by Audrey Millemann

In Net MoneyIN, Inc. v. Verisign, Inc., 545 F.3d 1359 (Fed. Cir. 2008), the Federal Circuit Court of Appeals clarified the test for anticipation under 35 U.S.C. §102(a).

The patents in the case covered systems for conducting credit card transactions over the internet. The existing systems involve four different entities: a customer, the issuing bank for the customer’s credit card, a merchant, and the merchant’s bank. The inventor developed his system in response to two problems with the existing systems. First, the existing systems required prospective purchasers to send their confidential credit card information to an unknown merchant over the Internet. Second, in the existing systems, the banks that had issued the customers’ credit cards imposed stringent requirements on merchants.
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