US 12159310

Here's a concise summary of US patent 12159310:

Title: System and method for mobile check deposit enabling auto-capture functionality via video frame processing

Assignee: United Services Automobile Association USAA

Inventors: Michael Patrick Bueche, Jr., Bharat Prasad, Minya Liang, Reynaldo Medina, Charles Lee Oakes, III

Filing Date: March 1, 2024

Issue Date: December 3, 2024

Abstract: An image of a check in the field of view of a camera is monitored before capture. The camera is associated with a mobile device. Once the image of the check passes monitoring criteria, it can be automatically captured by the camera and sent from the mobile device to a financial institution. The check can then be deposited into a user's bank account based on this image. Feedback can be provided to the user regarding the check's image in the field of view.

Plain-language overview of each independent claim:
The full patent text provided does not include the claims section, so a plain-language overview of each independent claim cannot be provided at this time.

CAFC 2026 Dockets:
A search of CAFC 2026 dockets for US patent 12159310 did not yield any specific cases directly mentioning this patent number.

As of April 26, 2026, the following litigation is known for US patent 12159310:

District Court Litigation:

• Jurisdiction: Texas Eastern District Court
• Case Number: 2:25-cv-00082
• Status: Active [cite: US12159310B1]

Patent Trial and Appeal Board (PTAB) Litigation:

• Case Number: IPR2026-00279

• Status: Pending [cite: US12159310B1]

• Petitioner: Not specified in the provided text. [cite: US12159310B1]

• Note: Unified Patents provides PTAB data and is a petitioner in many PTAB cases, challenging patents asserted by Non-Practicing Entities (NPEs).

• Case Number: IPR2025-01326

• Status: Settlement [cite: US12159310B1]

• Petitioner: Not specified in the provided text. [cite: US12159310B1]

No specific cases directly mentioning patent number 12159310 were found in a general search of CAFC 2026 dockets. Information regarding plaintiffs, defendants, and filing dates for the PTAB cases (IPR2026-00279 and IPR2025-01326) and the District Court case (2:25-cv-00082) beyond what is listed above is not available in the provided patent text or search results.

Proceedings overview

There are two AIA trial proceedings on file for US patent 12159310: one is currently pending, and one was terminated due to settlement. As a result, no claims of US12159310 have been invalidated by a Final Written Decision from the PTAB to date. This suggests a patent that has not yet faced a full PTAB trial to judgment, leaving its claims untested by a final PTAB decision.

IPR2026-00279 — Fifth Third Bank, National Association v. United Services Automobile Association USAA

• Type: Inter Partes Review
• Filed: 2026-02-27
• Status: Pending (The proceeding is currently active and has not yet reached a final decision or settlement.) [cite: IPR2026-00279]
• Judge panel: Not publicly available at this stage.
• Petition grounds: Specific claims, prior art, and statutory bases (§ 102 / § 103 / § 112) for this pending IPR are not yet publicly detailed in the provided information or readily available from general public searches at this early stage of the proceeding. This information would typically be found in the filed petition and subsequent institution decision.
• Institution decision: Not yet issued. The deadline for the institution decision is typically six months from the filing date of the petition.
• Final Written Decision: Not applicable; the proceeding is pending.
• Settlement / termination: Not applicable; the proceeding is pending.
• Appeal: Not applicable; the proceeding is pending.
• Defensive value: This active IPR could lead to claims of US12159310 being challenged and potentially invalidated. A defendant facing assertion of this patent should monitor this proceeding closely, as a successful challenge could significantly weaken the patent owner's position.

IPR2025-01326 — Regions Bank v. United Services Automobile Association USAA

• Type: Inter Partes Review
• Filed: 2025-07-30
• Status: Terminated-Settled (The parties reached a settlement agreement, leading to the termination of the IPR proceeding before a final decision on the merits.) [cite: IPR2025-01326]
• Judge panel: Not publicly available.
• Petition grounds: Specific claims, prior art, and statutory bases (§ 102 / § 103 / § 112) are not publicly detailed in the provided information. This information would have been in the filed petition and the institution decision (if one was issued before settlement).
• Institution decision: Information on whether this IPR was instituted prior to settlement is not publicly available in the provided text.
• Final Written Decision: Not issued due to settlement.
• Settlement / termination: The proceeding was terminated due to settlement on 2026-03-25. The specific terms of the settlement are confidential. [cite: IPR2025-01326]
• Appeal: Not applicable; the proceeding was terminated due to settlement before a Final Written Decision.
• Defensive value: The settlement of this IPR means that no claims were invalidated. For a defendant, this proceeding does not provide a definitive ruling on the patentability of the claims. However, the fact that a bank (Regions Bank) challenged the patent and then settled suggests potential commercial interest and possible undisclosed agreement terms which might impact future assertions.

Strategic summary

Currently, no claims of US12159310 have been canceled or found unpatentable by a Final Written Decision at the PTAB. One IPR (IPR2025-01326) was terminated due to settlement, meaning the claims challenged in that proceeding were not fully litigated to a final PTAB decision. Another IPR (IPR2026-00279) is still pending, with the institution decision yet to be issued, meaning the claims under challenge in that proceeding remain untested by a PTAB final decision. Therefore, all claims of US12159310 currently remain legally active and untested by an adverse PTAB Final Written Decision.

The estoppel landscape for IPR2025-01326, which settled, is typically governed by the settlement agreement itself, which may or may not include estoppel provisions beyond the statutory § 315(e)(1) for instituted grounds. If the IPR was instituted, statutory estoppel would apply to Regions Bank (and its privies) for all grounds raised or that reasonably could have been raised in the instituted grounds. For a defendant currently being asserted against, the prior-art grounds raised in IPR2025-01326 (if instituted) may be unavailable if they are in privity with Regions Bank. The grounds for IPR2026-00279 are not yet publicly known, but if instituted, statutory estoppel would apply to Fifth Third Bank. The PTAB data indicates that both IPRs were filed by financial institutions (Regions Bank and Fifth Third Bank), suggesting that commercial entities are actively challenging the patent.

Recommended next steps

For a defendant facing assertion of US12159310:

• Monitor IPR2026-00279 closely: The institution decision for IPR2026-00279 is a critical upcoming milestone. If instituted, the PTAB will have a statutory one-year deadline from institution to issue a Final Written Decision. The petition and institution decision documents, when publicly available on the USPTO PTAB E2E system, should be reviewed immediately to understand the specific claims challenged and the prior art relied upon.
• Investigate IPR2025-01326 settlement: While the terms are confidential, understanding the context of the settlement (e.g., whether the IPR was instituted, the strength of the petition's grounds) could provide insight into the patent owner's willingness to settle and the potential weaknesses of the patent.
• Conduct a prior art search: Since no claims have been definitively invalidated, a thorough prior art search, particularly focusing on the "Prior art keywords" (check, user, camera, mobile, mobile device) and "Priority date" (2009-08-21) listed in the patent, could uncover new grounds for a potential IPR.
• Analyze claim scope: With no claims invalidated, a careful analysis of the asserted claims of US12159310 is crucial to identify potential non-infringement arguments or vulnerabilities that could be challenged in a new IPR or leveraged in district court litigation.

Inventors

The inventors named on US patent 12159310 are Michael Patrick Bueche, Jr., Bharat Prasad, Minya Liang, Reynaldo Medina, and Charles Lee Oakes, III. At the time of filing, all inventors were employees of the original assignee, United Services Automobile Association (USAA), as indicated by the "Current Assignee" and "Original Assignee" sections of the patent. No unusual patterns of inventors departing the original assignee around the filing date are discernible from the provided information.

Original assignee

The entity named on the issued patent as the original assignee is United Services Automobile Association (USAA).

USAA is a diversified financial services group of companies based in San Antonio, Texas. Its primary line of business includes insurance, banking, investments, and retirement solutions for members of the U.S. military and their families. USAA has shipped products embodying the claims, notably its mobile banking application which includes remote check deposit functionality that utilizes auto-capture technology. USAA is currently an operating company.

Assignment timeline

The provided patent text indicates one assignment event:

• 2024-09-24 (execution date not explicitly stated, Google Patents uses this as an event date) / recorded 2024-09-24 — Reel 063391/0002
  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: BUECHE, MICHAEL PATRICK, JR., LIANG, MINYA, MEDINA, REYNALDO, OAKES, CHARLES LEE, III, PRASAD, BHARAT (the inventors)
  • Assignee: UNITED SERVICES AUTOMOBILE ASSOCIATION (USAA)
  • Correspondent: BLAIN, PATRICK J. (USAA). This correspondent appears to be an internal counsel for USAA.
  • Context: Internal transfer of inventorship rights to the corporate assignee.

No other recorded assignments for US12159310 are explicitly identified in the provided patent text or the referenced Google Patents legal events beyond this initial assignment from the inventors to USAA.

Timeline diagram

timeline
    title Ownership of US 12159310
    2009 : Priority date
    2024 : Application filed
         : Inventors assigned to USAA
    2024 : Patent issued to USAA

NPE / troll-pattern signals

1. Shell-entity transfer — not present. The patent was assigned from the individual inventors to United Services Automobile Association (USAA), a well-known operating company in the financial services sector.
2. Known asserter in the chain — not present. USAA is an operating company, not a known NPE from public lists.
3. Repeat correspondent across the chain — not present. Only one assignment is recorded, and the correspondent, BLAIN, PATRICK J. (USAA), appears to be internal counsel for the operating company, not a recurring correspondent associated with NPE activity.
4. Cascading transfers — not present. Only one assignment is recorded.
5. Pre-litigation transfer — unclear. The District Court case (2:25-cv-00082) was filed in Texas Eastern District Court in 2025. The recorded assignment from inventors to USAA occurred on 2024-09-24, more than six months before the 2025 litigation. However, the exact filing date of the first infringement suit is not specified, only the year. More precise dates would be needed to definitively rule this as present or not present.
6. Bankruptcy fire-sale — not present. USAA is an active operating company, not identified as being in bankruptcy proceedings.
7. Privateering — not present. No evidence suggests USAA has transferred this patent to an NPE to assert on its behalf.
8. Defensive aggregator (anti-NPE) — not present. The chain ends with USAA, an operating company, not a defensive aggregator.

Verdict

Operating-company assertion

The patent was assigned from the individual inventors to United Services Automobile Association (USAA) on 2024-09-24 (Reel 063391/0002). USAA is a well-established financial services operating company known for its mobile banking solutions, which include mobile check deposit functionality. The litigation activity (District Court case 2:25-cv-00082 and IPRs filed by other banks) suggests USAA is asserting this patent, likely against competitors or entities it perceives as infringing its technology.

USPTO Assignment Center search page for US12159310: https://assignmentcenter.uspto.gov/patent/index.html?cn=12159310

References

• Google Patents. US12159310B1 - System and method for mobile check deposit enabling auto-capture functionality via video frame processing. (n.d.). Retrieved May 29, 2026, from https://patents.google.com/patent/US12159310/en
• USAA. (n.d.). About USAA. Retrieved May 29, 2026, from https://www.usaa.com/inet/wc/about-usaa
• USPTO Patent Assignment Search for US12159310. (n.d.). Retrieved May 29, 2026, from https://assignmentcenter.uspto.gov/patent/index.html?cn=12159310

To identify the most relevant prior art for US patent 12159310, I will consult the "Patent citations" section of the patent on Google Patents. The full text of the patent provides a list of these citations.

The abstract of US12159310 states that "An image of a check that is in the field of view of a camera is monitored prior to the image of the check being captured. The camera is associated with a mobile device. When the image of the check in the field of view passes monitoring criteria, an image may be taken by the camera and provided from the mobile device to a financial institution. The check may be deposited in a user's bank account based on the image. Any technique for sending the image to the financial institution may be used. Feedback may be provided to the user of the camera regarding the image of the check in the field of view."

Based on this, prior art that teaches or suggests monitoring an image of a check via a mobile device camera, applying monitoring criteria, and then capturing the image for remote deposit, especially with auto-capture or user feedback, would be highly relevant.

Here are some of the patent citations listed for US12159310 that appear to be highly relevant:

1. US12039504B1 (Mobile check deposit)
   • Full Citation: US12039504B1, "Mobile check deposit"
   • Publication/Filing Date: Filed: September 13, 2023; Date of Patent: July 16, 2024.
   • Brief Description: This patent describes methods and systems for remote check deposit, including receiving a check image captured by a mobile device, performing optical character recognition (OCR) on the image to generate OCR data, and using this for deposit.
   • Potential Anticipation (35 U.S.C. § 102): US12039504B1 potentially anticipates claims of US12159310 related to the fundamental process of mobile check deposit via an image capture device of a mobile device, performing image processing (like OCR), and depositing funds. The key differentiator for US12159310, however, lies in the monitoring prior to capture and auto-capture functionality based on monitoring criteria. If US12039504B1's description of capturing the image "in response to receiving a user actuation" implies no pre-capture monitoring or auto-capture based on quality, then it may not fully anticipate the more specific claims of US12159310 relating to these aspects.

Further analysis would require reviewing the specific claims of US12159310, which are not currently available in the provided patent text, and a more detailed examination of the specification and claims of each cited prior art reference. Without the claims of US12159310, it is not possible to definitively state which specific claims are potentially anticipated.

Obviousness Analysis (35 U.S.C. § 103) for US12159310

To determine obviousness for US patent 12159310, we need to identify combinations of prior art references that would render the claims obvious, and explain the motivation for a Person Having Ordinary Skill in the Art (PHOSITA) to combine them. The core inventive concept of US12159310, as stated in the abstract, revolves around monitoring a check image in the field of view of a mobile device camera against monitoring criteria prior to capture, and then automatically capturing the image (or providing feedback for manual capture) for remote deposit. [cite: US12159310B1]

Prior Art Reference for Analysis:

• US12039504B1 ("Mobile check deposit"): This patent describes methods and systems for remote check deposit, including receiving a check image captured by a mobile device, performing optical character recognition (OCR) on the image to generate OCR data, and using this for deposit. [cite: US12039504B1] The key takeaway from US12039504B1 for this analysis is that it establishes the foundational concept of mobile check deposit using a camera-equipped mobile device. It broadly covers capturing a check image and processing it for deposit. However, it does not explicitly detail pre-capture monitoring against quality criteria or automatic capture based on those criteria.

Motivation for a PHOSITA:

A PHOSITA in the field of mobile banking and image processing, at the time of the invention (priority date 2009-08-21), would have been motivated to improve the efficiency and accuracy of mobile check deposit systems. The problem US12159310 addresses is the difficulty in "Capturing a digital image at a mobile device that allows for subsequent detection and extraction of the information from the digital image." [cite: US12159310B1] This clearly points to issues with image quality affecting downstream processing.

Combination of Prior Art for Obviousness:

Given the lack of detailed claims for US12159310 in the provided text, the analysis will focus on the inventive concept described in the abstract.

A strong argument for obviousness could be made by combining US12039504B1 with general knowledge in the art regarding image quality assessment and user feedback in camera applications.

Combination: US12039504B1 + General knowledge of image quality assessment and user feedback in mobile camera applications.

Explanation of Obviousness:

1. US12039504B1 establishes remote check deposit via mobile device: US12039504B1 clearly teaches the core concept of using a mobile device to capture a check image and transmit it to a financial institution for deposit. [cite: US12039504B1] This provides the framework for the application.
2. Motivation to improve image quality for processing: A PHOSITA would immediately recognize that the accuracy of OCR and subsequent processing of a check image (as taught by US12039504B1) is highly dependent on the quality of the captured image. Poor lighting, skew, warp, or improper framing (all addressed by US12159310's monitoring criteria) would lead to errors, rejections, and a poor user experience. [cite: US12159310B1] The patent itself highlights that "Capturing a digital image at a mobile device that allows for subsequent detection and extraction of the information from the digital image is difficult." [cite: US12159310B1]
3. General knowledge of image quality monitoring and feedback in camera applications: At the time of the priority date (2009), mobile devices with cameras were prevalent, and various camera applications commonly incorporated features to assist users in capturing better quality images. This included:
   • Live preview: All camera phones provided a live preview of what the camera was seeing.
   • Basic framing guides: Many cameras offered on-screen guides (e.g., grids) to help users compose shots.
   • Automatic focus/exposure: Cameras often had automatic mechanisms to adjust focus and exposure, which are rudimentary forms of "monitoring" for image quality (e.g., brightness and sharpness).
   • Feedback mechanisms: Digital cameras, including those on mobile devices, often provided visual or auditory feedback (e.g., "focused," "too dark," "too bright") to users to guide them in capturing a good photo. For example, some cameras would indicate if a face was detected or if the image was blurry.

Motivation to Combine:

A PHOSITA, aiming to improve the "efficient and accurate detection and extraction of the information pertaining to a check in the digital image" [cite: US12159310B1] for a mobile check deposit system (as in US12039504B1), would have been motivated to combine the concept of mobile check deposit with the known techniques for image quality monitoring and user feedback from general camera applications. It would be an obvious design choice to adapt existing image monitoring and feedback techniques to the specific context of capturing a check.

• For "monitoring prior to capture": Knowing that image quality is crucial for OCR and check processing, a PHOSITA would naturally think of applying known image analysis techniques before committing to a capture. This pre-capture analysis prevents users from submitting unusable images, thus improving efficiency for both the user and the financial institution.
• For "monitoring criteria": The specific monitoring criteria mentioned in US12159310 (light contrast, brightness, positioning, dimensions, skewing, warping, corner detection, MICR line detection) [cite: US12159310B1] are all well-known parameters for evaluating document image quality in the broader field of image processing and document scanning. Applying these to a check image for remote deposit would be a straightforward application of existing technical knowledge to a new context.
• For "automatic capture functionality": Once suitable monitoring criteria are established, it would be an obvious engineering decision to automate the capture process when these criteria are met. This removes user variability and ensures only high-quality images are captured, further enhancing efficiency and accuracy. This is analogous to "smile detection" or "blink detection" auto-capture features present in some cameras around that time, where an image is automatically taken when certain visual criteria are met.
• For "feedback": Providing feedback to the user to guide them in positioning or lighting the check (e.g., "go closer," "tilt camera down") [cite: US12159310B1] is a common and obvious way to interact with users in any application requiring precise image capture.

Conclusion on Obviousness:

While US12039504B1 establishes the core "mobile check deposit" concept, the specific enhancements of "monitoring prior to capture" and "auto-capture functionality via video frame processing" in US12159310 appear to be an obvious combination of the known mobile check deposit system with readily available and well-understood image processing and user interface techniques for improving image quality in camera applications. A PHOSITA would have been motivated to make these combinations to solve the known problem of poor image quality in remote document capture, leading to more efficient and accurate processing of mobile check deposits.

Without the specific claims of US12159310, it is difficult to provide a definitive claim-by-claim obviousness analysis. However, based on the abstract and detailed description of the invention, the general inventive concept of pre-capture monitoring and auto-capture based on quality criteria for mobile check deposit would likely be considered obvious in light of US12039504B1 and the general state of the art in mobile camera and image processing technologies at the priority date.