated claims are exactly claims 1 and 2 — this independently corroborates my earlier "moderate confidence" reconstruction and upgrades it: claims 1–2 are the asserted claims, and claims 3–7 remain unverified by any source I retrieved. Second, the '413 died on § 112 ¶ 6 indefiniteness, not § 102 — so no tribunal has ever made a § 102 finding on it.
A. U.S. patent documents cited on the face of the '413 (verified, partial)
Recovered verbatim from the (56) block. Dates are as printed; I have not re-derived them from USPTO. The column is truncated in my source after the "7,1xx,xxx" series, so the list below is incomplete — treat it as the first tranche, not the whole (56) list.
| # | U.S. Patent | Date | Brief description | Claims it potentially anticipates under § 102 (analyst view) |
|---|---|---|---|---|
| 1 | 5,221,838 A — Gutman et al. | 6/1993 | Portable electronic wallet (stored-value/purse-type disclosure) — moderate confidence in this characterization | Only the stored-value / "money container" aspects; cannot alone anticipate claims 1 or 2 (no integration tier, no notification services, no payment handler abstraction). At most relevant to a dependent claim reciting a stored value account. |
| 2 | 5,717,374 A — Smith | 2/1998 | Not verified — I will not characterize | Not assessed |
| 3 | 5,828,739 A — Nakanishi | 10/1998 | Not verified | Not assessed |
| 4 | 5,991,749 A — Morrill | 11/1999 | Not verified | Not assessed |
| 5 | 6,021,397 A — Jones et al. | 2/2000 | Financial-transaction-system art (bank/processor messaging) — moderate confidence | Potentially relevant to the "payment handler configured to use APIs of different payment processors" idea only conceptually; no claim chart possible without reading the reference. |
| 6 | 6,175,823 B1 — Van Dusen | 1/2001 | Not verified | Not assessed |
| 7 | 6,185,545 B1 — Resnick | 2/2001 | Not verified | Not assessed |
| 8 | 6,199,762 B1 — Hobbs | 3/2001 | Not verified | Not assessed |
| 9 | 6,250,557 B1 — Forslund | 6/2001 | Not verified | Not assessed |
| 10 | 6,256,614 B1 — Wecker et al. | 7/2001 | Not verified | Not assessed |
| 11 | 6,356,908 B1 — Brown et al. | 3/2002 | Not verified | Not assessed |
| 12 | 6,415,156 B1 — Sadelmann | 7/2002 | Not verified | Not assessed |
| 13 | 6,480,957 B1 — Liao et al. | 11/2002 | Not verified | Not assessed |
| 14 | 6,487,403 B2 — Carroll | 11/2002 | Not verified | Not assessed |
| 15 | 6,622,015 B1 — Himmel | 9/2003 | Not verified | Not assessed |
| 16 | 6,697,839 B2 — Sim | 2/2004 | Not verified | Not assessed |
| 17 | 6,714,797 B1 — Rautin | 3/2004 | Not verified | Not assessed |
| 18 | 6,732,179 B1 — Brunn et al. | 5/2004 | Not verified | Not assessed |
| 19 | 6,736,232 B2 — Gobburu | 5/2004 | Not verified | Not assessed |
| 20 | 6,819,219 B1 — Bolle | 11/2004 | Not verified | Not assessed |
| 21 | 6,840,448 B2 — Fukushima | 1/2005 | Not verified | Not assessed |
| 22 | 6,865,575 B1 — Anilai et al. | 3/2005 | Not verified | Not assessed |
| 23 | 6,873,974 B1 — Schutzer | 3/2005 | Not verified | Not assessed |
| 24 | 6,959,939 B2 — Tobin | 9/2005 | Not verified | Not assessed |
| 25 | 6,957,342 B2 — Vatanen | 9/2005 | Not verified | Not assessed |
| 26 | 7,016,532 B2 — Boneyk | 3/2006 | Not verified | Not assessed |
| 27 | 7,024,174 B2 — Nagy (printed with an asterisk, ...... G06Q 20/04) |
4/2006 | Not verified; the asterisk/IPC annotation marks it as a substantively relevant cited document | Not assessed. The G06Q 20/04 IPC is the "payment schemes / using a payment card" subclass — i.e., the examiner flagged it against the payment-processing aspects. |
| 28 | 7,024,390 B1 — Mori et al. | 4/2006 | Not verified | Not assessed |
| 29 | 7,054,430 B2 — Lynam | 5/2006 | Not verified | Not assessed |
| 30 | 7,065,341 B2 — Kamiyama et al. | 6/2006 | Not verified | Not assessed |
| 31 | 7,069,001 B2 — Rupp | 6/2006 | Not verified | Not assessed |
| 32 | 7,089,208 B1 — Levchin | 8/2006 | Not verified (Levchin = PayPal co-founder; consistent with payments-processor art) | Not assessed |
| 33 | 7,059,350 B1 — Mann | 8/2006 | Not verified. Note the out-of-order date (7,059,350 after 7,089,208) — this is how it prints; I am not auto-correcting it. | Not assessed |
| 34 | 7,1…… | — | Column truncated in my source | — |
Important structural observation: every recovered U.S. reference is pre‑2011 (earliest June 1993, latest mid‑2006), i.e., all comfortably before the June 3, 2011 priority date and thus facially available under pre‑AIA § 102(a)/(b). But the list is an examiner's list, and the recovered subset is heavily weighted toward stored-value/wallet and bank-messaging art — the features the examiner was searching — not toward anything resembling the "integration tier + notification services + payment handler + security service" combination that claim 1 actually recites.
A citation set I explicitly refuse to attribute to the '413: I encountered a U.S. publication list beginning 20040235450 Rosenberg (Nov. 25, 2004) and continuing through the Tumminaro family (20070244811, 20070255620, 20070255652, 20070255653), Rackley (20080006685, 20080010191/196/204/215, 20080040265, 20080126145), Fisher (20080052192, 20090132362, 20090144161, 20090156190), Pharris (20090254440/479, 20090281904), Kumar (20100088188) and others. That list was served from a Justia page whose URL is patents.justia.com/patent/9842325 — i.e., US 9,842,325, a different patent. It is a plausible sibling citation list, and several of those names (Tumminaro, Fisher, Pharris, Rackley) are exactly the references PayPal later deployed in IPR, but I cannot state that any of them appears on the face of the '413. Do not source the '413's § 102 exposure from that list without checking Patent Public Search.
B. Foreign patent documents cited (from the Justia record for patent 11120413)
| Jurisdiction | Documents as listed |
|---|---|
| JP | 2001357164 (Dec. 2001); 2002‑99716 (Apr. 2002) |
| KR | 10‑2002‑0065989 (Aug. 2002); 10‑2003‑0068603 (Aug. 2003); 10‑2007‑0092400 (Sept. 2007) |
| WO | 199834203 (Aug. 1998); 9913636 (Mar. 1999); 0171627 (Sept. 2001); 2001097118 (Dec. 2001); 2002071354 (Sept. 2002); 2003012717 (Feb. 2003); 2004010393 (Jan. 2004); 2004023353 (Mar. 2004); 2004053640 (June 2004); 2004088641 (Oct. 2004); 2005079254 (Sept. 2005); 2005086593 (Sept. 2005); 2007145500 (Dec. 2007); 2008008735 (Jan. 2008); 2008/046161 (Apr. 2008); 2008005018 (Oct. 2008); 2012025824 (Mar. 2012); 2013009444 (Jan. 2013); 2013009446 (Jan. 2013); 2013025273 (Feb. 2013); 2013/052729 (Apr. 2013); 2013078176 (May 2013); 2013166174 (Nov. 2013) |
This is the single most analytically important fact in the whole § 102 question, and it cuts against the references: eight of the listed WO documents (bolded above) were published after the '413's asserted June 3, 2011 priority date. If the '413's priority chain to 61/493,064 (June 3, 2011) and 61/522,099 (Aug. 10, 2011) is perfected — and the front page prints both provisionals, so it is at least asserted — then:
- A publication dated Mar. 2012 or later is not § 102(a) or § 102(b) art against claims entitled to the 2011 date, because it is not "before the invention by the applicant" and not more than one year before the U.S. filing date.
- Such a document could only qualify as pre‑AIA § 102(e) art, and only if it is a PCT publication designating the United States, published in English, with an international filing date before June 3, 2011. Based on publication dates in 2012–2013, several of these are likely too late even on that theory — but I have not retrieved their international filing dates, so I state this as a flag, not a conclusion.
- Practical reading: these WO documents were almost certainly cited to Fintiv's own later-filed family members (the '413 is a continuation; its prosecution History in the Justia record includes Office Actions on 15/809,872 and 16/550,029), and were carried into the '413's face-list as part of the family's cumulative citation set. Do not treat them as anticipation candidates for the '413's claims.
The genuinely pre-2011 foreign art (JP 2001/2002, KR 2002/2003/2007, WO 1998–Oct. 2008) is facially available under § 102(a)/(b), but I did not read any of it and cannot chart it against claims 1–7.
C. Non-patent literature cited
Verified as listed on the Justia record for patent 11120413:
- Standards / vendor disclosures: GlobalPlatform, Card Specification, Version 2.2, published Mar. 2006; Motorola M‑Wallet Solution brochure (2006); Boneyk-type NFC/wallet art rounds out this theme.
- Academic/technical papers (pre-2011): Chen & Adams, "Short-Range Wireless Technologies with Mobile Payments Systems," ICEC 2004; Labrou et al., "Wireless Wallet," Mobiquitous 2004; Valcourt et al., "Investigating Mobile Payment," WiMob 2005; Gao et al., "P2P‑Paid: A Peer-to-Peer Wireless Payment System," WMCS 2005; Edwin, "Technobiography," 2004; Wei et al. (2005); Clarke (2008); Sykes et al. (Nov. 2010).
- M‑PESA / mobile-money-for-the-unbanked literature — the dominant block: Medhi et al. (2009); Mbogo (2010); Jack & Suri (2010, including NBER WP 16721); Comninos et al. (2008); Lonie (Jul. 2010); Plyler et al. (Mar. 2010); Hughes & Lonie (2007); Omwansa (2009); Mas & Morawczynski (2009); Porteous (2007 and 2006); Morawczynski & Pickens (CGAP, Aug. 2009); Ivatury & Mas (CGAP No. 46, Apr. 2008); Sultana; Rice, The Guardian (Mar. 20, 2007); PYMNTS (Aug. 2010); Graham, BBC (Nov. 22, 2010); plus popular-press items on the RadioShack/Trumpet Mobile prepaid money-transfer launch (all Apr. 2008) and a 2009 Mozambique piece.
- Search reports / EPO: International Search Reports and Written Opinions for PCT/US2012/040131, /043321, /43458, /058849, /066013, PCT/US2013/039100, PCT/US2015/58886; European Search Reports for EP12824344 and EP12851211.
- Prosecution documents of sibling applications (listed as "cited"): Office Actions on 13/484,199, 13/527,466, 13/528,720, 13/680,824, 13/874,192, 13/964,707, 14/012,822, 14/213,543, 14/341,605, 14/928,105, 14/928,521, 15/201,152, 15/809,872 (Apr. 23, 2020; Jan. 7, 2021 Final; Jun. 24, 2021) and 16/550,029 (Jun. 4, 2021). Note these are prosecution history of the direct parent and grandparent, not prior art.
- Concurrently the record lists Fintiv's own provisional applications (61/493,064; 61/522,099; 61/498,957; 61/499,927; 61/562,301; 61/641,677; 61/694,118; 61/862,437; 62/075,657) — these are priority documents, not § 102 art against the '413 (they are the applicant's own earlier filings; § 102(b)/§ 102(e) do not reach an applicant's own priority provisionals for the same subject matter).
§ 102 relevance of the NPL block: the M‑PESA corpus (2007–2010) is the most serious § 102(b) exposure in the entire cited set for broad unbanked-mobile-money concepts — agent-based cash-in/cash-out, eMoney-equivalents, subscriber profiles, and SMS/USSD transaction instructions. But even M‑PESA literature does not describe an "integration tier" that "manages mobile wallet sessions," a discrete "notification services" component, or a "payment handler configured to use APIs of different payment processors including one or more APIs of banks, credit and debit cards processors, and bill payment processors." So it is a § 102 candidate only against claims that reduce to mobile-money-over-a-handset-plus-agent-network — arguably the '845-family claims (hence its use in the '845/IPR discourse), and not against '413 claims 1–2 as written.
D. § 102 framework and the honest bottom line
Governing statute — pre-AIA § 102. The '413 was filed Sept. 12, 2019, but its claims assert an effective filing date of June 3, 2011 (provisionals 61/493,064 and 61/522,099 printed on the face). Because the claims' effective filing date precedes March 16, 2013, pre-AIA §§ 102/103 govern. This is corroborated by the district court's and the Federal Circuit's application of pre-AIA 35 U.S.C. § 112 ¶ 6 to these very claims. Practical consequence: the critical date is June 3, 2011, and the § 102(e)/§ 102(g) edge cases all key off that date. I flag that the 2011‑06‑02 entries on two third-party aggregator pages (see my earlier section) would, if literally correct, be a one-day difference with no effect on any of the analysis here.
Per-claim exposure, as honestly as I can state it:
| Claim | Verified status | § 102 exposure from the cited set |
|---|---|---|
| Claim 1 (independent system) | Verified to recite the "payment handler configured to use APIs of different payment processors including … banks, credit and debit cards processors, and bill payment processors" limitation | No reference I recovered comes close to a full § 102 anticipation. Anticipation requires every element in a single reference. The integration-tier + notification-services + payment-handler + security-service + entity-profile combination is not disclosed, on the face of anything I saw, in a single pre‑June‑2011 document. Claims 1–2 in any event were held invalid as indefinite under § 112 ¶ 6 (W.D. Tex. 2023, aff'd Fed. Cir. Apr. 30, 2025, No. 23‑2312) — so no § 102 ruling exists. |
| Claim 2 (independent method) | Verified to contain the same payment-handler limitation ("similar") | Same as claim 1. |
| Claims 3–7 | Unverified — I could not obtain their text from any source this session | Cannot be assessed. I decline to assign § 102 exposure to claims whose language I have not read. |
The three candidate § 102 theories I would investigate first if I had USPTO text access, stated as leads rather than findings:
- Gutman 5,221,838 + the stored-value-account dependent claims. The only recovered reference I can characterize with any confidence as an electronic-wallet/stored-value disclosure. § 102 exposure would be to a dependent claim reciting a stored value account or money container — not to claims 1–2.
- The M‑PESA NPL corpus under § 102(b). All items are 2007–2010, i.e., more than one year before the '413's earliest U.S. non-provisional filings, so facially § 102(b) art. Use for unbanked/agent/eMoney limitations only.
- Jones 6,021,397 (and the
G06Q 20/04-annotated 7,024,174) for the processor-interface concept. The examiner's own IPC annotation on 7,024,174 signals this was the line of art used against the payment-processing elements. Whether either discloses "APIs of different payment processors" as an abstraction layer is exactly what I could not verify.
What is not on the record, and why that matters. I found no IPR petition instituted against the '413, and no § 102 rejection that survived into the granted claims. The '413's invalidity is purely a § 112 ¶ 6 artifact of a specification that supported "payment handler" with language "nearly identical to the claim language." A § 102 attack is therefore academic for claims 1–2 — but not for claims 3–7, which are unadjudicated and whose text remains unknown to me.
E. Confidence ledger
- High: the existence and identity of the (56) U.S. references listed in § A rows 1–33, their printed dates, and the fact that the front-page list is truncated in my source; the foreign-document and NPL lists in § B–C as listed on the Justia record for patent 11120413; the June 3, 2011 / Aug. 10, 2011 provisional dates printed on the patent; that the adjudicated '413 claims are claims 1–2 only; that the '413 was invalidated under § 112 ¶ 6 (not § 102) and affirmed Apr. 30, 2025.
- Moderate: the characterizations of 5,221,838 (electronic wallet) and 6,021,397 (financial transaction system); my reading that the 2012–2013 WO documents are not § 102(a)/(b) art against a June 3, 2011 priority date.
- Low / explicitly unresolved: the technical content of the remaining ~30 U.S. references; the identity of any U.S. patent publications cited on the '413's face (I could not attribute the Tumminaro/Fisher/Pharris/Rackley list to this patent — it came from a different patent's page); the text and dependency structure of claims 3–7; whether any IPR was ever filed or instituted against the '413; and whether the '413's citation list differs materially from its parent 15/809,872's.
- Not done this session, and you should not assume otherwise: I never queried USPTO Patent Center, Patent Public Search, or the USPTO Open Data API; I did not read the full (56) list; and I did not verify the § 102 availability dates of any single reference against its actual filing/publication record.
If you want, the next step I'd take is to pull the untruncated (56) block from the USPTO full-text image of US11120413 and the file wrapper for 16/569,348, so the § A list can be completed and the claims 3–7 text obtained — those are the two gaps that block a real § 102 chart.
Generated 10/1/2026, 1:05:14 PM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
I'll research the prior art cited on the '413 patent's Google Patents page and related prosecution history, since the Prior Art section wasn't included in the text supplied to me.
I have the cited-references list partially. Let me pin down the specific prior-art references (including foreign documents, NPL, and the PCT search-report art) and the "Cited By"/"Similar Documents" entries on the '413's page.
Obviousness Analysis — US 11,120,413 B2 under 35 U.S.C. § 103
Method note and sourcing caveat (read first)
The "Prior Art section of this page" was not included in the material supplied to me. The patent text I was given is the Google Patents description/definitions body and cuts off before the claims; the front-page "(56) References Cited" list and the Google Patents "Prior Art / Similar Documents" tab content were not reproduced. I therefore reconstructed the prior-art set from three sources, and I label each item's provenance:
- The '413 front page per se, retrieved via search of the issued-PDF text (partial list only — the search extract shows entries beginning
5,221,838 A 6/1993 Gutman et al.and5,717,374 A 2/1998 Smith, but truncates). Source: https://patentimages.storage.googleapis.com/b9/0c/c0/76d488038dfca2/US11120413.pdf - The International Search Report / Written Opinion for PCT/US2012/040131, published as WO 2013/025273 — the same specification family as the '413. Source: https://patentimages.storage.googleapis.com/cc/13/89/f29f48866a6379/WO2013025273A1.pdf (also reproduced in the '488 file-history exhibit at https://www.docketalarm.com/cases/[PTAB](/ptab)/IPR2023-00399/Apple_Inc/docs/12-22-2022-Petitioner/Exhibit-1002-3-APPL_1002___488_File_History___Part3_of_4.pdf).
- The sibling '386 patent's front-page list and NPL list (the '386 and '413 "share a common specification," per the Federal Circuit), at https://patents.justia.com/patent/[9892386](/patent/9892386). I flag that I have not verified item-by-item that the '413's list is identical to the '386's.
I did not retrieve the '413's own U.S. prosecution history (no office actions, no examiner's citations, no 892s), so nothing below should be read as reporting what the '413's examiner actually did.
1. Threshold framing (three points that shape the whole analysis)
(a) Pre-AIA § 103 governs. The CAFC confirmed all four asserted Fintiv patents "are based on two provisional applications filed in 2011, and therefore fall under pre-AIA." So the analysis is pre-AIA § 103(a), with § 102(a)/(b)/(e)/(g) defining the art, and the Graham v. John Deere / KSR framework. The effective priority date is June 3, 2011 (with an Aug. 10, 2011 provisional also in the chain). The 2011‑06‑02-vs-2011‑06‑03 one-day discrepancy flagged in the earlier section is immaterial here — every reference below pre-dates both by more than a year.
(b) The § 112 issue and the § 103 issue are two edges of one sword. The W.D. Tex. held, and the CAFC affirmed (Apr. 30, 2025, No. 23-2312), that "payment handler [service]" is a means-plus-function term with no disclosed corresponding structure → indefinite. The court's reasoning — that the term is a "blank box" whose specification support is "nearly identical to the claim language" — is itself probative on obviousness: a claim element that recites function without structure is satisfied by any prior-art system that performs the function, and is the classic fact pattern for In re Schreiber / KSR "known technique" reasoning. Conversely, because the term is indefinite, there is a formal problem: a claim whose scope cannot be determined cannot be cleanly compared to prior art. That asymmetry is why the case was won on § 112 and not § 103, and it is the single biggest caveat on everything below.
(c) Practical reach of this analysis. Claims 1 and 2 (the ones with the payment-handler limitation) stand invalidated as to the asserted scope. The § 103 question therefore matters chiefly for (i) any claim of the '413 not adjudicated — claims 3–7, whose text I still cannot verify (see previous section, § 4) — and (ii) later continuations in the same family. A third-party listing shows a further "Monetary Transaction System" grant, US 12,346,886 B2, assignee Fintiv, priority listed as 2011‑06‑02 (https://portal.unifiedpatents.com/patents/patent/US-[7899252](/patent/7899252)-B2) — I have not verified that grant first-hand, but if accurate it means claims of this specification continue to issue and the § 103 exposure keeps recurring.
2. The prior-art set (reconstructed)
| Reference | Date / status | § 102 basis vs. 6/3/2011 | Where it appears |
|---|---|---|---|
| US 2009/0119190 A1 – Realini, "Virtual pooled account for mobile banking"; granted as US 7,873,573 B2 (Jan. 18, 2011) | pub. May 7, 2009 | § 102(b) | ISR for PCT/US2012/040131: "X" against claim 20 alone; "Y" against claims 1–19 in view of Keena |
| US 2006/0253335 A1 – Keena et al. | pub. Nov. 9, 2006 | § 102(b) | ISR: "Y", claims 1–19, with Realini (cited ¶¶[0012], [0038], [0042]) |
| US 2009/0265272 A1 – Dill et al. (Western Union), "Money transfers utilizing a unique receiver identifier" | pub. Oct. 22, 2009 | § 102(b) | ISR: "Y", claim 13, with Realini + Keena (¶[0067]) |
| US 2009/0106152 A1 – Dill et al., same family (app. 12/146,650; prov. 60/980,675, Oct. 17, 2007) | pub. Apr. 22, 2009 | § 102(b) | Dill family |
| US 2009/0081989 A1 – Wuhrer, "…financial transaction interoperability across multiple mobile networks" | pub. Mar. 26, 2009 | § 102(b) | ISR: "Y", claims 16–17, with Realini + Keena (¶¶[0076], [0088], [0106]; motivation quoted at ¶[0007]) |
| US 2009/0063352 A1 – Kaufman, "Methods and systems for monetary exchange and transfer" | pub. Mar. 5, 2009 | § 102(b) | general field art |
| US 6,021,397 – Jones (electronic purse / value transfer) | Feb. 1, 2000 | § 102(b) | '413/'386 front page |
| US 7,024,174 B2 – Nagy (G06Q 20/04) | Apr. 4, 2006 | § 102(b) | '413 front page |
| US 6,480,957 (Liao); US 6,697,839 (Sim); US 6,873,974 (Schutzer); US 7,089,208 (Levchin/PayPal); US 6,957,342 (Vatanen); US 6,862,575 (Antila); US 6,199,762 (Hobbs); US 6,256,614 (Wecker); US 6,250,557 (Forslund); US 6,356,908 (Brown); US 7,016,532 (Boncyk); US 5,991,749 (Morrill); US 6,175,823 (Van Dusen); US 6,185,545 (Resnick); US 6,415,156 (Stadelmann); US 6,487,403 (Carroll); US 7,024,390 (Mori); US 6,959,939 (Tobin); US 6,840,448 (Fukushima); US 6,819,219 (Bolle); US 6,714,797 (Rautila); US 6,732,179 / 6,736,232 … | 1993–2006 | § 102(b) | '413 front page (partial list retrieved) |
| Foreign: CN 101606400 A (Dec. 2009); CA 2666616 A1 (Apr. 2008) | 2008–2009 | § 102(b) | '386 front page (same family; unverified for the '413) |
| NPL: Labrou & Agre, "Wireless Wallet," MobiQuitous 2004, pp. 1–10; Valcourt et al., "Investigating Mobile Payment," WiMob 2005, v.4, 29–36; Gao et al., "P2P‑Paid," WMCS '05 (Jul. 2005); Chen et al., "Short‑Range Wireless Technologies with Mobile Payments Systems," ICEC 2004, 649–56; Motorola M‑Wallet Solution (2006); Sykes et al., "Securing Mobile Banking," Credit Union Management, Nov. 2010; Clarke, "Emerging Value Propositions for M‑commerce," J. Bus. Strategies, Fall 2008 | 2004–2010 | § 102(a)/(b) | '386 front page NPL list (unverified for the '413) |
Two observations that matter for § 103:
- The ISR is an Examiner-grade prior-art finding on the same specification. An ISA (the USPTO acting as ISA) applied Realini as anticipatory ("X") against the broadest claim of the family (claim 20) and as part of a two- and three-reference obviousness combination against claims 1–19. That is unusually strong evidence that the claimed subject matter as a genus was old.
- The NPL set (2004–2010) shows the field was crowded well before June 2011, which both supplies the "known work" predicate under KSR and undercuts any later long-felt-need argument.
3. Person of ordinary skill
For § 103, POSITA matters for the motivation and predictability prongs. A reasonable definition consistent with the record: a bachelor's degree in electrical engineering, computer science, or equivalent, plus ~2–3 years' experience in payment/mobile-commerce system design, or a master's degree with less experience — the definition used in the sibling-patent IPR petitions (see the petition excerpts at https://ptacts.uspto.gov/ptacts/public-informations/petitions/[1549608](/patent/1549608)/download-documents?artifactId=CetCgTZczCR7E5Ge8-DVvTRQUrcjgmbU1OQru4eeUS9eMAlmVjhkOcw). Such a person would have been familiar with SMS/USSD/IVR/POS channel integration, API-façade ("wrapper"/"handler") design patterns, ACL-based authorization, and rules-driven limits/velocity checks — the exact building blocks recited.
4. Element-by-element mapping of claims 1–2
Claim 1 (system) and claim 2 (method) recite, in substance (per the CAFC's quotation and the sibling publication; treat as moderate confidence): processors → storage system holding financial transaction details, customer profiles, money containers → integration tier managing mobile-wallet sessions with a communication API to accept messages from channels → notification services over different notification channels → payment handler using APIs of different payment processors (banks, credit/debit-card processors, bill-payment processors) → security service for authentication → entity profile → instructions to receive a message from a mobile device over one of the plurality of channels, validate the subscriber's account by querying account attributes from storage via the integration tier, and receive confirmation.
| Claim element | Primary teaching | Secondary/alternative teaching |
|---|---|---|
| Processor(s); mobile-wallet platform | Realini (mobile banking platform, virtual pooled account, general ledger, system of record) | Keena; Dill |
| Storage system w/ transaction details + customer profiles + "money containers" | Realini ¶¶[0176], [0351], [0440], [0679] (records of transactions, users/subgroups, balances monitored) | Dill (subscriber/account mapping DB; transfer records) |
| Integration tier / session mgmt / channel-facing API | Realini (SMS + mobile-app + browser channels into one platform) | Dill (IVR, web, agent, mobile, kiosk, ATM channels); Keena |
| Notification services, different channels | Dill (SMS, e-mail, instant message, live operator, prerecorded voice, web-page notification) | Realini |
| Payment handler using APIs of different payment processors | Wuhrer ¶[0007] ("platform and application layer that can function across an array of payment platforms or network types"; accounts include system, debit card, credit card, PayPal, prepaid 364, and bank) | Realini (multiple partner banks/financial institutions behind one pooled account); front-page art (Liao, Sim, Schutzer, Levchin); Labrou "Wireless Wallet" / Motorola M‑Wallet (NPL) |
| Security service / authentication | Dill (PIN verified at the mobile wallet application before the transaction identifier is sent) | Realini (tiered fraud detection); Jones (RSA key exchange); Sykes NPL |
| Entity profile | Realini (agent/financial-partner/subscriber records; agent authority at ¶[0586]) | Dill (agent retail locations; MNO/recipient mapping) |
| Receive message over one of a plurality of channels; validate account status by querying storage | Realini ¶¶[0351], [0427], [0594] (validation checks; limits/velocity) | Wuhrer ¶¶[0076], [0088], [0106] (validation of allowed accounts per subscriber) |
| Receive confirmation transaction performed | Dill (response indicating completion; balance update; user notification) | Realini |
5. The obviousness grounds
Ground 1 — Realini in view of Keena (claims 1–2, and the platform genus)
This is the ground the family's own ISA already ran. For every claim 1–19 of PCT/US2012/040131 the ISA entered "Y" over Realini + Keena, and entered "X" (anticipation) over Realini alone for claim 20.
Motivation (as articulated in the ISR): Realini and Keena "are directed to systems and methods for monetary transaction system[s]" — i.e., the references are from the same field of endeavor, address the same problem (allowing subscribers, including unbanked ones, to move value through a mobile device across multiple financial institutions), and the combination is the "simple substitution of one known element for another" and "use of a known technique to improve similar devices in the same way" (KSR rationales; MPEP 2143(A)(3)). One of skill would look to Keena for the complementary balance/transaction-handling features Realini describes at a platform level, with predictable results.
Ground 2 — Realini + Keena + Dill (claims reciting international/remote transfers and multi-channel messaging)
The ISA expressly found that Realini + Keena fails to teach money transferred internationally between mobile wallets, and turned to Dill ¶[0067] for it (the same combination appears in the '488 file history exhibit above).
Motivation (verbatim thrust of the ISR): "it would have been obvious … to combine the virtual pooled account for mobile banking of Realini (as enhanced by Keena) with the money transfers utilizing a unique receiver identifier of Dill, because Realini, Keena and Dill are directed to systems and methods for monetary transaction system"; and "users and designers benefit from systems and/or methods adapted for enabling the data of the request to be verified by the mobile application of the money transfer facilitator … because such systems/methods allow … flexible payment options for the transaction (Dill ¶[0005])." Dill additionally supplies, in one reference, the multi-channel intake (IVR/web/agent/mobile/kiosk/ATM), the notification over multiple channels, the PIN-based authentication of the mobile wallet application, and the MTCN/reference-number + pay-out-at-agent flow — a near one-to-one match for the '413's Figs. 5B, 6B, 17C, 18B and the "secure, perishable code" motif.
Caveat — do not treat Dill as the primary reference. Fintiv's own IPR responses argued convincingly that Dill's database 150 stores mobile subscriber/account mapping data, not transaction data, and that Dill is structurally a remittance system, not a stored-value wallet platform (see the petition papers at https://ptacts.uspto.gov/ptacts/public-informations/petitions/1549608/download-documents?artifactId=dgU5yj685eu_J1cZcp3ieWQgldsUC75pFP_bWMbM9tPrNP-FdlBxNnE). For the '413's "storage system storing financial transaction details" limitation, Dill is therefore a secondary, not primary, reference.
Ground 3 — Realini + Keena + Wuhrer (the "payment handler" and account-validation limitations)
The ISA used Wuhrer for exactly the two limitations that map onto the '413's most-litigated elements: (i) validation checks ensuring a subscriber does not exceed an allowed number of accounts (Wuhrer ¶¶[0076], [0088], [0106]) — the rules-engine/limit-check function — and (ii) the API layer spanning an array of payment platforms and network types, including system, debit-card, credit-card, PayPal and prepaid accounts (Wuhrer ¶[0007]).
Motivation (as articulated): "it would have been obvious … to combine the virtual pooled account for mobile banking of Realini (as enhanced by Keena) with the system and method for financial transaction interoperability across multiple mobile networks of Wuhrer, because Realini, Keena and Wuhrer are directed to systems and methods for monetary transaction systems," and because such systems "provide a platform and application layer that can function across an array of payment platforms or network types (Wuhrer ¶[0007])." That is a textbook KSR "predictable variation" motivation, and it is the strongest available answer to the payment-handler limitation: by 2011 (indeed by 2009, on Wuhrer's face), exposing one façade over bank, card, and wallet APIs was "known work" done "in a known manner."
Ground 4 — Ground 3 plus the front-page/NPL art on API façades
For the payment-handler limitation specifically, a second, independent obviousness case arises from the '413's own cited art and NPL: Liao (US 6,480,957), Sim (US 6,697,839), Schutzer (US 6,873,974), Levchin (US 7,089,208 — PayPal), plus Labrou "Wireless Wallet" (2004) and Motorola M‑Wallet (2006), all teach or suggest unified payment-processing interfaces to heterogeneous payment instruments. Under KSR, "the combination of familiar elements according to known methods is likely to be obvious when it does no more than yield predictable results," and the Federal Circuit here noted that a POSITA in this field would have recognized "handler"-type abstractions; the court's conclusion that the term lacked structural meaning cuts toward, not against, the proposition that the recited function was a known, routine programming construct — the very evidence supporting an obviousness rejection of a functional element (In re Schreiber; cf. Williamson v. Citrix on nonce terminology).
Ground 5 — Alternative primary reference: Kaufman + Wuhrer (+ Dill)
US 2009/0063352 A1 (Kaufman) describes a centralized location holding multiple accounts, securable devices associated with each account, electronic value transfer between devices, and reconciliation with the centralized accounts. Combined with Wuhrer (multi-network API layer; account-limit validation) and Dill (unique-receiver-identifier transfers, multi-channel notification), Kaufman supplies the "storage system + accounts + reconciliation" core and the "entity profiles," avoiding the Dill-database weakness identified above.
Ground 6 — Anticipation fallback
Realini was found by the ISA to anticipate the family's claim 20 (the broadest "monetary transaction system" claim). If any unadjudicated claim of the '413 (e.g., a claim of the '413's claims 3–7 that merely elaborates the platform) were construed commensurate in scope with that subject matter, the correct challenge is § 102 over Realini alone, not § 103. I cannot confirm this because I could not verify claims 3–7.
6. Motivation to combine — consolidated
- Same field of endeavor / same problem. All of Realini, Keena, Dill, Wuhrer and Kaufman address mobile/electronic monetary transactions, including for unbanked or under-banked users, and the integration of mobile devices with banks, card processors and merchants. The ISR says so in terms, three times.
- Predictable combination of known elements. Each reference contributes a discrete, self-contained, well-understood subsystem (ledger/pooled accounts; rules & limits; channel intake; notification; multi-processor API façade; authentication). KSR: assembling these yields "no more than predictable results."
- Design incentive / art-recognized benefit. The references themselves state the benefit: Dill ¶[0005] (flexible payment options through verified requests and multi-channel notification); Wuhrer ¶[0007] (a platform/application layer that "can function across an array of payment platforms or network types").
- Market/regulatory pressure. 2004–2010 NPL and the M‑PESA/GCash-era proliferation of mobile-money programs supply the "known market demand" driver recognized in KSR and DyStar.
- No teaching away. No reference disparages channel-agnostic intake, multi-processor API abstraction, or rules-based validation; each is described as an improvement.
7. Where the obviousness case is weakest (be candid for the record)
- The § 112 holding is a double-edged sword. Because "payment handler" was held to have no ascertainable structure, a challenger cannot be certain what the claim covers — which is precisely why the district court and CAFC disposed of the case on indefiniteness rather than § 103. A § 103 challenge on claims 1–2 is now largely academic.
- "Money containers" and "integration tier" are coined terms with no verified antecedent in the art. A challenger must show the underlying constructs (stored-value ledgers; a session-managing integration layer) are old — doable, but the terminology gives the patent owner room to argue non-analogousness and to demand a claim-construction first.
- Dill's database-150 problem (subscriber/account mapping ≠ transaction records) is a documented, patent-owner-favorable argument that a challenger must design around; use Dill as secondary art.
- Secondary considerations are unaddressed on this record. I found no evidence of unexpected results, licensing-due-to-merit, or long-felt-but-unsolved need; conversely, any commercial-success story from Fintiv/Mozido would need a nexus to the claimed architecture, which the crowded 2004–2010 art makes difficult to establish.
- Verify claims 3–7 before relying on any ground. Their text, dependency structure, and whether each contains a payment-handler limitation remain unverified (flagged in the prior section and repeated here). Grounds 2–5 are keyed to the specification's subject matter (enrollment; stored-value accounts; bank/credit-union and debit/credit-card linking; deposit/withdrawal; bill pay; airtime top-up; domestic and international transfer; in-store purchase), which is a reasonable but inferred proxy for those claims' content.
8. Bottom line
- High confidence: The '413's claimed platform genus was, on the face of the family's own PCT search report, obvious over Realini in view of Keena (claims 1–19), with Dill supplying international/inter-wallet transfers (claim 13) and Wuhrer supplying multi-processor API interoperability and per-subscriber account validation (claims 16–17); and the family's broadest claim was anticipated by Realini alone (claim 20). Sources: WO 2013/025273 ISR; the ISR/WO reproduced in the '488 file history; Realini US 7,873,573.
- High confidence: Pre-AIA § 103 applies; all named references qualify as § 102(b) art relative to the June 3, 2011 (or Aug. 10, 2011) priority date; the one-day priority discrepancy is irrelevant here.
- Moderate confidence: The element-by-element mapping of claim 1/claim 2, especially the alignment of the payment-handler limitation to Wuhrer ¶[0007] (and to the front-page/NPL API-façade art), and the characterization of Keena's contribution (the ISR cites ¶¶[0012], [0038], [0042] but I did not retrieve Keena's full text, so I have not independently verified its content).
- Low confidence / flagged: the text and dependency structure of the '413's claims 3–7; the precise identity of the '413's own front-page NPL list (I inferred it from the '386, which shares the specification); whether any IPR has ever been instituted against the '413 (I found none; the Apple/PayPal IPRs I located target sibling patents); and any 2026 disposition of the '413 itself.
Generated 10/1/2026, 1:05:36 PM
Extensions
Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.
Derivative works
Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.
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1 tracked lawsuit name US 11120413.