IP Law Daily, PATENT—D. Del.: Fintech company’s infringement lawsuit against JPMorgan Chase succumbs to dismissal challenge, (Jun 2, 2026)

By Saurabh Kashyap, B.A., M.A., LL.B., LL.M.

The asserted patent merely applied conventional blockchain technology to the abstract idea of processing financial transactions and lacked an inventive concept under Section 101.

A Delaware federal court has dismissed an infringement lawsuit brought by a financial technology company against JPMorgan Chase & Co. and related entities after finding that the asserted patent was directed to patent-ineligible subject matter. It found that the asserted patent covered the abstract idea of processing financial transactions using blockchain technology and failed to disclose an inventive concept sufficient to satisfy the requirements of 35 U.S.C. § 101. Accordingly, the court granted JPMorgan’s motion to dismiss and dismissed the complaint with prejudice (Identitii Ltd. v. JPMorgan Chase & Co., No. 1:23-cv-01095-GBW (D. Del. May 29, 2026)).

Background. The plaintiff, Identitii, is a financial technology company that develops software solutions for payment processing, compliance, and transaction intelligence. JPMorgan Chase & Co. is one of the world's largest banking institutions and provides a broad range of financial services, including payment processing and banking infrastructure.

The asserted U.S. Patent No. 10,984,413 (the ’413 patent) relates to systems and methods for processing financial transactions using blockchain technology. The patent describes a framework in which transaction documents are transmitted through intermediary servers, enriched with additional data, recorded on a blockchain, and associated with generated tokens that can later be used to identify and verify transaction information.

Identitii filed suit in October 2023, alleging that JPMorgan infringed the patent. After the complaint was amended, JPMorgan moved to dismiss under Rule 12(b)(6), arguing that the asserted claims were invalid under Section 101 because they merely recited an abstract idea implemented through conventional computer technology.

Representative claim. Before addressing patent eligibility, the court considered whether claim 15 could serve as a representative claim for purposes of the Section 101 analysis. JPMorgan argued that the patent’s independent claims contained substantially similar limitations and that the dependent claims merely added generic computer components performing conventional functions. The court agreed and noted that Identitii did not meaningfully challenge the use of claim 15 as representative. Because the remaining claims were substantially similar and linked to the same alleged inventive concept, the court concluded that claim 15 fairly represented the patent for purposes of the eligibility inquiry.

Abstract idea. Applying the framework established in Alice Corp. Pty. Ltd. v. CLS Bank International, 573 U.S. 208 (2014), the court first examined whether the representative claim was directed to an abstract idea.

Identitii argued that the patent claimed a new blockchain-based and tokenized computer network architecture for processing payments. The company contended that the invention solved technological problems in financial transactions by enabling the secure handling of transaction information through blockchain technology.

The court rejected that characterization. Looking at the claim as a whole, it concluded that the patent merely recited a sequence of information-processing activities involving the receipt of transaction documents, extraction of transaction data, storage of information on a blockchain, generation of a transaction identifier, and association of that identifier with stored information.

The court found the patent analogous to the claims invalidated in PersonalWeb Technologies LLC v. Google LLC, 8 F.4th 1310 (Fed. Cir. 2021). There, the Federal Circuit held that claims involving content-based identifiers for organizing and retrieving information were directed to abstract ideas.

No technological improvement. A significant factor in the court’s analysis was the absence of any alleged improvement to blockchain technology itself. The court observed that Identitii repeatedly emphasized that blockchain technology enhances the security, reliability, and efficiency of financial transactions. However, the patent did not claim any innovation in the operation of a blockchain, any new blockchain protocol, or any improvement to token-generation techniques.

The court distinguished the case from Ancora Technologies, Inc. v. HTC America, Inc., 908 F.3d 1343 (Fed. Cir. 2018), where the Federal Circuit upheld claims directed to a specific improvement in computer security architecture. Unlike the claims in Ancora, the ’413 patent did not improve the operation of a computer system or blockchain network. Instead, it merely used those technologies as tools to facilitate financial transactions.

No inventive concept. Proceeding to Alice step two, the court examined whether the claim elements, individually or as an ordered combination, supplied an inventive concept capable of transforming the abstract idea into patent-eligible subject matter. Identitii argued that the ordered combination of claim limitations created a novel architecture for payment processing. The court disagreed, finding that the patent merely combined conventional components, including servers, databases, messaging systems, and blockchain technology, in expected ways.

Relying in part on Trading Technologies International, Inc. v. IBG LLC, 921 F.3d 1378 (Fed. Cir. 2019), the court explained that an abstract idea itself cannot supply the inventive concept required by Alice step two. The court found that the patent did not claim unconventional hardware, a new blockchain framework, or any novel tokenization mechanism.

The court also rejected Identitii’s argument that the inventive concept resided in the ordered arrangement of the claim elements. Citing BASCOM Global Internet Services, Inc. v. AT&T Mobility LLC, 827 F.3d 1341 (Fed. Cir. 2016), Identitii argued that even conventional components can become patent eligible when arranged in a nonconventional manner. The court found BASCOM distinguishable because the ’413 patent did not disclose any comparable technological arrangement. The patent specification expressly stated that the claimed steps need not be performed in any particular sequence, undermining the contention that the ordering of operations constituted an inventive concept.

Outcome. After concluding that the patent was directed to an abstract idea and lacked an inventive concept, the court held that the asserted claims were invalid under Section 101. Because the court found the patent itself ineligible, it declined to address JPMorgan’s remaining dismissal arguments and dismissed the First Amended Complaint with prejudice.

The Case is No. 1:23-cv-01095-GBW.

Judge: Williams, G.

Attorneys: John G. Day (Ashby & Geddes) for Identitii Ltd. Kelly E. Farnan (Richards, Layton & Finger, PA) for JPMorgan Chase & Co.

Companies: Identitii Ltd.; JPMorgan Chase & Co.

Cases: Patent DelawareNews TechnologyInternet