Grecia v. TIAA, FSB member FDIC
- Valerie Caproni
- 1:19-cv-02813
- U.S. District Court · Southern District of New York
- 4
In Grecia v. TIAA, Judge Caproni denied reconsideration of dismissals, finding no controlling legal change, clear error, or manifest injustice.
William Grecia and the defendants in the five related cases: Bank of New York Mellon Corporation, Citibank, N.A., Morgan Stanley Smith Barney LLC, TIAA, FSB d/b/a TIAA Bank, and Samsung Electronics America, Inc.
What happened
Grecia v. TIAA, FSB d/b/a TIAA Bank concerns William Grecia’s motions asking the court to reconsider its earlier order dismissing materially identical claims in five related cases.
Grecia argued that a newer Federal Circuit decision changed the law, that the court made a claim-construction mistake, and that its analogy to military-base access was erroneous. The court rejected each argument, finding the newer decision neither controlling nor sufficiently similar, the mistake immaterial, and the analogy non-dispositive.
Judge Valerie Caproni denied Grecia’s motions for reconsideration in each case and directed the Clerk of Court to close all open motions.
The detailed version
- Grecia v. TIAA, FSB member FDIC · No. 1:19-cv-02813
- Valerie Caproni
- Apr. 24, 2020
Background
On March 13, 2020, the Court entered an opinion and order granting materially identical motions to dismiss filed by the defendants in five related cases brought by William Grecia. On March 27, Grecia moved for reconsideration in each case.
A motion for reconsideration is available only when the moving party identifies an intervening change in controlling law, new evidence, or a need to correct clear error or prevent manifest injustice. The court described this as a strict standard.
Arguments and Analysis
Grecia argued that the Federal Circuit’s decision in Illumina, Inc. v. Ariosa Diagnostics, Inc. created an intervening change in controlling law. The court disagreed. It said that, at most, Illumina was potentially persuasive authority and did not change controlling law. The court also found the decision materially different: Illumina concerned patent claims directed to a natural phenomenon, while Grecia’s claim concerned an abstract idea involving interoperable digital access. The court stated that Grecia’s method did not exploit a natural discovery or transform a natural phenomenon into something new.
Grecia also argued that the court had mistakenly used the construction of “verified web service” when discussing “verified web service account identifier.” The court acknowledged the mistake but found it immaterial because the relevant point was that the claim included a web service used to authenticate a user’s or device’s identity. The court said it would issue an amended opinion correcting that error. It also said the amended opinion would revise an overbroad statement about Claim 1’s coverage because the claim covered only computer-based methods of storing the information.
Finally, Grecia challenged the court’s analogy involving an authorized-access process at a military base. The court found that the analogy was illustrative and non-dispositive, not clear error, and said Grecia’s evidence concerning a procedure at Fort Bliss did not address the analogy as he understood it. The court also rejected his remaining arguments as repetitions of arguments made in opposition to the original dismissal motions.
Ruling
Judge Valerie Caproni denied Grecia’s motions for reconsideration. The order did not alter the earlier order granting the defendants’ motions to dismiss. The Clerk of Court was directed to close all open motions in the related cases.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.