In re Raiz v. USPTO: Federal Circuit Affirms Stellar Remittance Patent Rejection
Pro se applicant Haim S. Raiz challenged the USPTO’s rejection of his Stellar blockchain-based international remittance patent application (US16/536175) before the Federal Circuit. The court affirmed the finding of unpatentability in a 344-day appellate proceeding, leaving the claims dead and the technology open.
Federal Circuit closes door on Stellar blockchain remittance patent bid
This case arose from a patent prosecution dispute in which Haim S. Raiz, appearing pro se, sought to patent an external transaction agent system for facilitating international remittance transactions on the Stellar blockchain network (US App. No. 16/536175, published as US20200349638A1). The USPTO rejected the application on patentability grounds, and Raiz appealed that determination to the Court of Appeals for the Federal Circuit, filing on March 4, 2024.
On February 11, 2025, the Federal Circuit issued a summary order affirming the USPTO’s rejection. The single-word verdict — ‘AFFIRMED’ — confirms that the appellate panel found no reversible legal or factual error in the agency’s unpatentability determination. With affirmance, the application remains rejected and Raiz cannot pursue the specific claims as filed through further agency proceedings.
The 344-day duration is broadly consistent with expedited or routine Federal Circuit examination appeals, which often resolve without oral argument. The public record does not disclose the specific grounds of rejection — whether § 101 subject-matter eligibility, § 102 anticipation, or § 103 obviousness — nor the precise claim scope at issue. The pro se posture may have limited the sophistication of the arguments advanced, a factor that sometimes influences appellate outcomes in examination appeals.
Filing to Unpatentable in 344 days
344-day appellate proceeding — consistent with routine Federal Circuit patent examination appeals
Federal Circuit affirms: what the USPTO rejection ruling means for both parties
Affirmance means the lower decision stands without reversible error
When the Federal Circuit issues an ‘AFFIRMED’ order in a patent examination appeal, it signals the panel found no reversible error — legal or factual — in the USPTO’s rejection. The court does not substitute its judgment on patentability; it reviews whether the agency applied the correct legal standard and whether substantial evidence supports its factual findings. Affirmance here leaves the USPTO’s unpatentability ruling fully intact.
No reversible error foundRaiz’s Stellar remittance claims remain rejected and unenforceable
With the Federal Circuit’s affirmance, Raiz’s patent application (US16/536175) stays rejected. The applicant cannot revive these specific claims through further USPTO proceedings on this application. To pursue protection, Raiz would need to file a continuation with materially amended claims, seek en banc rehearing, or petition the Supreme Court — all of which face significant procedural and substantive hurdles given the affirmance.
Claims remain rejectedUSPTO’s rejection of the Stellar remittance application is fully upheld
The USPTO, represented by the Acting Under Secretary of Commerce, successfully defended its examination rejection before the Federal Circuit. The affirmance validates the agency’s patentability analysis and forecloses the applicant’s appellate options at this level. No remand was ordered, meaning the USPTO faces no further obligation to reconsider the rejected claims as presented.
Agency rejection validatedStellar remittance technology remains unpatented — sector stays open
The failure of this application means no enforceable patent on this particular Stellar Network external transaction agent for international remittance issued from US16/536175. Competitors and developers working on blockchain-based cross-border payment infrastructure on or adjacent to the Stellar protocol face no infringement risk from this specific application. However, other pending or granted patents in the remittance and blockchain payment space may still pose FTO concerns.
No blocking patent issuedFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | In re: HAIM S. RAIZ | Individual | Pro se patent applicant — holder of pending app. US16/536175 for Stellar blockchain remittanceSearch in Eureka ↗ |
| Defendant | DERRICK BRENT, Acting Under Secretary of Commerce for Intellectual Property and Acting Director of the United States Patent and Trademark Office | Individual | Acting Director of the USPTO, representing the agency’s unpatentability rejection on appealSearch in Eureka ↗ |
| Plaintiff counsel | Haim S. Raiz | Attorney | Counsel for In re: HAIM S. RAIZSearch in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Court of Appeals for the Federal CircuitSearch in Eureka ↗ |
Official order — verbatim text
The Federal Circuit’s order — ‘AFFIRMED’ with basis ‘Unpatentable’ — is terse but conclusive. At the appellate level, affirmance in an examination appeal confirms the panel applied the substantial evidence standard to factual findings and de novo review to legal conclusions, and found the USPTO’s rejection sound on both axes. No remand instruction suggests the panel saw no viable path for the claims even with further prosecution. The absence of a published opinion (consistent with Rule 36 summary affirmance practice) means no new legal precedent was set, but the outcome is binding on these specific claims.
US16/536175 — Stellar Network external transaction agent for international remittance
US Application No. 16/536175, published as US20200349638A1, covers a system described as a ‘Stellar Banks External Transaction Agent for International Remittance on Stellar Network.’ The application was filed in August 2019 and relates to an agent-based architecture that facilitates cross-border payment transactions using the Stellar distributed ledger protocol — a public blockchain designed for fast, low-cost international value transfer. The technical domain sits at the intersection of decentralized finance infrastructure and traditional correspondent banking workflows.
Strategically, this application targeted a commercially significant problem: reducing friction and cost in international remittance, a market historically dominated by incumbent wire transfer operators. Stellar-based remittance solutions have attracted attention from fintech startups and institutional players alike. Had the claims granted, they could have created a licensing or enforcement position against developers building transaction intermediary layers on the Stellar network. The USPTO’s rejection — affirmed by the Federal Circuit — suggests the claimed architecture lacked sufficient novelty or a patentable technical contribution over existing blockchain and remittance prior art.
Should you run an FTO against US16/536175 and the Stellar remittance patent family?
Product teams building external transaction agent layers, payment routing systems, or remittance APIs on the Stellar network should note that US16/536175 is now a dead application — it does not generate infringement risk. However, this cleared ground is narrow. If your product performs functions analogous to those claimed — intermediary transaction agents, multi-currency conversion steps, or Stellar-specific settlement orchestration — you should verify that no continuation, divisional, or related application in the same family remains active before treating the space as fully free.
PatSnap Eureka’s FTO Search Agent can map the full prosecution history and family tree of US16/536175, identify any surviving related applications, and cross-reference active third-party patents in the Stellar blockchain remittance domain. For R&D teams working on cross-border payment infrastructure, a targeted Eureka landscape search will surface live claim sets from larger fintech and blockchain patent holders that may present genuine FTO risk — risk that this case alone does not eliminate.
Run a freedom-to-operate analysis on US20200349638A1 to assess your product’s exposure
Run FTO in Eureka →Similar Federal Circuit appeals: blockchain and fintech patentability challenges
Federal Circuit examination appeals involving blockchain payment and fintech patent rejections by the USPTO — cases most relevant to the Stellar remittance technology domain.
What this case signals for the blockchain remittance IP landscape
The Federal Circuit’s affirmance reinforces persistent patentability headwinds for blockchain-based financial transaction systems.
Blockchain remittance claims face high § 101 and obviousness barriers
Applications covering transaction agent architectures on public blockchain networks like Stellar routinely encounter § 101 subject-matter eligibility rejections and § 103 obviousness challenges citing prior distributed ledger art. This affirmance, while non-precedential, is consistent with the broader USPTO and Federal Circuit skepticism toward fintech-adjacent blockchain claims that do not articulate a concrete technical improvement.
Pro se prosecution significantly increases appellate risk in complex patent domains
The pro se posture of this appeal likely constrained the quality of claim differentiation and appellate briefing. For innovators in the blockchain payments space, this case underscores the practical value of specialist patent prosecution counsel — particularly when claim language must navigate § 101 eligibility doctrine and distinguish a crowded prior art landscape in decentralized finance.
RAIZ v DERRICK — key questions answered
The Federal Circuit affirmed the USPTO’s rejection of US Application No. 16/536175 on February 11, 2025. The court found no reversible error in the agency’s unpatentability determination. The application, which covered a Stellar Network external transaction agent for international remittance, remains rejected and no enforceable patent issued.
The patent at issue was US Application No. 16/536175, published as US20200349638A1. The application claimed an external transaction agent system for facilitating international remittance on the Stellar blockchain network. The USPTO rejected the application on patentability grounds, and the Federal Circuit affirmed that rejection in February 2025.
When the Federal Circuit affirms a USPTO rejection in an examination appeal, the agency’s unpatentability determination stands with full legal force. The specific claims as filed cannot be revived through further USPTO proceedings on that application. The applicant’s remaining options are limited to en banc rehearing, Supreme Court certiorari, or filing a continuation application with materially different claims.
The death of this specific application removes it as an infringement risk. However, the broader Stellar and blockchain remittance patent space contains other active applications and granted patents from various filers. Practitioners and product teams should conduct a current freedom-to-operate analysis to identify any live claims from third parties that may cover similar technology before assuming the space is clear.
The public record does not indicate that the Federal Circuit issued a precedential opinion in this case. The terse ‘AFFIRMED’ verdict is consistent with a Rule 36 summary affirmance, which carries no precedential weight for future cases. The outcome is binding only on the specific claims of US Application No. 16/536175 and does not establish new law on blockchain or fintech patentability.
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