Early Warning Services, LLCDownload PDFPatent Trials and Appeals BoardAug 31, 202014949416 - (D) (P.T.A.B. Aug. 31, 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. 14/949,416 11/23/2015 Ravi Loganathan 090850-003910US-0962393 4602 20350 7590 08/31/2020 KILPATRICK TOWNSEND & STOCKTON LLP Mailstop: IP Docketing - 22 1100 Peachtree Street Suite 2800 Atlanta, GA 30309 EXAMINER CHEIN, ALLEN C ART UNIT PAPER NUMBER 3687 NOTIFICATION DATE DELIVERY MODE 08/31/2020 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): KTSDocketing2@kilpatrick.foundationip.com ipefiling@kilpatricktownsend.com PTOL-90A (Rev. 04/07) UNITED STATES PATENT AND TRADEMARK OFFICE ____________ BEFORE THE PATENT TRIAL AND APPEAL BOARD ____________ Ex parte RAVI LOGANATHAN, RONALD SCOTT ALCORN, JIE HE, STEVE FLEMING, and JEFF PARENT ____________ Appeal 2020-000740 Application 14/949,416 Technology Center 3600 ____________ Before JOHN A. JEFFERY, JOHN A. EVANS, and CATHERINE SHIANG, Administrative Patent Judges. EVANS, Administrative Patent Judge. DECISION ON APPEAL STATEMENT OF THE CASE Jurisdiction Appellant1 seeks our review under 35 U.S.C. § 134(a) of the Examiner’s non-final rejection of Claims 13 and 15–18, all pending claims. Appeal Br. 3. We have jurisdiction under 35 U.S.C. § 6(b). 1 We use the word “Appellant” to refer to “applicant” as defined in 37 C.F.R. § 1.42 (2017). Appellant states the real party in interest is Early Warning Services, LLC. Appeal Br. 3. Appeal 2020-000740 Application 14/949,416 2 We AFFIRM.2 Summary of the Invention The claims relate to a method of fraud detection. See Abstract. Invention Claim 13 is independent. Claims App. An understanding of the invention can be derived from a reading of Claim 13, which is reproduced in Table 1, infra. References Name Publication Number Date Moorman US 2008/0086409 A1 Apr. 10, 2008 Hodgin US 2011/0191219 A1 Aug 4, 2011 Baker US 2011/0270744 A1 Nov. 3, 2011 Nigel Morris-Cotterill, “Think Again Money Laundering,” http://foreignpolicy.com/2009/11/19/think-again-money-laundering/ (“Morris”). U.S. Bank Routing Number Database (5/9/2013), https://web.archive.Org/web/20130509032229/http://data-lists.com/bank- routing-number-database/ (“Routing Number Database”). 2 Rather than reiterate the arguments of Appellant and the Examiner, we refer to the Appeal Brief (filed June 25, 2019, “Appeal Br.”), the Reply Brief (filed November 4, 2019, “Reply Br.”), the Examiner’s Answer (mailed September 5, 2019, “Ans.”), the Non-Final Action (mailed January 30, 2019, “Non-Final Act.”), and the Specification (filed November 23, 2015, “Spec.”) for their respective details. Appeal 2020-000740 Application 14/949,416 3 HSBC, “Drug Money and Terrorist Laundering,” https://web.archive.org/web/20130313093741/https://en.wikipedia.org/wiki/ HSBC (“HSBC”). Rejections3 Claims Rejected 35 U.S.C. § References/Basis 13–184 101 Subject Matter Eligibility Non-Final Act. 3–6. 13, 15–175 103(a), Obviousness Moorman, Morris, Routing Number Database, Hodgin, HSBC. Non-Final Act. 7–14. 18 103 Moorman, Morris, Routing Number Database, Hodgin, Baker. Non-Final Act. 14–15. ANALYSIS We have reviewed the rejections of Claims 13 and 15–18 in light of Appellant’s arguments that the Examiner erred. We have considered in this Decision only those arguments Appellant actually raised in the Briefs. Any other arguments which Appellant could have made but chose not to make in the Briefs are deemed to be waived. See 37 C.F.R. § 41.37(c)(1)(iv). We provide the following explanation to highlight and address specific 3 The Application was examined under the AIA first inventor to file provisions. Non-Final Act. 2. 4 The header of the rejection refers to Claim 14 the merits of which we do not reach as it was previously cancelled. 5 Claims 15 and 16 are not mentioned in the header of the rejection, but are discussed in the body thereof. Appeal 2020-000740 Application 14/949,416 4 arguments and findings primarily for emphasis. We consider Appellant’s arguments as they are presented in the Appeal Brief and the Reply Brief. CLAIMS 13 AND 15–18: INELIGIBLE SUBJECT MATTER Appellant argues the merits of the claims as a group with reference to the limitations of Claim 13. Appeal Br. 4, 7. Therefore, we decide the appeal of the § 101 rejection on the basis of illustrative Claim 13 and refer to the rejected claims collectively herein as “the claims.” See 37 C.F.R. § 41.37(c)(1)(iv); In re King, 801 F.2d 1324, 1325 (Fed. Cir. 1986). We reviewed the record de novo. SiRF Tech., Inc. v. Int’l Trade Comm’n, 601 F.3d 1319, 1331 (Fed. Cir. 2010) (“Whether a claim is drawn to patent-eligible subject matter is an issue of law that we review de novo.”). Based upon our review of the record in light of recent policy guidance with respect to patent-eligible subject matter rejections under 35 U.S.C. § 101,6 we affirm the rejection of Claims 13 and 15–18 for the specific reasons discussed below. Appellant argues: “the Office Action improperly commingles the steps of the Alice analysis to arrive at its conclusion, and uses incorrect standards for patent eligibility.” Appeal Br. 4. Our analysis, below, based upon the cited Guidance, renders Appellant’s argument moot. 35 U.S.C. § 101 Section 101 provides that a patent may be obtained for “any new and useful process, machine, manufacture, or composition of matter, or any new 6 See 2019 Revised Patent Subject Matter Eligibility Guidance, 84 Fed. Reg. 50 (Jan. 7, 2019) (“Revised Guidance”). “All USPTO personnel are, as a matter of internal agency management, expected to follow the guidance.” Id. at 51; see also October 2019 Update at 1 (October 2019 Update: Subject Matter Eligibility) (hereinafter “October 2019 Update”). Appeal 2020-000740 Application 14/949,416 5 and useful improvement thereof.” 35 U.S.C. § 101. The Supreme Court has long recognized, however, that § 101 implicitly excludes “[l]aws of nature, natural phenomena, and abstract ideas” from the realm of patent-eligible subject matter, as monopolization of these “basic tools of scientific and technological work” would stifle the very innovation that the patent system aims to promote. Alice Corp. v. CLS Bank Int’l, 573 U.S. 208, 216 (2014) (quoting Ass’n for Molecular Pathology v. Myriad Genetics, Inc., 569 U.S. 576, 589 (2013)); see also Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66, 72–78 (2012); Diamond v. Diehr, 450 U.S. 175, 185 (1981). Under the mandatory Revised Guidance, we reconsider whether Appellant’s claims recite: 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 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 reach the issue of 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. A. Whether the claims recite a judicial exception Appeal 2020-000740 Application 14/949,416 6 The Revised Guidance extracts and synthesizes key concepts identified by the courts as abstract ideas to explain that the abstract-idea exception includes the following groupings of subject matter: (a) mathematical concepts,7 i.e., mathematical relationships, mathematical formulas, equations,8 and mathematical calculations9; (b) certain methods of organizing human activity—fundamental economic principles or practices (including hedging, insurance, mitigating risk); commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations); managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions)10; and (c) mental processes—concepts performed in the human mind (including observation, evaluation, judgment, opinion).11 7 Bilski v. Kappos, 561 U.S. 593, 611 (2010) (“The concept of hedging . . . reduced to a mathematical formula . . . is an unpatentable abstract idea . . . .”). 8 Diehr, 450 U.S. at 191 (“A mathematical formula as such is not accorded the protection of our patent laws . . . .”); Parker v. Flook, 437 U.S. 584, 594 (1978) (“[T]he discovery of [a mathematical formula] cannot support a patent unless there is some other inventive concept in its application.”). 9 SAP Am., Inc. v. InvestPic, LLC, 898 F.3d 1161, 1163 (Fed. Cir. 2018) (holding that claims to a “series of mathematical calculations based on selected information” are directed to abstract ideas). 10 Alice, 573 U.S. at 219–20 (concluding that use of a third party to mediate settlement risk is a “fundamental economic practice” and thus an abstract idea); see Revised Guidance, at 52 n.13 for a more extensive listing of “[c]ertain methods of organizing human activity” that have been found to be abstract ideas. 11 Mayo, 566 U.S. at 71 (“[M]ental processes[] and abstract intellectual concepts are not patentable, as they are the basic tools of scientific and Appeal 2020-000740 Application 14/949,416 7 The preamble of independent Claim 13 recites: “A method, comprising.” The limitations recited in the body of the claim are analyzed in Table I against the categories of abstract ideas as set forth in the Revised Guidance. As set forth in Table I below, we find limitations [b]–[i] of independent Claim 1 recite abstract ideas, i.e., “mental processes.” Table I Claim 1 Revised Guidance [a]12 maintaining one or more computerized databases holding records of check-based financial transactions and other information; An additional element that adds insignificant extra-solution activity to the judicial exception, i.e., mere data-gathering. See 84 Fed. Reg. at 55. [b] identifying from the one or more computerized databases a number of checks that have been drawn on U.S. subsidiaries of international financial institutions; Mental processes, i.e., concepts performed in the human mind (including an observation, evaluation, judgment, opinion). See 84 Fed. Reg. at 52. [c] for each of the identified checks, identifying the owner of the account into which the check was deposited; Mental processes, i.e., concepts performed in the human mind (including an observation, evaluation, judgment, opinion). See 84 Fed. Reg. at 52. [d] for each of a number of identified account owners, counting the number of the identified checks deposited into one or more accounts owned by the respective identified owner; and Mental processes, i.e., concepts performed in the human mind (including an observation, evaluation, judgment, opinion). See 84 Fed. Reg. at 52. technological work.” (quoting Gottschalk v. Benson, 409 U.S. 63, 67 (1972))). 12 Step designators, e.g., “[a],” were added to facilitate discussion. Appeal 2020-000740 Application 14/949,416 8 [e] producing a report of the respective number of identified checks deposited into one or more accounts owned by the respective identified owners; Mental processes, i.e., concepts performed with a pen and paper. See 84 Fed. Reg. at 52. [f] wherein identifying a number of checks that have been drawn on U.S. subsidiaries of international financial institutions further comprises, for each of a number of checks being investigated: identifying the check drawee financial institution from a routing number of a respective check; Mental processes, i.e., concepts performed in the human mind (including an observation, evaluation, judgment, opinion). See 84 Fed. Reg. at 52. [g] looking up the name of the drawee financial institution in the one or more computerized databases; Mental processes, i.e., concepts performed in the human mind (including an observation, evaluation, judgment, opinion). See 84 Fed. Reg. at 52. [h] searching the name of the drawee financial institution for one or more keywords indicating that the drawee financial institution is an international financial institution; and Mental processes, i.e., concepts performed in the human mind (including an observation, evaluation, judgment, opinion). See 84 Fed. Reg. at 52. [i] identifying the respective check as having been drawn on a U.S. subsidiary of an international financial institution based in part on the results of the keyword search. Mental processes, i.e., concepts performed in the human mind (including an observation, evaluation, judgment, opinion). See 84 Fed. Reg. at 52. Step 2A(ii): Judicial Exception Integrated into a Practical Application? If the claims recite a patent-ineligible concept, as we conclude above, Appeal 2020-000740 Application 14/949,416 9 we proceed to the “practical application” Step 2A(ii) wherein the “claims are considered in their entirety to ascertain whether their character as a whole is directed to excluded subject matter.” McRO, Inc. v. Bandai Namco Games Am. Inc., 837 F.3d 1299, 1312 (Fed. Cir. 2016) (quotes and citation omitted). This test determines whether the recited judicial exception is integrated into a practical application of that exception by: (a) identifying whether there are any additional elements recited in the claim beyond the judicial exception(s); and (b) evaluating those additional elements individually and in combination to determine whether they integrate the exception into a practical application. Appellant argues: “the Office Action appears to assume that only hardware elements can restrict a claim to a practical application. This position has no basis in law.” Appeal Br. 6. Appellant further argues: “the Office Action improperly discounts the method steps in its analysis, and that the method steps of claim 13 limit it to a practical application of any purported abstract idea.” Id. Our analysis considers each claimed element, separately in Table I, above, and the claims, as a whole, below, thus, rendering Appellant’s argument moot. For the reasons that follow, we conclude that Appellant’s claims do not integrate the judicial exception into a practical application. MPEP § 2106.05(a) “Improvements to the Functioning of a Computer or to Any Other Technology or Technical Field” “In determining patent eligibility, examiners should consider whether the claim ‘purport(s) to improve the functioning of the computer itself’ or ‘any other technology or technical field.’” MPEP § 2106.05(a). Appeal 2020-000740 Application 14/949,416 10 Appellant recognizes limitations that may constitute “significantly more” include improvements to the functioning of a computer used to implement the claimed invention.” See Appeal Br. 5. However, Appellant fails to direct our attention to limitations that may improve the functioning of the implementing computer, or to any other technology. For example, Appellant discloses: A computer system 101 is coupled to one or more databases 102. Databases 102 may be organized in any suitable manner. For example, all of the stored information may be considered to be one large database 102, or the information may be considered to be organized into a number of specialized databases. Spec., ¶ 17. Although we find the individual limitations [b]–[i] are directed to mental processes, the claims as a whole are directed to “[c]ertain methods of organizing human activity,” i.e., “commercial or legal interactions [] including . . . advertising, marketing or sales activities or behaviors; business relations.” See 84 Fed. Reg. at 52. Because, as Appellant discloses: [e]mbodiments of the invention provide methods and systems for analyzing information about financial transactions involving certain kinds of accounts. Such techniques may be helpful in uncovering fraud such as money laundering.” Spec., ¶ 14. The FairWarning court13 also noted that the claimed rules here were unlike those in McRO because they “are the same questions (though perhaps phrased with different words) that humans in analogous situations detecting fraud have asked for decades, if not centuries.” 839 F.3d. at 1094–95. 13 FairWarning IP, LLC v. Iatric Sys., Inc., 839 F.3d 1089 (Fed. Cir. 2016). Appeal 2020-000740 Application 14/949,416 11 MPEP § 2106.05(b): Particular Machine The Bilski machine-or-transformation test is only applicable to method (process) claims. However, “[r]egardless of what statutory category (‘process, machine, manufacture, or composition of matter,’ 35 U.S.C. § 101) a claim’s language is crafted to literally invoke, we look to the underlying invention for patent-eligibility purposes.” CyberSource Corp. v. Retail Decisions, Inc., 654 F.3d 1366, 1374 (Fed. Cir. 2011). Here, Claim 13, the sole independent claim, claims a method. We therefore, analyze the machine prong of the Bilski machine-or-transformation test. Appellant discloses generic machines and software are suitable: a computer system 900 such as may be used, in whole, in part, or with various modifications, to provide the functions of the system 100. Spec., ¶ 101. The computer system 900 may also comprise software elements, shown as being located within a working memory 970, including an operating system 974 and/or other code 978. Software code 978 may be used for implementing functions of various elements of the architecture as described herein. For example, software stored on and/or executed by a computer system, such as system 900, can be used in implementing the processes. . . . Spec., ¶ 104. We find no indication, nor does Appellant so direct our attention, that the claimed invention relies on non-generic devices or non-generic software. We, therefore, conclude Appellant’s claims fail to satisfy the machine prong of the Bilski machine-or-transformation test. Appeal 2020-000740 Application 14/949,416 12 MPEP § 2106.05(c): Particular Transformation This section of the MPEP guides: “Another consideration when determining . . . whether a claim recites significantly more . . . is whether the claim effects a transformation or reduction of a particular article to a different state or thing.” “Transformation and reduction of an article to a different state or thing is the clue to the patentability of a process claim that does not include particular machines.” Bilski, 561 U.S. at 658 (quoting Benson, 409 U.S. at 70). The claims select and analyze certain electronic data. Specifically, Claim 13 maintains a computerized database records of check-based financial transactions and produces a report that identifies a number of checks that have been drawn on U.S. subsidiaries of international financial institutions. The selection and analysis of electronic data is not a “transformation or reduction of an article into a different state or thing constituting patent-eligible subject matter[.]” In re Bilski, 545 F.3d 943, 962 (Fed. Cir. 2008) (emphasis added); see also CyberSource, 654 F.3d at 1375 (“The mere manipulation or reorganization of data . . . does not satisfy the transformation prong.”). Applying this guidance here, we conclude Appellant’s method claims fail to satisfy the transformation prong of the Bilski machine-or-transformation test. MPEP § 2106.05(e): Other Meaningful Limitations This section of the MPEP guides: Diamond v. Diehr provides an example of a claim that recited meaningful limitations beyond generally linking the use of the judicial exception to a particular technological environment. 450 U.S. 175 . . . (1981). In Diehr, the claim was directed to the use of the Arrhenius equation (an abstract idea or law of Appeal 2020-000740 Application 14/949,416 13 nature) in an automated process for operating a rubber-molding press. 450 U.S. at 177-78 . . . . The Court evaluated additional elements such as the steps of installing rubber in a press, closing the mold, constantly measuring the temperature in the mold, and automatically opening the press at the proper time, and found them to be meaningful because they sufficiently limited the use of the mathematical equation to the practical application of molding rubber products. 450 U.S. at 184, 187 . . . . In contrast, the claims in Alice Corp. v. CLS Bank International did not meaningfully limit the abstract idea of mitigating settlement risk. 573 U.S. . . . In particular, the Court concluded that the additional elements such as the data processing system and communications controllers recited in the system claims did not meaningfully limit the abstract idea because they merely linked the use of the abstract idea to a particular technological environment (i.e., “implementation via computers”) or were well-understood, routine, conventional activity. MPEP § 2106.05(e). “[T]he relevant question is whether the claims here do more than simply instruct the practitioner to implement the abstract idea . . . on a generic computer.” Alice, 573 U.S. at 225. Similarly as in Alice, we find that “[t]aking the claim elements separately, the function performed by the computer at each step of the process is ‘[p]urely conventional.’” 573 U.S. at 225 (citation omitted). “In short, each step does no more than require a generic computer to perform generic computer functions.” Id. We find that Appellant’s claims do not add meaningful limitations beyond generally linking the use of the judicial exception to a particular technological environment. Appeal 2020-000740 Application 14/949,416 14 MPEP § 2106.05(f): Mere Instructions to Apply an Exception Appellant does not persuasively argue that their claims do any more than to merely invoke generic computer components merely as a tool in which the computer instructions apply the judicial exception. MPEP § 2106.05(g): Insignificant Extra-Solution Activity The claims acquire and display data, which are classic examples of insignificant extra-solution activity. See, e.g., Bilski, 545 F.3d at 963 (en banc), aff’d sub nom, Bilski, 561 U.S. 593. MPEP § 2106.05(h): Field of Use and Technological Environment [T]he Supreme Court has stated that, even if a claim does not wholly pre-empt an abstract idea, it still will not be limited meaningfully if it contains only insignificant or token pre- or post-solution activity—such as identifying a relevant audience, a category of use, field of use, or technological environment. Ultramercial, Inc. v. Hulu, LLC, 722 F.3d 1335, 1346 (Fed. Cir. 2013) (citation omitted). We find the claimed data-manipulation is simply a field of use that attempts to limit the abstract idea to a particular technological environment. We are unpersuaded by Appellant’s arguments because the mere application of an abstract idea in a particular field is not sufficient to integrate the judicial exception into a practical application. See 84 Fed. Reg. at 55 n.32. In view of the foregoing, we conclude the claims are “directed to” a judicial exception. B. Well-understood, routine, conventional Because the claims recite a judicial exception and do not integrate that Appeal 2020-000740 Application 14/949,416 15 exception into a practical application, we must then reach the issue of whether the claim adds a specific limitation beyond the judicial exception that is not “well-understood, routine, conventional” in the field. 84 Fed. Reg. at 56. As discussed above, the written description describes the claimed computer system consistent with its being “well-understood, routine, [and] conventional.” C. Specified at a high level of generality It is indicative of the absence of an inventive concept where the claims simply append well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception. 84 Fed. Reg. at 56. The claims fail to recite any specific steps of an algorithm, nor does Appellant cite any Specification disclosure for the required specificity. We find the limitations are specified at such a high level of generality consistent with the absence of an inventive concept. Considering the claim limitations as an ordered combination adds nothing to the abstract idea that is not already present when the limitations are considered separately. See Mayo, 566 U.S. at 79. The ordered combination of limitations amounts to nothing more than certain mental processes implemented with generic computer components that operate “in a conventional way.” See also Alice, 573 U.S. at 225–26. Therefore, we conclude that none of the claim limitations, viewed “both individually and as an ordered combination,” amount to significantly more than the judicial exception in order to sufficiently transform the nature of the claims into patent-eligible subject matter. See Alice, 573 U.S. at 217 (internal quotations omitted) (quoting Mayo, 566 U.S. at 79). Appeal 2020-000740 Application 14/949,416 16 In view of the foregoing, we sustain the rejection of Claims 13 and 15–18 under 35 U.S.C. § 101. CLAIMS 13 AND 15–17: OBVIOUSNESS OVER MOORMAN, MORRIS, ROUTING NUMBER DATABASE, HODGIN, AND HSBC. Claim 13, the sole independent claim, recites, inter alia, “identifying from the one or more computerized databases a number of checks that have been drawn on U.S. subsidiaries of international financial institutions.” The Examiner finds Moorman teaches a portion of this limitation, i.e., “identifying from the one or more computerized databases a number of checks that have been drawn.” Non-Final Act. 8. The Examiner finds Moorman does not teach the remainder of the limitation, i.e., “on U.S. subsidiaries of international financial institutions,” but cites Morris for this portion of the claimed limitation. Non-Final Act. 9 (citing Morris, 1) (“And the globalization of financial-services companies means that money placed in a bank branch in a less regulated jurisdiction is easily transferred internally within the organization to a branch in a more regulated jurisdiction.”). The Examiner further finds Morris discloses “a U.S. Senate subcommittee report found that several major U.S. banks . . . had not paid sufficient attention to correspondent accounts held by foreign banks that were linked to money laundering, tax evasion, and fraud.” Id. Appellant argues Moorman is concerned with outgoing checks, but analyze the source of any checks. Appeal Br. 9. Appellant further argues whereas Morris discloses corresponding accounts are linked to money laundering, Morris fails to teach any analysis of where the money comes from. Id.; see Reply Br. 4. Appeal 2020-000740 Application 14/949,416 17 The Examiner finds all the steps of Moorman and Morris relate to money laundering. Ans. 7. We agree with Appellant that whereas Moorman and Morris each relates to money laundering, the cited portions of the prior art fail to teach the disputed limitation of the method. In view of the foregoing, we decline to sustain the rejection of Claims 13 and 15–17. CLAIM 18: OBVIOUSNESS OVER MOORMAN, MORRIS, ROUTING NUMBER DATABASE, HODGIN, BAKER. The Examiner does not apply Baker to teach the disputed limitation. See Ans. 7–10. In view of the foregoing, we decline to sustain the rejection of Claim 18. DECISION SUMMARY Claims Rejected 35 U.S.C. § Reference(s)/Basis Affirmed Reversed 13, 15–18 101 Eligibility 13, 15–18 13, 15–17 103 Moorman, Morris, Routing Number Database, Hodgin, HSBC 13, 15–17 18 103 Moorman, Morris, Routing Number Database, Hodgin, Baker. 18 Overall Outcome 13, 15–18 Appeal 2020-000740 Application 14/949,416 18 TIME PERIOD FOR 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)(1)(iv). See 37 C.F.R. § 41.50(f). AFFIRMED Copy with citationCopy as parenthetical citation