On January 3, 2015, the PTAB issued two decisions invalidating the patents of TransUnion Intelligence, LLC after a Search America, Inc. petitioned to institute a covered business method patent review. Search America petitioned the PTAB after being sued for patent infringement in the District of Minnesota. Both patents were directed to a health care financing system in which health care grant information can be analyzed to determine whether a patient qualifies for a health care grant.

To invalidate the patents, the PTAB relied on two public use systems: 1) a computer-implemented eligibility system operated by the Texas Department of Human Services; and 2) manual method performed by the John T. Mather Memorial Hospital, in implementing a charity-care eligibility process. As evidence of each of the systems, the PTAB relied, not just on technical documents describing the systems, but also relied on the deposition transcripts from the district court proceedings describing the respective systems. For each system, the PTAB considered the respective deposition transcripts in combination with the technical documentation as a single 102(b) reference.

Search America Inc. v. Transunion Intelligence LLC, Nos. CBM2013-00038 and CBM2013-00037 (PTAB Feb. 3, 2015) [Giannetti, DeFranco, Boucher (opinion)].