Ex Parte Mehew et al

Patent Trial and Appeal Board

Oct 31, 2018

12894456 (P.T.A.B. Oct. 31, 2018)

UNITED STA TES p A TENT AND TRADEMARK OFFICE
APPLICATION NO. FILING DATE FIRST NAMED INVENTOR
12/894,456 09/30/2010
20350 7590 11/02/2018
KILPATRICK TOWNSEND & STOCKTONLLP
Mailstop: IP Docketing - 22
1100 Peachtree Street
Suite 2800
Atlanta, GA 30309
Evans Mehew
UNITED STATES DEPARTMENT OF COMMERCE
United States Patent and Trademark Office
Address: COMMISSIONER FOR PATENTS
P.O. Box 1450
Alexandria, Virginia 22313-1450
www .uspto.gov
ATTORNEY DOCKET NO. CONFIRMATION NO.
90945-788292 (Ol 7900US) 6008
EXAMINER
CAMPEN, KELLY SCAGGS
ART UNIT PAPER NUMBER
3691
NOTIFICATION DATE DELIVERY MODE
11/02/2018 ELECTRONIC
Please find below and/or attached an Office communication concerning this application or proceeding.
The time period for reply, if any, is set in the attached communication.
Notice of the Office communication was sent electronically on above-indicated "Notification Date" to the
following e-mail address(es):
ipefiling@kilpatricktownsend.com
KTSDocketing2@kilpatrick.foundationip.com
PTOL-90A (Rev. 04/07)
UNITED STATES PATENT AND TRADEMARK OFFICE
BEFORE THE PATENT TRIAL AND APPEAL BOARD
Ex parte EV ANS MEHEW, KIMBERLY DUNWOODY,
and GAIL GALUPP0 1
Appeal2017-007415
Application 12/894,456
Technology Center 3600
Before: ELENI MANTIS MERCADER, JAMES R. HUGHES, and
CATHERINE SHIANG, Administrative Patent Judges.
HUGHES, Administrative Patent Judge.
DECISION ON APPEAL
STATEMENT OF THE CASE
Appellants seek our review under 35 U.S.C. § 134(a) of the
Examiner's decision rejecting claims 1-22, which constitute all the claims
pending in this application. See Final Act. 1-2; Appeal Br. 1.2 We have
jurisdiction under 35 U.S.C. § 6(b). We Affirm.
1 According to Appellants, the real party in interest is the W estem Union
Company. Appeal Br. 3.
2 We refer to Appellants' Specification filed Sept. 30, 2010 ("Spec.");
Appeal Brief filed Feb. 16, 2016 ("Appeal Br.") Supplemental Appeal Brief
filed June 16, 2016 ("Supp. Appeal Br."); and Reply Brief filed Apr. 10,
2017 ("Reply Br."). We also refer to the Examiner's Final Office Action
Appeal2017-007415
Application 12/894,456
Appellants' Invention
The invention "relates generally to financial transfers" (Spec. ,r 2).
More specifically Appellants' invention relates to systems and methods for
improving the security of financial transactions conducted using a mobile
(user) device. See Spec. ,r 4. The process (method) for providing improved
security of a financial transaction conducted at a user device collects unique
device identifying data from the user device, including data relating to
features of the user device and data relating to use of the user device. The
method transmits the unique device identifying data to a host computer and
stores the data as a reference unique device identifier. When a user conducts
a financial transaction on the user device, the process transmits current
unique device identifying data collected at the user device ( when the
financial transaction is initiated) to the host computer and compares the
current unique device identifying data to the unique device identifier. Based
on the comparison, the process determines, at the host computer, whether to
authorize the financial transaction. See Spec. ,r,r 5-6; Abstract.
Representative Claim
Independent claim 1, reproduced below, further illustrates the
invention:
1. A method for providing security to a financial
transaction conducted at a user device, comprising:
initially collecting unique device identifying data from the
user device, the unique device identifying data including both
data relating to features of the user device and data relating to use
of the user device;
mailed Aug. 14, 2015 ("Final Act."), and Answer mailed Feb. 9, 2017
("Ans.").
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transmitting the initially collected unique device
identifying data to a host computer, and storing the initially
collected unique device identifying data at the host computer as
a reference unique device identifier;
when a financial transaction is to be conducted at the user
device, transmitting current unique device identifying data
collected at the user device to the host computer, the current
unique device identifying data corresponding to the unique
device identifying data initially collected at the user device;
comparing the current unique device identifying data to
the unique device identifier at the host; and
based on the comparison, determining, at the host
computer, whether to authorize the financial transaction.
App. Br. 16 ( Claims Appendix).
Re} ection on Appeal3
The Examiner rejects claims 1-22 under 35 U.S.C. § 101 as being
directed to patent-ineligible subject matter.
ISSUE
Based upon our review of the record, Appellants' contentions, and the
Examiner's findings and conclusions, the issue before us follows:
Did the Examiner err in finding Appellants' claims were directed to
patent-ineligible subject matter under 35 U.S.C. § 101?
ANALYSIS
Appellants argue independent claims 1, 14, and 15 (as well as
dependent claims 2-13 and 16-22) together as a group with respect to the
3 The Examiner withdrew the rejections under 35 U.S.C. §§ 102(b) and
103(a). See Ans. 6. Accordingly, we do not address Appellants' discussion
of the withdrawn rejections. See Appeal Br. 8-16.
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§ 101 rejection. See Appeal Br. 5-13. We select independent claim 1 as
representative of Appellants' arguments with respect to claims 1-22. 37
C.F.R. § 4I.37(c)(l)(iv).
The Examiner rejects the claims ( claim 1) as being directed to patent-
ineligible subject matter in that claim 1 is "directed to the abstract idea of a
fundamental economic practice (i.e. determining whether to authorize a
financial transaction) and/or a method of organizing human activity (i.e.
identifying a device to authorize a financial transaction)." Final Act. 7; see
Ans. 6-10. Additionally, the Examiner found the
additional elements or combination of elements in the claims ...
amount[] to no more than: (i) mere instructions to implement the
idea on a computer, and/or (ii) recitation of generic computer
structure that serves to perform generic computer functions that
are well-understood, routine, and conventional activities
previously known to the pertinent industry.
Final Act. 7-8; see Ans. 6-10.
Appellants summarize the Alice decision (Alice Corp. Pty. Ltd. v. CLS
Banklnt'l, 134 S.Ct. 2347 (2014)) and the USPTO's guidance concerning
patent-eligible subject matter (see Appeal Br. 5-8) and contend the claims
are not directed to the abstract idea proposed by the Examiner because "the
claims recite far more than identifying a device to authorize a financial
transaction" (Appeal Br. 9; see Appeal Br. 8-9). Appellants also contend
"Appellants' claims pose no risk of pre-emption of any fundamental
business practice or abstract idea, and are therefore patent-eligible" (Appeal
Br. 9; see Appeal Br. 9-10) and "the claims contain additional details
sufficient to ensure that the patent in practice amounts to significantly more
than a patent upon the [abstract idea] itself' (Appeal Br. 10 (quotations
omitted); see Appeal Br. 10-11 ). Appellants further contend a number of
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recent Federal Circuit case, in particular DDR Holdings-DDR Holdings,
LLC v. Hotels.com L.P., 773 F.3d 1245 (Fed. Cir. 2014}-support their
contentions that the instant claims are not directed to patent-ineligible
subject matter. See Appeal Br. 11-13.
In Appellants' Reply Brief, Appellants present more detailed
contentions with respect to the Examiner's Alice analysis. Appellants
contend "the claims improve a computer-related technology, as evidenced
from the support in the specification, the claims are not directed to an
abstract idea" (Reply Br. 6) and recite a "particular solution to a problem or
a particular way to achieve a desired outcome" (Reply Br. 6 ( quotations
omitted)) similar to the claims in McRO (McRO, Inc. v. Bandai Namco
Games Am. Inc., 837 F.3d 1299 (Fed. Cir. 2016)). See Reply Br. 2-7.
Appellants also reiterate that the claims do not preempt other approaches for
performing the allegedly abstract idea, similar to the claims in McRO. See
Reply Br. 7-8. Appellants further contend that the "alleged abstract ideas of
'authorize a financial transaction' or 'identifying a device to authorize a
financial transaction' are not abstract ideas in the form of a fundamental
economic activity or a method of organizing human activity." Reply Br. 8;
see Reply Br. 8-10. Appellants additionally contend that "the claims recite
elements that are significantly more than the alleged abstract idea." Reply
Br. 11; see Reply Br. 10-12.
Under 35 U.S.C. § 101, a patent may be obtained for "any new and
useful process, machine, manufacture, or composition of matter, or any new
and useful improvement thereof." The Supreme Court has "long held that
this provision contains an important implicit exception: Laws of nature,
natural phenomena, and abstract ideas are not patentable." Alice Corp. Pty.
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Ltd. v. CLS Bankint'l, 134 S.Ct. 2347, 2354 (2014) (quotingAss'nfor
Molecular Pathology v. Myriad Genetics, Inc., 569 U.S. 576, 589 (2013)).
The Supreme Court, in Alice, reiterated the two-step framework
previously set forth in Mayo Collaborative Services v. Prometheus
Laboratories, Inc., 566 U.S. 66, 77-80 (2012), "for distinguishing patents
that claim laws of nature, natural phenomena, and abstract ideas from those
that claim patent-eligible applications of those concepts." Alice, 134 S.Ct. at
2355. Assuming that a claim nominally falls within one of the statutory
categories of machine, manufacture, process, or composition of matter, the
first step in the analysis is to "determine whether the claims at issue are
directed to one of those patent-ineligible concepts," e.g., to an abstract idea.
Id. For example, abstract ideas include, but are not limited to, fundamental
economic practices, methods of organizing human activities, an idea of
itself, and mathematical formulas or relationships. Id. at 2355-57. If the
claims are not directed to an abstract idea, the inquiry ends. Otherwise, the
inquiry proceeds to the second step where the elements of the claims are
considered "individually and 'as an ordered combination' to determine
whether the additional elements 'transform the nature of the claim' into a
patent-eligible application." Alice, 134 S.Ct. at 2355 (quoting Mayo, 566
U.S. at 78-79). This second step is described as "a search for an 'inventive
concept'-i.e., an element or combination of elements that is ' ...
significantly more than ... the [ineligible concept] itself."' Id. at 2355
(alteration in original) (quoting Mayo, 566 U.S. at 72-73).
The Court acknowledged in Mayo, that "all inventions at some level
embody, use, reflect, rest upon, or apply laws of nature, natural phenomena,
or abstract ideas." Mayo, 566 U.S. at 71. We, therefore, look to whether the
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claims focus on a specific means or method that improves the relevant
technology or are instead directed to a result or effect that itself is the
abstract idea and merely invoke generic processes and machinery. See
Enfish, LLC v. Microsoft Corp., 822 F.3d 1327, 1336 (Fed. Cir. 2016).
Alice Step 1 Analysis
Turning to the first step of the eligibility analysis, "the first step in the
Alice inquiry ... asks whether the focus of the claims is on the specific
asserted improvement in computer capabilities ... or, instead, on a process
that qualifies as an 'abstract idea' for which computers are invoked merely
as a tool." Enfish, 822 F.3d at 1335-36. "The abstract idea exception
prevents patenting a result where 'it matters not by what process or
machinery the result is accomplished."' McRO, 837 F.3d at 1312 ( quoting
0 'Reilly v. Morse, 56 U.S. (15 How.) 62, 113 (1853)). "We therefore look
to whether the claims ... focus on a specific means or method that improves
the relevant technology or are instead directed to a result or effect that itself
is the abstract idea and merely invoke generic processes and machinery."
McRO, 837 F.3d at 1314.
We begin our analysis with a detailed interpretation of claim 1. Claim
1 recites a process ( method) for providing security for a financial transaction
conducted at a user device by collecting data ("unique device identifying
data from the user device," which includes "data relating to features of the
user device and data relating to use of the user device"). The collected data
is transmitted from the user device to a host computer and stored on the host
computer "as a reference unique device identifier." Subsequently, when a
user conducts a financial transaction on the user device, user device data
(which corresponds to the unique device identifying data initially collected
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at the user device) is collected and transmitted to the host computer-
"transmitting current unique device identifying data collected at the user
device to the host computer." The host computer compares the current data
(current unique device identifying data) to the previously stored data (unique
device identifier) and determines whether to authorize the financial
transaction. In sum, claim 1 is directed to collecting, organizing, storing,
and analyzing ( comparing) data to determine whether to authorize a
financial transaction.
Our interpretation concurs with the Examiner's, i.e., that the claim is
directed to "the abstract idea of a fundamental economic practice (i.e.
determining whether to authorize a financial transaction) and/or a method of
organizing human activity (i.e. identifying a device to authorize a financial
transaction)." Final Act. 7.
Appellants contend claim 1 is not directed to a fundamental economic
activity or a method of organizing human activity (see Reply Br. 8-10) in
that the claim improves a computer-related technology and recites a
particular solution to a problem similar to the claims in McRO (see Reply
Br. 2-7).
Appellants misconstrue the relevant law and precedent. The McRO
decision distinguished the at-issue claims from previous human-
implemented methods for performing animation. See McRO, 837 F.3d at
1314. Claim 1, unlike the claims in McRO, does not recite rules specifically
defining a computerized process that is different in kind from the previous
processes a human would use to collect and analyze information to
determine whether to allow a financial transaction. That is, there is no
aspect of claim 1 that defines a technological improvement, whether in a
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software algorithm or a hardware design. See McRO, 837 F.3d at 1314;
Enfish, 822 F.3d at 1335-36.
Further, with respect to step 1 of the Alice/Mayo analysis, instead of
using a fixed definition of an abstract idea and analyzing how claims fit ( or
do not fit) within the definition, "the decisional mechanism courts now apply
is to examine earlier cases in which a similar or parallel descriptive nature
can be seen-what prior cases were about, and which way they were
decided." Amdocs (Isr.) Ltd. v. Openet Telecom, Inc., 841 F.3d 1288, 1294
(Fed. Cir. 2016) (citing Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d
1350, 1353-54 (Fed. Cir. 2016)). As part of this inquiry, we must "look at
the 'focus of the claimed advance over the prior art' to determine if the
claim's 'character as a whole' is directed to excluded subject matter."
Affinity Labs of Texas, LLC v. DirecTV, LLC, 838 F.3d 1253, 1257 (Fed.
Cir. 2016).
Here, Appellants' claims generally, and independent claim 1 in
particular, relate to collecting, organizing, and analyzing information to
determine whether to authorize a financial transaction (see discussion
supra). That is, Appellants' claims relate to collecting, organizing, and
analyzing data utilizing un-recited processes or algorithms and devices to
make the determination (whether to authorize the transaction). See Abstract;
Spec. ,r,r 5-6. This is consistent with how Appellants describe the claimed
invention. See Appeal Br. 3 and Supp. Appeal Br. 2 citing Spec. ,r,r 6, 17,
30, 56.
The present claims are analogous to a number of cases in which courts
have identified similar claims as encompassing abstract ideas. Our
reviewing court has held that abstract ideas include gathering, organizing,
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analyzing, and manipulating information. Elec. Power Grp., 830 F.3d at
1353-54 (finding claims directed to a "combination of ... abstract-idea
processes ... of gathering and analyzing information" to be abstract).
Similarly, our reviewing court has held that abstract ideas include gathering,
organizing, analyzing, and storing information. See Two-Way Media Ltd. v.
Comcast Cable Commc 'ns, LLC., 874 F.3d 1329, 1337-38 (Fed. Cir. 2017)
( finding claims directed to the functional results of accumulating,
converting, and monitoring records manipulate data "but fail[] to do so in a
non-abstract way"); Content Extraction & Transmission LLC v. Wells Fargo
Bank, Nat'! Ass 'n, 776 F.3d 1343, 1345, 1347 (Fed. Cir. 2014) (finding the
"claims generally recite ... extracting data [and] recognizing specific
information from the extracted data" and that the "claims are drawn to the
basic concept of data recognition").
Here, the collection, organization, analysis, and manipulation of
information ( data }--to determine whether to authorize a financial
transaction-are analogous to the abstract ideas of collecting, analyzing, and
manipulating information discussed in Electric Power Group, Two-Way
Media, and Content Extraction.
Appellants' claims can also be distinguished from patent-eligible
claims such as those in McRO, Bascom (Bascom Global Internet Servs., Inc.
v. AT&T Mobility LLC, 827 F.3d 1341 (Fed. Cir. 2016)), and Enfzsh that are
directed to "a specific means or method that improves the relevant
technology" (McRO, 837 F.3d at 1314) or a "specific technical solution"
(Bascom, 827 F.3d at 1351-52) or "a specific improvement to the way
computers operate" (Enfish, 822 F.3d at 1336). Appellants' claims are
directed to the results of data analysis rather than a particular way of
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performing or inventive technology for performing a data comparison to
determine whether to authorize a financial transaction or, in other words,
"achiev[ing] these results in a non-abstract way." Two-Way Media, 874
F.3d at 1337-38 (quotations omitted). In summary, "the focus of the claims
is not on such an improvement in computers as tools, but on certain
independently abstract ideas that use computers as tools." Elec. Power Grp.,
830 F.3d at 1354. Thus, we agree with the Examiner that the claims are
directed to the abstract ideas of determining whether to authorizing a
financial transaction which is, alternately and collectively, a fundamental
economic practice, a method of organizing human activity, and collecting,
organizing, and analyzing information.
Appellants also contend that the claims do not preempt the
Examiner's asserted abstract idea (supra). See Appeal Br. 9-10; Reply Br.
7-8. We find Appellants' arguments unavailing of Examiner error.
Although preemption is the concern that drives the exclusionary principle of
judicial exceptions to patent-eligible subject matter (see Alice, 134 S. Ct. at
2354), preemption is not a separate test of patent-eligibility, but is inherently
addressed within the Alice framework. See Ariosa Diagnostics, Inc., v.
Sequenom, Inc., 788 F.3d 1371, 1379 (Fed. Cir. 2015) ("While preemption
may signal patent ineligible subject matter, the absence of complete
preemption does not demonstrate patent eligibility.").
Alice Step 2 Analysis
Having found Appellants' claims are directed to an abstract idea under
Alice's step 1 analysis, we next address whether the claims add significantly
more to the alleged abstract idea. As directed by our reviewing court, we
search for an "'inventive concept' sufficient to 'transform the nature of the
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claim into a patent-eligible application."' McRO, 837 F.3d at 1312 (quoting
Alice, 134 S.Ct. at 2355). The implementation of the abstract idea involved
must be "more than performance of 'well-understood, routine, [and]
conventional activities previously known to the industry."' Content
Extraction, 77 6 F .3 d at 134 7--48 ( alteration in original) ( quoting Alice, 134
S.Ct. at 2359). The "inventive concept" "must be significantly more than
the abstract idea itself, and cannot simply be an instruction to implement or
apply the abstract idea on a computer." Bascom, 827 F.3d at 1349 (citation
omitted).
Here, the Examiner determined that Appellants' claims do not add
significantly more. See Final Act. 7-8; Ans. 6-10. Appellants, on the other
hand, contend "the claims recite elements that are significantly more than
the alleged abstract idea." Reply Br. 11; see Appeal Br. 10-11; Reply Br.
10-12.
Appellants fail to persuade us of error in the Examiner's rejection
with respect to the second Alice step. We agree with the Examiner that
Appellants' claim 1 ( and the other pending claims) does not evince an
"inventive concept" that is significantly more than the abstract idea itself.
We agree with the Examiner that collecting, organizing, and analyzing
information, utilizing undisclosed means (algorithms, processes, and/or
devices) and utilizing a generic computer system and processor to make a
determination ( determine whether to authorize a financial transaction) does
not amount to significantly more than the abstract idea ( of determining
whether to authorize a financial transaction). See Final Act. 7-8; Ans. 6-10.
As pointed out by the Examiner, Appellants' Specification describes general
purpose computers performing routine and conventional
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processes/functionality. See Ans. 6-7 (citing Spec. ,r,r 24, 35). For example,
the Specification describes "mobile devices" including "any one or more of
various kinds of devices for communicating with network" "such as a
cellular phone, a personal communication device, or a notebook, notepad or
laptop computer" (Spec. ,r 24 ), "central processing units" and "storage
devices" (Spec. ,r 35) utilized to implement the recited processes-"mobile
device ... executes the fingerprint application to initiate the collection or
capture of device fingerprint data at the mobile device" (Spec. ,r 41 );
"authentication is controlled at a mobile wallet application running at a host
computer system" and the "fingerprint data is stored at the mobile device
and also communicated to a digital or mobile wallet (implemented at the
wallet application at the host)" (Spec. ,r 17); if "a fingerprint is authenticated
for a mobile device, the wallet application ... determines .... the
transaction is authorized" (Spec. ,r 56).
Appellants simply reiterate the limitations of claim 1 and conclude
that the limitations are not routine or conventional. See Appeal Br. 10-11;
Reply Br. 10-12. Appellants, however, do not explain in sufficient detail or
provide persuasive evidence showing how the limitations (individually and
in combination) are not routine or are unconventional or "result in [a] non-
conventional and non-generic arrangement of elements" (Reply Br. 12). As
we explain supra, we agree with the Examiner that Appellants' claim
limitations do not amount to significantly more than the abstract idea of
collecting, organizing, and analyzing information to determine whether to
authorize a financial transaction by performance of well-understood, routine,
and conventional activities.
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With respect to Appellants' arguments concerning DDR Holdings, in
that the instant claims allegedly improve the operation of a computer system,
we disagree. See Appeal Br. 11-13. In DDR Holdings, the court held that a
claim may amount to more than an abstract idea recited in the claims when it
addresses and solves problems only encountered with computer technology
and online transactions, e.g., by providing (serving) a composite web page
rather than adhering to the routine, conventional functioning of Internet
hyperlink protocol. See DDR Holdings, 773 F.3d at 1257-59. In contrast
and as discussed supra, claim 1 simply collects, organizes, and analyzes data
to make a determination ( determine whether to authorize a financial
transaction) using known conventional computers and/or equipment. See
supra. Despite Appellants' arguments to the contrary, nothing in claim 1
recites a specific improvement to the way computers operate. The
collection, organization, and analysis of information (to make a
determination whether to authorize/allow a financial transaction) is not a
solution to a technical problem as discussed in DDR Holdings.
Rather, making a determination to allow a transaction based on
analyzed information (a comparison), is a commercial solution to a routine
and conventional activity involving financial transactions-making a
determination whether to allow a transaction is fundamental to the
transaction process-it is not a technical solution to a computer or
networking problem. This commercial solution may be assisted using a
general purpose computer (see Spec. ,r,r 24, 35) to perform the data
collection, transmission, storage, and analysis processes, and determine
whether to authorize a transaction. The commercial solution does not,
however, improve how the computers themselves function. As we
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previously explained, the instant claims are more akin to the claims for
analyzing information found to be abstract. See Elec. Power Grp., 830 F.3d
at 1353.
We agree with the Examiner that the additional limitations, separately,
or as an ordered combination, do not provide meaningful limitations (i.e., do
not add significantly more) to transform the abstract idea into a patent
eligible application. See, e.g., Ans. 6-10. The claim merely recites
functions (processes) for collecting and analyzing data using known
conventional computers and/ or equipment to communicate/transmit data and
make a determination. Such conventional computer and communication
processes "do not alone transform an otherwise abstract idea into patent-
eligible subject matter." Fair Warning IP, LLC v. Iatric Sys., Inc., 839 F.3d
1089, 1096 (Fed. Cir. 2016) (citing DDR Holdings, 773 F.3d at 1256).
For at least the reasons above, we are not persuaded of Examiner error
in the rejection of claim 1 under 35 U.S.C. § 101. Thus, we sustain the
Examiner's rejection under§ 101 of independent claim 1, as well as
independent claims 14 and 15, and dependent claims 2-13 and 16-22, which
were not argued separately.
CONCLUSION
Appellants have not shown that the Examiner erred in rejecting claims
1-22 under 35 U.S.C. § 101.
DECISION
We affirm the Examiner's rejection of claims 1-22.
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No time period for taking any subsequent action in connection with
this appeal may be extended under 37 C.F.R. § 1.136(a)(l )(iv).
AFFIRMED
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