Fresh From the Bench: Latest Precedential Patent Case

CASE OF THE WEEK

Fintiv, Inc. v. Paypal Holdings, Inc., Appeal No. 2023-2312 (Fed. Cir. Apr. 30, 2025)

In its only precedential patent opinion last week, the Federal Circuit affirmed a district court’s determination that the terms “payment handler” and “payment handler service” were means-plus-function terms subject to pre-AIA 35 U.S.C. § 112, par. 6, and that claims reciting the terms were invalid as indefinite.

The case concerned four patents directed to a “cloud-based transaction system” or “mobile wallet system” that patent owner Fintiv asserted were infringed by PayPal.  Several patent claims recited “a payment handler [service]” that interacts with application programming interfaces (“APIs”) of different payment processors.  Following claim construction, the district court found that the “payment handler” terms did not connote definite structure to a person of ordinary skill in the art, and that because the specification did not recite specific structure or an algorithm for performing the recited functions, the claims were invalid as indefinite.

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Editors:

Nika Aldrich, IP Litigation Group Leader, Schwabe

Jason A. Wrubleski, Shareholder