CAFC Reverses Attorney's Fees, Sanctions, While Affirming Obviousness in E-Banking Patent Case

CAFC affirmed Southern District of Florida's dismissal of mCom IP's patent infringement complaint against City National Bank of Florida, finding asserted claims from U.S. Patent No. 8862508 (e-banking system) obvious based on prior PTAB invalidation of related claims. However, CAFC reversed $87,000+ attorney's fees award under Section 285 and sanctions under Section 1927, ruling district court improperly found case exceptional without evidence of frivolous litigation conduct by mCom's counsel.