MasterCard International IncorporatedDownload PDFPatent Trials and Appeals BoardMar 16, 202014496572 - (D) (P.T.A.B. Mar. 16, 2020) Copy Citation UNITED STATES PATENT AND TRADEMARK OFFICE 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 APPLICATION NO. FILING DATE FIRST NAMED INVENTOR ATTORNEY DOCKET NO. CONFIRMATION NO. 14/496,572 09/25/2014 Debashis Ghosh P01594-US-UTIL 4007 98665 7590 03/16/2020 Otterstedt, Wallace & Kammer, LLP P.O. Box 381 Cos Cob, CT 06807 EXAMINER KAZIMI, HANI M ART UNIT PAPER NUMBER 3691 MAIL DATE DELIVERY MODE 03/16/2020 PAPER 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. PTOL-90A (Rev. 04/07) UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE PATENT TRIAL AND APPEAL BOARD Ex parte DEBASHIS GHOSH Appeal 2019-000487 Application 14/496,572 Technology Center 3600 Before JOSEPH L. DIXON, JOHN A. EVANS, and JAMES W. DEJMEK, Administrative Patent Judges. DIXON, Administrative Patent Judge. DECISION ON APPEAL STATEMENT OF THE CASE Pursuant to 35 U.S.C. § 134(a), Appellant,1 appeals from the Examiner’s decision to reject claims 1–18, 20, 21, 23, and 24. (Final Act. 1.) The claims 19 and 22 have been canceled. We have jurisdiction under 35 U.S.C. § 6(b). We affirm. 1 We use the word “Appellant” to refer to “Applicant” as defined in 37 C.F.R. § 1.42(a) (2017). Appellant identifies the real party in interest as MasterCard International Incorporated. (Appeal Br. 3.) Appeal 2019-000487 Application 14/496,572 2 CLAIMED SUBJECT MATTER The claims are directed to an apparatus, method, and computer program product for extracting insights from bill presentment data to determine credit worthiness and payment propensity of customers. Claim 1, reproduced below, is illustrative of the claimed subject matter: 1. A method comprising the steps of: obtaining access to a database of bill presentment data in an electronic bill presentment system connecting a plurality of customers with a plurality of billers, at least some of said billers comprising payment card issuers; extracting from said database of bill presentment data at least one presentment record for at least one of said customers, said at least one presentment record for said at least one of said customers comprising a presentment record for a bill of a credit card, said credit card having been issued to said at least one of said customers by one of said payment card issuers; and determining, based on said at least one presentment record for said at least one of said customers, at least one of credit worthiness of said at least one of said customers and payment propensity of said at least one of said customers. Appeal Br. 35 (Claims App., emphasis added). REJECTION2 Claims 1–18, 20, 21, 23, and 24 stand rejected under 35 U.S.C. § 101 because the claimed invention is directed to a judicial exception (abstract idea) without significantly more. 2 The Examiner withdrew the obviousness rejection. (Ans. 3.) Appeal 2019-000487 Application 14/496,572 3 OPINION 35 U.S.C. § 101 A. Legal Principles An invention is patent eligible if it claims a “new and useful process, machine, manufacture, or composition of matter.” 35 U.S.C. § 101. However, the Supreme Court has long interpreted 35 U.S.C. § 101 to include implicit exceptions: “[l]aws of nature, natural phenomena, and abstract ideas” are not patentable. E.g., Alice Corp. v. CLS Bank Int’l, 573 U.S. 208, 216 (2014). In determining whether a claim falls within an excluded category, we are guided by the Supreme Court’s two-step framework, described in Mayo and Alice. Id. at 217–18 (citing Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66, 75–77 (2012)). In accordance with that framework, we first determine what concept the claim is “directed to.” See Alice, 573 U.S. at 219 (“On their face, the claims before us are drawn to the concept of intermediated settlement, i.e., the use of a third party to mitigate settlement risk.”); see also Bilski v. Kappos, 561 U.S. 593, 611 (2010) (“Claims 1 and 4 in petitioners’ application explain the basic concept of hedging, or protecting against risk.”). Concepts determined to be abstract ideas and, thus, patent ineligible, include certain methods of organizing human activity, such as fundamental economic practices (Alice, 573 U.S. at 219–20; Bilski, 561 U.S. at 611); mathematical formulas (Parker v. Flook, 437 U.S. 584, 594–95 (1978)); and mental processes (Gottschalk v. Benson, 409 U.S. 63, 69 (1972)). Concepts determined to be patent eligible include physical and chemical processes, such as “molding rubber products” (Diamond v. Diehr, 450 U.S. 175, 192 Appeal 2019-000487 Application 14/496,572 4 (1981)); “tanning, dyeing, making water-proof cloth, vulcanizing India rubber, smelting ores” (id. at 182 n.7 (quoting Corning v. Burden, 56 U.S. 252, 267–68 (1853))); and manufacturing flour (Benson, 409 U.S. at 69 (citing Cochrane v. Deener, 94 U.S. 780, 785 (1876))). In Diehr, the claim at issue recited a mathematical formula, but the Supreme Court held that “[a] claim drawn to subject matter otherwise statutory does not become nonstatutory simply because it uses a mathematical formula.” Diehr, 450 U.S. at 187; see also id. at 191 (“We view respondents’ claims as nothing more than a process for molding rubber products and not as an attempt to patent a mathematical formula.”). Having said that, the Supreme Court also indicated that a claim “seeking patent protection for that formula in the abstract . . . is not accorded the protection of our patent laws, . . . and this principle cannot be circumvented by attempting to limit the use of the formula to a particular technological environment.” Id. (citing Benson and Flook); see, e.g., id. at 187 (“It is now commonplace that an application of a law of nature or mathematical formula to a known structure or process may well be deserving of patent protection.”). If the claim is “directed to” an abstract idea, we turn to the second step of the Alice and Mayo framework, where “we must examine the elements of the claim to determine whether it contains an ‘inventive concept’ sufficient to ‘transform’ the claimed abstract idea into a patent- eligible application.” Alice, 573 U.S. at 221 (quotation marks omitted). “A claim that recites an abstract idea must include ‘additional features’ to ensure ‘that the [claim] is more than a drafting effort designed to monopolize the [abstract idea].’” Id. (quoting Mayo, 566 U.S. at 77). Appeal 2019-000487 Application 14/496,572 5 “[M]erely requir[ing] generic computer implementation[] fail[s] to transform that abstract idea into a patent-eligible invention.” Id. The U.S. Patent and Trademark Office (“USPTO”) published revised guidance on the application of § 101. USPTO’s January 7, 2019 Memorandum, 2019 Revised Patent Subject Matter Eligibility Guidance, 84 Fed. Reg. 50 (“Memorandum”). Under that guidance, we first look to whether the claim recites: (1) any judicial exceptions, including certain groupings of abstract ideas (i.e., mathematical concepts, certain methods of organizing human activity such as a fundamental economic practice, or mental processes); and (2) additional elements that integrate the judicial exception into a practical application (see Manual of Patent Examining Procedure (“MPEP”) § 2106.05(a)–(c), (e)–(h)). Only if a claim (1) recites a judicial exception and (2) does not integrate that exception into a practical application, do we then look to whether the claim: (3) adds a specific limitation beyond the judicial exception that is not “well-understood, routine, conventional” in the field (see MPEP § 2106.05(d)); or (4) simply appends well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception. See Memorandum. B. The Examiner’s Conclusions and Appellant’s Arguments The Examiner concludes the present claims recite certain methods of organizing human activity. Final Act. 3; Ans. 5 (“an abstract idea of extracting data to determine customer creditworthiness and payment history”). The Examiner also determines the present claims do not amount to significantly more than an abstract idea itself because the abstract idea is implemented using additional elements that are well-understood, routine, Appeal 2019-000487 Application 14/496,572 6 and conventional. (Final Act. 4 (“generic recitation of a processor performing its generic computer functions [see page 8, portable payment devices 102, 112, 142 and processor 130 of specification for generic computer functions] of obtaining access to a database of bill presentment data in an electronic bill presentment system;”) Ans. 5 (“generic computer components (see para [0117-0124] of the specification) are claimed to perform their basic functions of obtaining access to a database, extracting bill data from database and determining credit worthiness of a customer.” [Citing to the description of a Figure 5 in published application 2016/0092981 A1, published March 31, 2016 corresponding to pages 30–34 of the original Specification])). Appellant contends the Examiner does not establish a prima facie case of subject matter ineligibility because the Examiner fails to identify clearly the abstract idea and oversimplifies the claim. (Appeal Br. 8–19; Reply Br. 2–3.) Appellant also contends the Examiner's analysis has improperly oversimplified the claims instead of considering them as a whole. (Appeal Br. 9; Reply Br. 3.) Appellant argues “Embodiments of the claimed invention have concrete and tangible applications and represent significant improvements to technologies in the marketplace.” (Appeal Br. 17; Reply Br. 9.) The remainder of Appellant’s arguments regarding the alleged “improvements” are merely quotations from cases and the MPEP without any substantive argument regarding the specific claimed “improvement” in the claimed invention. Appellant further argues the present claims are necessarily rooted in technology to solve problems specifically arising in the realm of technology Appeal 2019-000487 Application 14/496,572 7 because in situations when a transaction decision process is taking too long, this problem is solved by modifying a computer system instead of hiring more human reviewers. (Appeal Br. 15; Reply Br. 13) (citing DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d 1245 (Fed. Cir. 2014)). Additionally, Appellant argues the present claims provides an unconventional technical solution and cite to the Specification at page 22, which provides an unclaimed “example,” and Appellant provides a list of additional citations to the Specification without specific argument thereto. (Appeal Br 15; Reply Br. 14.) Appellant does not specifically identify any additional elements, such as, “database of bill presentment data,” “electronic bill presentment system,” “memory,” “processor,” or “persistent storage device” that would be “significantly more” than the abstract idea. (Appeal Br. 14–19; Reply Br. 7–21.) Appellant further recites cases for the proposition that the Examiner should provide clear and convincing evidence to support the finding that the additional elements implementing the abstract idea are well-understood, routine, and conventional, but does not provide any specific argument that the Examiner has not performed the required findings. (Appeal Br. 14–19; Reply Br. 7–21 (citing Berkheimer v. HP Inc., 881 F.3d 1360 (Fed. Cir. 2018); Reply Br. 18.)) We disagree with any implied argument by Appellant regarding a lack of evidence and find that the Examiner provided citation to the Specification citing only generic computer components in the disclosed invention. (Ans. 5.) C. Discussion 1. Step 2A, Prong 1 Patent eligibility under 35 U.S.C. § 101 is a question of law that is Appeal 2019-000487 Application 14/496,572 8 reviewable de novo. See Dealertrack, Inc. v. Huber, 674 F.3d 1315, 1333 (Fed. Cir. 2012). We, therefore, conclude the emphasized portions of claim 1, reproduced above (see supra at 2), recite commercial interactions including sales activities or business relations because claim 13 requires bill presentment data and extracting data for determining customer creditworthiness and payment history to determine credit worthiness or payment propensity of customers. According to the Memorandum, commercial interactions including sales activities or business relations fall into the category of certain methods of organizing human activity. See Memorandum. Moreover, those certain methods of organizing human activity are a type of an abstract idea. See id.; see also Smart Sys. Innovations, LLC v. Chicago Transit Auth., 873 F.3d 1364, 1372 (Fed. Cir. 2017) (verifying payment information, as well as “financial transactions . . . and data collection related to such transactions” “are directed to an abstract idea under Alice step one.”); buySAFE, 765 F.3d at 1352–54 (Claims reciting sending and receiving communications over a computer network to facilitate online commercial transactions are directed to “contractual relations, which are intangible entities” and “constitute[] ‘a fundamental 3 Claim 1, reproduced above with emphases, recites similar features as independent claims 18 and 20. Appellant does not argue claims 2–13, 15, 16, 18,20, 21, 23, and 24 separately, but asserts the § 101 rejection of those claims should be withdrawn for at least the same reasons as argued for independent claim 1. (Appeal Br. 8–21.) We, therefore, group claims 1–13, 15, 16, 18,20, 21, 23, and 24 together and separately address Appellant's arguments to dependent claims 14 and 17. Appeal 2019-000487 Application 14/496,572 9 economic practice long prevalent in our system of commerce.’”). We, therefore, agree with the Examiner’s conclusion that the claims recite an “abstract idea of extracting data for determining customer creditworthiness and payment history is similar to cases found by the courts to be abstract idea” and “a generically computer-implemented solution to a business-related or economic problem” and the present claims recite certain methods of organizing human activity. (Final Act. 3–4, 6; Ans. 6.) Because the present claims recite commercial interactions including sales activities or business relations that fall into the category of certain methods of organizing human activity (i.e., an abstract idea), we proceed to prong 2. 2. Step 2A, Prong 2 The claims do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. In particular, we disagree with Appellant’s argument that, similar to Enfish, the present claims recite an improvement in computer- related technology.4 (Appeal Br. 14–16; Reply Br. 9–13.) The first step of obtaining access to a database in the first step of the method is merely insignificant extra-solution activity that could be performed alternatively by a person. Therefore, under the broadest reasonable interpretation, the claim starts the process that only requires acquiring data which is insignificant extra-solution activity. Appellant does not identify persuasively how the Specification sets forth an improvement in technology. The USPTO October 2019 Patent 4 Enfish, LLC v Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016) Appeal 2019-000487 Application 14/496,572 10 Eligibility Guidance Update (“Update”, available at https://www.uspto.gov/sites/default/files/documents/peg_oct_2019_update.p df), addresses how we consider any evidence that is presented to us. The Update states: During examination, the examiner should analyze the “improvements” consideration by evaluating the specification and the claims to ensure that a technical explanation of the asserted improvement is present in the specification, and that the claim reflects the asserted improvement. Generally, examiners are not expected to make a qualitative judgment on the merits of the asserted improvement. If the examiner concludes the disclosed invention does not improve technology, the burden shifts to applicant to provide persuasive arguments supported by any necessary evidence to demonstrate that one of ordinary skill in the art would understand that the disclosed invention improves technology. Any such evidence submitted under 37 C.F.R. § 1.132 must establish what the specification would convey to one of ordinary skill in the art and cannot be used to supplement the specification. For example, in response to a rejection under 35 U.S.C. § 101, an applicant could submit a declaration under § 1.132 providing testimony on how one of ordinary skill in the art would interpret the disclosed invention as improving technology and the underlying factual basis for that conclusion. Update at 13 (footnote omitted, emphasis added). In this case, the Examiner concludes the present claims do not recite an improvement to technology. (Final Act. 5; Ans. 5–6.) Consequently, we focus on any evidence Appellant cites pursuant to the Update. Here, Appellant cites pages 1, 12, 13–15, 26, 34 of the Specification as evidence, but we find these discussions unpersuasive of an improvement to a technology. (Appeal Br. 13–16; Reply Br. 14.) Therefore, the arguments in the Appeal Brief and Reply Brief citing to Enfish are merely attorney argument unsupported by evidence. (Appeal Br. 13–16; Reply Br. 14.) Appeal 2019-000487 Application 14/496,572 11 Even if the arguments were not attorney argument unsupported by evidence, which they are, the present claims recite broad limitations such as “at least one presentment record” (emphasis added) and “at least one of said customers,” (emphasis added). Because the broadest reasonable construction of limitations such as “at least one presentment record” (emphasis added) and “at least one of said customers,” (emphasis added) is one of each, we disagree with Appellant’s argument that there is an improvement in computer-related technology due to the limited amount of data required in the claimed invention. (Appeal Br. 13–16; Reply Br. 14.) In addition, in Enfish, the Federal Circuit considered how the present invention was superior to the technology in the prior art. That is, the court considered “the specification’s emphasis that ‘the present invention comprises a flexible, self-referential table that stores data,’” “[t]he specification also teaches that the self-referential table functions differently than conventional database structures,” and “traditional databases, such as ‘those that follow the relational model and those that follow the object oriented model[,]’ are inferior to the claimed invention.” Enfish, LLC v. Microsoft Corp., 822 F.3d at 1337 (citations omitted). Moreover, in Enfish, “‘[t]he structural requirements of current databases require a programmer to predefine a structure and subsequent [data] entry must conform to that structure,’ [and] the ‘database of the present invention does not require a programmer to preconfigure a structure to which a user must adapt data entry.’” Id. Based on the foregoing, the court determined the claims “achieve[d] other benefits over conventional databases, such as increased flexibility, faster search times, and smaller memory requirements.” Id. Unlike the claims of Enfish, the present claims do not recite an improvement Appeal 2019-000487 Application 14/496,572 12 in computer-related technology. Instead, the present claims recite an abstract idea as discussed supra, or at best, improving an abstract idea—not a technological improvement. The Specification indicates the additional elements (i.e., “database,” “an electronic bill presentment system,” “memory,” “processor,” “persistent storage device”) recited in the present claims are merely generic computer components used to implement the abstract idea. (Spec. 1, 12, 13–15, 26, 34.)5 Further, the generic computer components, individually and in combination, do not integrate the judicial exception into a practical application. (See Spec.4:8 section “Payment Devices and Associated Payment Processing Networks,” Spec.4:21–26 “For the avoidance of doubt, references to MasterCard, unless expressly stated to 10 be limited to MasterCard, are intended to be exemplary of an operator of an electronic BPPS and/or an operator of a payment card network, as will be appreciated from the context, whether or not qualified by words such as “or other operator.” Spec.12:9–12; “Furthermore, another non-limiting example of an electronic BPPS with which one or more embodiments of the invention can be employed is the CHECKFREE® platform available from Fiserv, Inc. of Brookfield, Wisconsin, USA.” Spec. 11:9–15; Section “System and Article of Manufacture Details,” Spec. 30–34 disclose generic hardware and commercially available software to carry out the disclosed invention.) Additionally, “a claim for a new abstract idea is still an abstract idea.” 5 We leave it to the Examiner in any further prosecution on the merits to further evaluate the corresponding structure, acts, or materials for the claimed “means” limitations of independent claim 20 and if the claim is sufficiently definite. Appeal 2019-000487 Application 14/496,572 13 Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 1151 (Fed. Cir. 2016) (emphasis added). “[U]nder the Mayo/Alice framework, a claim directed to a newly discovered law of nature (or natural phenomenon or abstract idea) cannot rely on the novelty of that discovery for the inventive concept necessary for patent eligibility.” Genetic Techs. Ltd. v. Merial L.L.C., 818 F.3d 1369, 1376 (Fed. Cir. 2016) (citations omitted). We further disagree with Appellant’s argument that, similar to DDR Holdings, the present claims are necessarily rooted in technology to solve problems specifically arising in the realm of technology because claims require “a database of bill presentment data in an electronic bill presentment system connecting a plurality of customers with a plurality of billers, at least some of said billers comprising payment card issuers.” (Appeal Br. 15.) The subject claim considered by the DDR court pertained to clicking on an advertisement for a third-party product displayed on a host’s website, the visitor is no longer being transported to the third party’s website. DDR Holdings, 773 F.3d at 1257. In DDR, instead of losing visitors to the third- party’s website, the host website can send its visitors to a web page on an outsource provider’s server that (1) incorporates “look and feel” elements from the host website and (2) provides visitors with the opportunity to purchase products from the third-party merchant without actually entering that merchant’s website. Id. at 1257–58. In contrast to the claims of DDR, the present claims do not recite incorporating “look and feel elements” from a host website and providing visitors with the opportunity to purchase products from a third-party merchant without actually entering the merchant’s website. Appeal 2019-000487 Application 14/496,572 14 We further disagree with Appellant’s argument that, similar to Amdocs,6 the present claims provides an unconventional technical solution by utilizing “a database of bill presentment data in an electronic bill presentment system connecting a plurality of customers with a plurality of billers, at least some of said billers comprising payment card issuers” that results in elements combined in an unconventional manner. (Appeal Br. 15.) The subject claim considered by the Amdocs court related to distributed architecture that led to load distribution, which was an advantage over the prior art because it made it easier to keep up with record flows, allow for smaller databases, and minimize impact on network and system resources. Amdocs (Israel) Ltd., 841 F.3d at 1303. Additionally, the court construed the claimed “enhance” to mean “to apply a number of field enhancements in a distrusted fashion.” Id. at 1292, 1300. In contrast to the claims of Amdocs, the present claims do not pertain to field enhancement in a distributed network. Appellant does not make any other arguments pertaining to step 2A, prong 2. Because the present claims recite an abstract idea that is not integrated into a practical application, we proceed to Step 2B. 3. Step 2B We agree with the Examiner’s determination that the additional elements implementing the abstract idea are well-understood, routine, and conventional. (Final Act. 4–6; Ans. 5 (citing Spec. 8).) The Specification supports the Examiner’s determination in this regard because the Specification indicates the additional elements (i.e., “database,” “an 6 Amdocs (Israel) Limited v. Openet Telecom, Inc., 841 F.3d 1288 (Fed. Cir. 2016). Appeal 2019-000487 Application 14/496,572 15 electronic bill presentment system,” “memory,” “processor,” “persistent storage device”) recited in the present claims are merely generic computer components used to implement the abstract idea. (Spec. 1, 12, 13–15, 26, 34.) Appellant’s Specification indicates these additional elements were well-understood, routine, and conventional components because it describes them at a high level of generality and in a manner that indicates that they were sufficiently well-known. Id. Moreover, the additional elements recited in the present claims, analyzed individually or in combination, do not result in the claims, as a whole, amounting to significantly more than the judicial exception. In addition, the Examiner identifies additional elements including “a generic recitation of a processor performing its generic computer functions.” (Final Act. 4.) Claim 1 does not even recite any additional element of a “processor” (dependent claim 17 recites “hardware processor” (Claim App., Appeal Br. 41)), but does set forth a “database.” Therefore, Appellant’s argument that the Examiner does not identify any additional elements is unavailing because no additional elements are recited in the language of independent claim 1. We also disagree with Appellant’s argument that, similar to Berkheimer, the Examiner fails to provide clear and convincing evidence to support the finding that the additional elements implementing the abstract idea are well-understood, routine, and conventional. (Reply Br. 18–19.) Indeed, as noted above, the Examiner provides citations to portions of the Specification to support this finding. (Ans. 5.) Furthermore, the Examiner cites to the Specification (Ans. 5 (citing Spec. 30–34 disclose generic hardware and commercially available software to carry out the disclosed Appeal 2019-000487 Application 14/496,572 16 invention)) and the Specification supports the Examiner’s determination in this regard because it explains that the additional elements are generic computer components. Appellant does not argue dependent claims 2–13, 15, 16, 23 and 24 separately, but asserts the § 101 rejection of those claims should be withdrawn for at least the same reasons as argued for independent claim 1. (Appeal Br. 8.) Accordingly, we sustain the Examiner’s rejection of: (1) independent claims 1, 18, 20, and 21; and (2) dependent claims 2–13, 15, 16, 23 and 24 under 35 U.S.C. § 101. We have only considered those arguments that Appellant actually raised in the Briefs. Arguments Appellant could have made, but chose not to make, in the Briefs have not been considered and are deemed to be waived. See 37 C.F.R. § 41.37(c)(1)(iv). Claims 14 and 17 With respect to claims 14 and 17, Appellant additionally “submits that the additional limitations recited in claims 14 and 17 are not ‘simply steps performed by a generic computer.’ For example, claim 14 specifies that the steps recited in claim 1 are carried out by an operator of said electronic bill presentment system.” (Reply Br. 22 (emphasis added).) We note that the “operator” is merely a corporate entity. We find Appellant’s argument to be unpersuasive to show an improvement to another technology and the additional limitation of an operator of the system does not evidence “significantly more” than the abstract idea. Appellant’s reliance on page 7 of the Specification merely evidences a broad interpretation of the claim language because “elements or components can combine or ‘mix and match’ one or more features.” (Spec. 7:13–14.) Appellant further identifies pages Appeal 2019-000487 Application 14/496,572 17 9–11 of the Specification which additionally identifies that “MasterCard,” a single corporate entity, “operate both a payment card network and an electronic bill presentment and payment system.” (Spec. 11:21–22.) But, Appellant does not show the additional element evidences “significantly more” than the abstract idea. DECISION The Examiner’s obviousness rejection is affirmed. DECISION SUMMARY Claims Rejected 35 U.S.C. § Reference(s)/Basis Affirmed Reversed 1–18, 20, 21, 23, 24 101 Eligibility 1–18, 20, 21, 23, 24 FINALITY AND RESPONSE No time period for taking any subsequent action in connection with this appeal may be extended under 37 C.F.R. § 1.136(a). See 37 C.F.R. § 1.136(a)(1)(iv). AFFIRMED Copy with citationCopy as parenthetical citation