IP Law Daily, PATENT—Fed. Cir.: Patent applicant’s bank transfer by blockchain claims properly found indefinite, (Feb 11, 2025)

By Kevin M. Finson, J.D.

Patent claims for processing bank transfers using a blockchain were invalid as indefinite because they lacked a sufficiently specific structure corresponding to the claimed function of performing settlement of contracts and transfer of completion codes.

A patent application for bank transaction using blockchain was properly rejected by the Patent Trial and Appeal Board as indefinite, the U.S. Court of Appeals for the Federal Circuit has held. The sole independent claim was constructed as a means-plus-function claim in which the specification lacked the required structure corresponding to the claimed function (In re Raiz, No. 24-1533 (Fed. Cir. Feb. 11, 2025)).

Haim S. Raiz applied for a patent under U.S. Patent Application No. 16/536,175, directed to “computer software for effectuating bank transaction operations on a blockchain network.” The examiner rejected the claims for being directed to patent-ineligible subject matter because it was directed to a method for organizing human activity which lacked an inventive concept, and also for indefiniteness, because the sole independent claim as a means-plus-function claim in which the specification failed to disclose a structure corresponding to the limitation “means [for] utilizing established communication lines for settlement according to contracts and transferring completion code.” The Patent Trial and Appeal Board (PTAB) upheld both grounds for rejection. Raiz appealed to the Federal Circuit.

Indefiniteness. It was undisputed that the claimed function was “to perform settlement of contracts and transfer completion codes.” Raiz appealed the Board’s finding that the specification did not disclose an adequate structure corresponding to this function. Raiz argued that a monitor as the structure corresponded to that function. It was not argued that the disclosed monitor was anything more than a general-purpose computer which executed specialized software to settle contracts and transfer completion code, which the court understood to mean an algorithm. The court held that this explanation lacked the specificity required to qualify as a structure in a means-plus-function claim, lacking a step-by-step procedure for accomplishing a given result. Accordingly, the court affirmed the rejection on the ground of indefiniteness.

Because the Federal Circuit found the claims were invalid as indefinite and affirmed the rejection on that ground, it did not reach the issue of whether they were directed to a patent-ineligible abstract idea.

The Case is No. 24-1533.

Judge: Per Curiam.

Attorneys: Haim S. Raiz, pro se. Kakoli Caprihan, U.S. Patent and Trademark Office, for Coke Morgan Stewart.

Cases: Patent FedCirNews USPTO