As a result of the Federal Circuit?ÇÖs decision in Secure Axcess, LLC v. PNC Bank National Association in late February, it is not likely that a flood of Covered Business Method (?Ç£CBM?Ç¥) reviews will be coming any time soon.?á By statute, CBM reviews are reserved for patents relating to ?Ç£a financial product or service,?Ç¥ and under the Federal Circuit?ÇÖs narrow reading of that statute, the number of CBM reviews will likely remain quite small relative to the number of Inter Partes Reviews (?Ç£IPR?Ç¥).?á Although relatively few in number, CBM reviews have generated a number of precedential Federal Circuit opinions recently. In Secure Axcess, the Federal Circuit reversed the Patent Trial and Appeals Board?ÇÖs (?Ç£PTAB?Ç¥) decision finding that claims relating to website authentication were eligible for CBM review.?á No. 16-1353, slip op. at 3 (Fed. Cir. Feb. 21, 2017).?á Although earlier precedent, such as Blue Calypso, LLC v. Groupon, Inc., could… Continue Reading
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