D'agostino v. Mastercard International. Inc., No. 16-1592 (Fed. Cir. 2016)
Annotate this CaseD’Agostino’s patents disclose methods of effecting secure credit-card purchases by minimizing merchant access to credit card numbers and using a transaction code to complete a purchase instead. At the request of MasterCard, the Patent Board initiated inter partes review and cancelled all of the reviewed claims as unpatentable on the grounds of anticipation or obviousness. The claims involve either “limiting a number of transactions to one or more merchants,” or “limit[ing] transactions to a single merchant.” The Federal Circuit vacated and remanded, finding the Board’s claim interpretation unreasonable. The single-merchant limitation requires, simply, that, when the transaction code is requested, the request limits the number of authorized merchants to one but does not then identify the merchant, such identification occurring only later.
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