US International Trade Commission administrative law judge Dee Lord has granted another Section 101 summary determination motion (the ALJ’s third such decision since March 1, 2016), this time in Certain Automated Teller Machines, ATM Products, Components Thereof, and Products Containing Same, Inv. No. 337-TA-972, Initial Determination, Order 21 (June 28, 2016).

The patent at issue on the motion was U.S. Patent No. 7,314,163 (“Check Accepting and Cash Dispensing Automated Banking Machine System and Method”). According to the ruling, “[t]he patent describes a computerized system for depositing checks in a deposit-accepting apparatus (‘IDM’ or ‘intelligent depository module’ or ‘depository module’.).” The ALJ concluded that the Federal Circuit’s decision in Content Extraction & Transmission, LLC v. Wells Fargo Bank, Nat’l. Ass’n., 776 F.3d 1343 (Fed. Cir. 2014), cert denied, 136 S. Ct. 119 (Oct. 5, 2015), “comes very close to controlling the outcome here.” Quoting that case, the ALJ noted specifically that “the method described by the patents [that were invalid under Section 101] in Content Extraction could be ‘performed by software on an automated teller machine (ATM) that recognizes information written on a scanned check, such as the check’s amount, and populates certain data fields with that information in a computer’s memory.’”

The ALJ’s initial determination is now subject to review by the Commission within 30 days, or longer if the Commission determines to extend its time for review. For further context, our blogs reporting on ALJ Lord’s recent Section 101 rulings in Certain Activity Tracking Devices, Systems, and Components Thereof, Inv. No. 337-TA-963 are available here and here.