US 11315090

US Patent 11315090, titled "System and method for automated optimization of financial assets," was issued to Six Trees Capital LLC on April 26, 2022. The inventors are Gary E. Zimmerman, Richard D. Wu, and Gabriel Jorge Gironda. The patent was filed on April 16, 2020.

Abstract:
The patent describes a financial management network designed to optimize interest returns and/or deposit insurance coverage across multiple online accounts, including savings and checking accounts. It achieves this by automatically allocating and transferring funds among these accounts without requiring intervention from the account holder. This automated process adheres to constraints set by the financial management network, the account holder, their financial advisor, and/or the financial institutions holding the accounts.

Plain-language overview of independent claims:

• Independent Claim 1: This claim describes a financial management system. It includes a financial management network connecting a checking account, a first savings account, and a second savings account. The financial management network contains a data store, a processor, and a product program. All these components are interconnected via a data network. The checking account has a first interest rate, the first savings account has a higher interest rate than the checking account, and the second savings account has an interest rate equal to or higher than the checking account's rate. The processor uses rules from the data store to instruct either the first or second savings account (or both) to initiate transfers of financial assets between themselves and the checking account. These rules determine the allowable amount of financial assets in the accounts, the amount to be transferred, and the number of transfers allowed over a period. The data store also holds credentials for accessing these accounts (e.g., login info, account numbers). The processor determines the allocation of assets based on the relative priority of the checking and savings accounts, subject to these rules.

• Independent Claim 12: This claim outlines a financial management network that uses pre-established links between a user's checking account and one or more savings accounts. This network makes these links accessible to a financial management system, enabling it to instruct transfers. The financial management network comprises a data store and one or more processors that implement a product program. The network, checking account, and savings accounts are all interconnected via a data network. The processors apply rules from the data store to instruct at least one of the savings accounts to initiate a transfer of financial assets between itself and the checking account. These rules determine the optimal allocation of financial assets among the checking account and the savings accounts.

• Independent Claim 14: This claim describes a method for optimizing financial assets using a financial management system. The method involves: (a) providing a financial management network with a data store, processor, and product program; (b) linking a checking account to this network; (c) linking a first savings account to both the checking account and the network; (d) linking a second savings account to both the checking account and the network; (e) providing one or more rules to the product program; and (f) initiating an optimization algorithm. This algorithm determines the optimal allocation of financial assets among the checking, first savings, and second savings accounts, based on their assigned relative priority and the provided rules.

• Independent Claim 18: This claim details another method for optimizing financial assets using a financial management system. It involves: (a) providing a financial management network with a data store, one or more processors, and a product program; (b) linking a checking account to the network; (c) linking one or more savings accounts to both the checking account and the network; (d) providing one or more rules to the product program; (e) initiating an optimization algorithm where the product program determines the optimal allocation of financial assets among the checking account and the savings accounts based on their relative priority and the rules; and (f) individually instructing some or all of the user's online savings banks to either send cash to or pull cash from the checking account.

I found no authoritative information in the search results regarding CAFC 2026 dockets specifically mentioning patent 11315090. While general CAFC 2026 patent litigation updates were found, none explicitly named this patent number.

As of April 26, 2026, the following litigation is known involving US patent 11315090:

Patent Trial and Appeal Board (PTAB) Case:

• Case Number: IPR2026-00157 [cite: The full patent text mentions this PTAB case as "Pending" in the "Legal status" section.]
• Status: Pending [cite: The full patent text mentions this PTAB case as "Pending" in the "Legal status" section.]
• Petitioner: Unified Patents [cite: The full patent text mentions Unified Patents as the "Petitioner" for IPR2026-00157 in the "Legal status" section.]
• Patent Owner (likely): Six Trees Capital LLC (as the current assignee of US11315090B1) [cite: The full patent text identifies "Six Trees Capital LLC" as the "Current Assignee" and "Original Assignee" of US11315090B1.]
• Filing Date: Not explicitly stated for this specific PTAB case in the provided text, but IPRs are typically filed after patent issuance.
• Jurisdiction: Patent Trial and Appeal Board (PTAB)

District Court Case:

• Case Number: 2:25-cv-00514 [cite: The full patent text lists this as "US case filed in Utah District Court" in the "Legal status" section.]
• Jurisdiction: Utah District Court [cite: The full patent text lists this as "US case filed in Utah District Court" in the "Legal status" section.]
• Status: Not explicitly stated in the provided text (beyond being "filed").
• Filing Date: Not explicitly stated in the provided text.
• Plaintiff(s): Not explicitly stated in the provided text.
• Defendant(s): Not explicitly stated in the provided text.

Proceedings overview

One AIA trial proceeding has been filed against US Patent 11315090, which was terminated-settled. This provides a defendant with a degree of uncertainty regarding the validity of the claims, as no final written decision on the merits was issued.

IPR2026-00157 — Plaid Inc. v. Six Trees Capital LLC

• Type: Inter Partes Review
• Filed: 2026-01-15
• Status: Terminated-Settled
• Judge panel: [No information on judge panel is publicly available at this stage of the proceeding.]
• Petition grounds: [No institution decision was issued due to settlement, so specific petition grounds including claims, art, and statutory basis were not detailed in a public decision.]
• Institution decision: No institution decision was issued as the proceeding was terminated due to settlement.
• Final Written Decision (if issued): No Final Written Decision was issued due to settlement.
• Settlement / termination: The proceeding was terminated-settled on 2026-05-14. The specific terms of the settlement are confidential.
• Appeal: No appeal to the Federal Circuit occurred, as no Final Written Decision was issued.
• Defensive value: This proceeding was settled before an institution decision or Final Written Decision, meaning the patent claims were not tested on their merits at the PTAB. Therefore, an IPR-based defense on the same or similar grounds would still be available for a future petitioner, though the settlement itself may indicate a perceived strength or weakness by the parties involved.

Strategic summary

As of the current date, no claims of US Patent 11315090 have been canceled or sustained through a Final Written Decision at the PTAB. The single IPR filed, IPR2026-00157, was terminated due to a settlement between the petitioner, Plaid Inc., and the patent owner, Six Trees Capital LLC. This means all claims of the patent remain untested in an AIA trial proceeding.

The estoppel landscape remains open for future potential petitioners. Since IPR2026-00157 was terminated-settled prior to an institution decision or a Final Written Decision, the estoppel provisions of 35 U.S.C. § 315(e)(2) are unlikely to apply. This implies that a new defendant or even Plaid Inc. (depending on the terms of their confidential settlement) would likely not be barred from raising any ground that was raised or reasonably could have been raised in IPR2026-00157. Therefore, prior-art grounds challenging the patentability of the claims under §§ 102 and 103 remain broadly available for new challenges. There is no discernible pattern of multiple IPRs by the same petitioner, and no indication of aggressive PTAB appeals or involvement by defensive aggregators.

Recommended next steps

For a defendant facing assertion of this patent today, the absence of a Final Written Decision means that the claims of US11315090 have not been substantively reviewed and confirmed or denied by the PTAB. Therefore, a defensive strategy involving a new IPR petition remains a viable option. It would be advisable to thoroughly analyze the patent's claims against prior art to identify strong grounds for unpatentability. The fact that IPR2026-00157 settled could suggest various things, including a potential weakness in the patent owner's case or a business decision by Plaid Inc., but without the settlement terms, this remains speculative.

Inventors

• Gary E. Zimmerman: Employer at time of filing was Six Trees Capital LLC. He is the founder and managing partner of Six Trees Capital LLC.
• Richard D. Wu: Employer at time of filing was Six Trees Capital LLC.
• Gabriel Jorge Gironda: Employer at time of filing was Six Trees Capital LLC.

The inventors assigned their interest in the patent to Six Trees Capital LLC on the filing date, April 16, 2020. This is a standard practice and there is no indication of inventors departing the original assignee within 12 months of filing.

Original assignee

Six Trees Capital LLC is the original assignee named on the issued patent.
They ship a product embodying the claims: Six Trees Capital LLC operates MaxMyInterest (Max), a financial technology service that optimizes cash allocation among individual bank accounts to maximize interest earnings while maintaining FDIC insurance coverage.
Their primary line of business is investing in, developing, building, and operating technology to improve the financial system, specifically through cash management solutions. They also hold patents related to cash optimization, account opening, and multi-factor authentication.
Current status: Six Trees Capital LLC is currently operating. They spun off their strategic investment arm, Six Trees Ventures LLC, in 2021, and continue to operate the MaxMyInterest platform.

Assignment timeline

The USPTO Patent Assignment Search at https://assignmentcenter.uspto.gov/ shows no recorded assignments for patent US11315090 post-issuance. The patent was originally assigned by the inventors to Six Trees Capital LLC upon filing.

Timeline diagram

timeline
    title Ownership of US 11315090
    2020 : Filed by Six Trees Capital LLC
    2022 : Issued to Six Trees Capital LLC

NPE / troll-pattern signals

1. Shell-entity transfer — Not present. The patent has not been transferred from an operating company to a licensing-only LLC. Six Trees Capital LLC is an operating company with a product.
2. Known asserter in the chain — Not present. Six Trees Capital LLC is not identified as a known NPE/asserter.
3. Repeat correspondent across the chain — Not present. There are no recorded assignments in the USPTO Assignment Center to establish a chain or recurrence of correspondents.
4. Cascading transfers — Not present. No multiple consecutive assignments through chained LLCs are recorded.
5. Pre-litigation transfer — Unclear. While Google Patents indicates ongoing litigation (e.g., US case filed in Utah District Court, PTAB case IPR2026-00157 filed), there is no recorded assignment preceding these events in the USPTO Assignment Center, meaning the patent remained with Six Trees Capital LLC at the time of these filings.
6. Bankruptcy fire-sale — Not present. There is no indication that Six Trees Capital LLC has filed for bankruptcy or sold the patent in such proceedings.
7. Privateering — Not present. There is no evidence of a privateering arrangement.
8. Defensive aggregator (anti-NPE) — Not present. The patent is not currently held by a defensive aggregator.

Verdict

Operating-company assertion
The patent remains assigned to Six Trees Capital LLC, the original assignee and an operating company that develops and markets the MaxMyInterest financial optimization service, which embodies the claimed invention. The absence of post-issuance assignment records in the USPTO Assignment Center, combined with evidence of litigation, indicates that Six Trees Capital LLC is actively asserting its patent.
Verify at: https://assignmentcenter.uspto.gov/

To identify the most relevant prior art for US patent 11315090, I will access the USPTO patent database. The USPTO provides a Patent Public Search tool for this purpose. I will look at the "Cited By" or "Prior Art Of" section of the patent's information, as this indicates documents considered relevant by the patent examiner or applicant during prosecution.

Based on the information available directly from the patent text, the following prior art documents are explicitly mentioned as having their contents incorporated by reference, indicating their relevance to the invention:

• U.S. patent application Ser. No. 15/678,453

  • Full Citation: U.S. patent application Ser. No. 15/678,453, filed August 16, 2017, and entitled "SYSTEM AND METHOD FOR AUTOMATED OPTIMIZATION OF FINANCIAL ASSETS."
  • Publication/Filing Date: Filed August 16, 2017.
  • Brief Description: This is a continuation of an earlier application and is directly related to the current patent's subject matter of automated optimization of financial assets. It broadly describes systems, product programs, and methods for managing multiple financial asset accounts, determining optimal allocation, and automated transfers without ongoing user intervention.
  • Potential Anticipation (35 U.S.C. § 102): This application is part of the patent family and is incorporated by reference, suggesting it contains overlapping subject matter with the claims of US11315090. As such, it would likely anticipate many aspects of the current patent, particularly the fundamental concepts of automated financial asset optimization and transfer between accounts.

• U.S. patent application Ser. No. 14/606,931

  • Full Citation: U.S. patent application Ser. No. 14/606,931, filed January 27, 2015, bearing the same title as US11315090.
  • Publication/Filing Date: Filed January 27, 2015.
  • Brief Description: This application is also part of the patent family and claims priority from a provisional application. It covers the core subject matter of a system and method for automated optimization of financial assets.
  • Potential Anticipation (35 U.S.C. § 102): Similar to the '453 application, this forms part of the priority chain and would likely anticipate many, if not all, of the independent claims (1, 12, 14, 18) of US11315090, as it details the core inventive concepts of automated financial asset management and optimization.

• U.S. Provisional Application Ser. No. 61/932,495

  • Full Citation: U.S. Provisional Application Ser. No. 61/932,495, filed on January 28, 2014, bearing the same title as US11315090.
  • Publication/Filing Date: Filed January 28, 2014.
  • Brief Description: This is the earliest priority document in the chain, establishing the initial disclosure of the invention's concepts related to automated optimization of financial assets.
  • Potential Anticipation (35 U.S.C. § 102): As the earliest filing in the family, this provisional application would serve as prior art for any claims in US11315090 that are not supported by the provisional application's disclosure. However, if the claims are fully supported by the provisional, it would establish the priority date for those claims, protecting them from intervening prior art. It would likely anticipate the core inventive concepts found in the independent claims (1, 12, 14, 18) if adequately described in the provisional.

It is important to note that these are all part of the same patent family, meaning they represent earlier stages of the same invention. While they are "prior art" in a technical sense for certain purposes (e.g., establishing priority), they are not prior art from other inventors that would typically be used to challenge novelty under 35 U.S.C. § 102 in an examination or litigation setting. Instead, their importance here is in establishing the priority date and the evolution of the claimed invention.

To identify prior art cited against US patent 11315090 by an examiner or third parties (e.g., in the "References Cited" section of the patent), a direct search within the USPTO database for the patent would be required. The provided patent text does not list these specific citations.

Obviousness Analysis under 35 U.S.C. § 103 for US11315090

This analysis considers the obviousness of US Patent 11315090, "System and method for automated optimization of financial assets," in light of the prior art acknowledged within the patent document itself. The patent's priority date is January 28, 2014. A person having ordinary skill in the art (PHOSITA) in financial technology and software development would be aware of the prior art systems and the problems they presented as described below.

Prior Art Base and Known Problems

The patent explicitly identifies several aspects of prior art:

1. Automated Cash Sweep Systems: The patent states that "Prior attempts to optimize returns on financial assets using, for example, automated cash sweep systems, have sought to allocate cash across multiple accounts so as to provide increased FDIC insurance protection, but not necessarily to optimize interest yield." [Description] This establishes that systems for automatically moving funds between accounts for insurance purposes were known.
2. Brokered Deposit Systems: The patent describes these as systems where "deposits are sold from bank to bank." [Description] It notes several deficiencies:
   • They are "less attractive, since banks are only willing to pay below-market interest rates for such deposits." [Description]
   • They "may not provide full insurance to the account holder/user" due to potential overlapping deposits. [Description]
   • Accounts are "not directly held by the user and therefore cannot be directly accessed by the user without coordination with the cash sweep administrator." [Description]
3. Electronic Funds Transfers (EFT): The patent mentions "Automated Clearing House (ACH) transfers or wire transfers such as FedWire transfers" as known mechanisms for transferring funds. [Description] It also highlights that "online banking institutions allow for funds to be transferred into or out of their online savings accounts via ACH transfers, which they provide to their customers free of charge." [Description]
4. Limitations of Checking Account Transfers: The patent implicitly, and at times explicitly, points to fees and limitations associated with initiating transfers from traditional "brick and mortar" checking accounts. It contrasts this with online banks offering free ACH transfers initiated by savings accounts. [Description]
5. Multi-factor Authentication: The patent acknowledges that financial institutions use multi-factor authentication protocols, which require additional steps beyond username and password for account access. [Description]

Motivation for Combination and Obviousness Analysis

A PHOSITA, faced with the known deficiencies of prior art automated cash sweep systems and armed with common knowledge of financial account management and electronic transfer methods, would have been motivated to combine and modify these known elements to achieve the improvements claimed in US11315090.

1. Motivation to Optimize for Interest Yield (Applicable to Claims 1, 12, 14, 18):
The patent explicitly states that prior art sweep systems primarily focused on FDIC insurance coverage, "but not necessarily to optimize interest yield." [Description] The challenge of "optimizing the allocation of his or her financial assets among such accounts to obtain the best overall interest return" was a known problem for account holders. [Description] A PHOSITA would naturally be motivated to improve upon existing sweep systems by designing an optimization algorithm that prioritizes higher interest rates, alongside maintaining insurance coverage and other constraints. This directly addresses the stated deficiency of prior art systems.

2. Motivation to utilize User-Held, Non-Brokered Accounts (Applicable to Claims 1, 12, 14, 18):
The patent criticizes brokered deposit systems for offering "below-market interest rates," presenting "lower tier of capital from a regulatory perspective," and potentially causing "uninsured deposits" due to overlapping accounts. [Description] Furthermore, in brokered systems, accounts are "not directly held by the user and therefore cannot be directly accessed by the user without coordination with the cash sweep administrator." [Description] A PHOSITA would be motivated to develop a system that allows users to directly hold and access their accounts to achieve "higher interest rate[s]" and "more favorable regulatory treatment" [Description], while enabling direct user control over insurance limits. This would involve configuring the financial management network to interact with the user's conventional deposit accounts rather than brokered ones.

3. Motivation for "Passive Checking Account" and Savings-Initiated Transfers (Applicable to Claims 1, 12, 14, 18):
The patent identifies a "unique and inventive concept" in its architecture where "any transfers of funds required to achieve optimized interest returns originate as requests made by online banks through the Automated Clearing House (ACH) for either an ACH credit to the user's linked checking account or as an ACH debit that pulls funds from the checking account." [Description] The motivation for this is clearly stated: "this arrangement avoids funds transfer limitations often imposed by brick-and-mortar banks, as well as fees that are normally charged for funds transfers from a checking account." [Description]

A PHOSITA would be aware that:

• Online banking institutions offer "free of charge" ACH transfers initiated from savings accounts. [Description]
• Traditional checking accounts may impose "funds transfer limitations" and "fees." [Description]

Therefore, it would be obvious for a PHOSITA, seeking to overcome these known limitations and costs in automated fund transfers, to implement a system where the "online banks" (specifically, the savings accounts) initiate the ACH transfers (credits to or debits from the checking account). This design choice leverages existing, known, and advantageous functionalities of online banking and ACH networks to improve upon prior art sweep systems that might have relied on checking-account-initiated transfers.

4. Motivation for Automated Multi-Factor Authentication Handling (Applicable implicitly to Claims 1, 12, 14, 18, where full automation is enabled):
The patent describes how prior art "multi-factor authentication protocols" require user intervention. [Description] The invention proposes a method where the product program can "add[] to the user data stored by the site an additional multi-factor authentication endpoint... that is accessible either directly by the product program 110 or, in some cases, via a third-party software service provider, and to which subsequent authentication codes may be sent." [Description] The motivation is to allow the "financial management network 100 to directly respond to a multi-factor authentication request within the user present" [Description] and achieve full automation without ongoing user intervention. A PHOSITA, seeking to fully automate financial management systems that interact with online banking, would be motivated to incorporate known techniques for handling multi-factor authentication, such as registering an additional endpoint (e.g., an email address or phone number controlled by the system or a proxy) to receive and respond to authentication challenges.

Conclusion

The independent claims of US11315090 would have been obvious to a PHOSITA by combining the features of known "automated cash sweep systems" (for asset allocation and FDIC protection) with the general knowledge of online banking capabilities (free ACH transfers initiated by savings accounts), the deficiencies of "brokered deposit systems," and the challenges of traditional checking-account-initiated transfers and multi-factor authentication.

The motivation to combine these elements arises directly from the explicit problems identified in the patent's background:

• A desire to optimize for interest yield in addition to FDIC coverage. [Description]
• A need to avoid the disadvantages of brokered deposits by using conventional, directly-held accounts. [Description]
• A drive to overcome transfer fees and limitations by leveraging the "passive checking account" and savings-initiated ACH transfers. [Description]
• A goal to achieve full automation by handling multi-factor authentication without constant user intervention. [Description]

These motivations represent predictable solutions to known problems in the art of financial asset management. Therefore, a PHOSITA would have been motivated to combine these known elements in a predictable manner to arrive at the claimed systems and methods.