Ex Parte Peters et alDownload PDFPatent Trial and Appeal BoardFeb 22, 201913436230 (P.T.A.B. Feb. 22, 2019) Copy Citation UNITED STA TES p A TENT AND TRADEMARK OFFICE APPLICATION NO. FILING DATE FIRST NAMED INVENTOR 13/436,230 03/30/2012 Deborah A. Peters 79340 7590 02/26/2019 MANNA VA & KANG, P.C. 3201 Jermantown Road SUITE 525 FAIRFAX, VA 22030 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. Dl 1-113-02467-00-US 4735 EXAMINER BOSWELL, BETH V ART UNIT PAPER NUMBER 3600 NOTIFICATION DATE DELIVERY MODE 02/26/2019 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): ASHOKM@MANNA V AKANG.COM docketing@mannavakang.com PTOL-90A (Rev. 04/07) UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE PATENT TRIAL AND APPEAL BOARD Ex parte DEBORAH A. PETERS, TIMOTHY I. GOBRAN, RANJIT A. SINGH, EMMA C. POTTER, and BHARAT GOSAI Appeal 2017-011447 Application 13/436,230 1 Technology Center 3600 Before BRADLEY W. BAUMEISTER, ERIC B. CHEN, and HUNG H. BUI, Administrative Patent Judges. BUI, Administrative Patent Judge. DECISION ON APPEAL Appellants seek our review under 35 U.S.C. § 134(a) from the Examiner'sfinalrejectionofclaims 1,3,4,6, 7, 11, 12, 14, 15, 17, 19,and 20, which are all the claims pending in the application. Claims 2, 5, 8-10, 13, 16, and 18 are cancelled. App. Br. 29-40 (Claims App.). We have jurisdiction under 35 U.S.C. § 6(b). We AFFIRM. 2 1 According to Appellants, Accenture Global Services Limited is the real party in interest. App. Br. 3. 2 Our Decision refers to Appellants' Appeal Brief filed March 27, 2017 ("App. Br."); Reply Brief filed September 13, 2017 ("Reply Br."); Examiner's Answer mailed July 13, 2017 ("Ans."); Final Office Action mailed November 14, 2016 ("Final Act."); and original Specification filed March 30, 2012 ("Spec."). Appeal 2017-011447 Application 13/436,230 STATEMENT OF THE CASE Appellants' invention relates to a "role mapping and training tool [ e.g., software]" for an organization to effectively utilize its work force and resources in the context of "role mapping and training of its work force for specialized roles and tasks within the organization." Spec. ,r,r 2-3. According to Appellants, the "role mapping and training tool may include a rule-based system determining parameters for tasks, roles, jobs, individuals, and training courses, and determining mappings between the tasks, roles, jobs, individuals, and training courses." Abstract. Claims 1, 9, and 17 are independent. Claim 1 is illustrative of the claimed subject matter, as reproduced below: 1. A method of generating a training plan, the method compnsmg: receiving, by a processor, training course parameters for an entity; receiving, by the processor, role and job parameters for the entity, where the role and job parameters include job identifier (ID), job title, job description, organization, report to ID, and business, and transactional job parameters, where the role and job parameters include parameters pertaining to a role assigned to individuals associated with the entity, and where the role includes responsibilities to perform a task and the task include[ s] actions to be performed by the individual for a job associated with the job parameters; receiving by the processor, parameters for the individuals associated with the entity, where the receiving of the training course parameters, the role and job parameters and the parameters for individuals comprises: connecting, by the processor, with at least one enterprise application through an application service integration and communication layer; and receiving, by the processor, at least one of the training resource parameters, the role and job parameters 2 Appeal 2017-011447 Application 13/436,230 and the parameters for the individuals via an application program interface in the application service integration and communication layer; storing, by the processor, the training course parameters, the role and job parameters and the parameters for individuals, where the storing comprises: identifying types and categories or fields for each of the training course parameters, the role and job parameters and the parameters for the individuals; determining a table in the data repository to store each of the training course parameters, the role and job parameters and the parameters for the individuals; mapping the types and categories or fields for each of the training course parameters, the role and job parameters and the parameters for the individuals to a schema of the table in the data repository; and storing each of the training course parameters, the role and job parameters and the parameters for individuals in the table in the data repository according to the schema; determining segregation rules to mitigate risk, where the segregation rules identify roles, jobs, and tasks to be segregated, where the segregation rules include a trigger for the segregation that includes at least one of a particular process and country, and where the segregation rules include: a segregation rule that identifies exceptions to the segregation and provides rationale for the segregation; a segregation rule that specifies that a task be mapped to a particular role and cannot also be mapped to different role; and a segregation rule that specifies roles that cannot be assigned to a same individual, where the specified roles include a purchasing role and a purchase approval role, and the segregation rule indicates that the purchasing role and the approval role must be assigned to different individuals; generating, by the processor, a hierarchical mapping of roles to jobs based on the role and job parameters and the segregation rules; 3 Appeal 2017-011447 Application 13/436,230 comparing, by the processor, the hierarchical mapping to an organization chart of the entity to identify an imbalance between roles assigned to different organizational sections of the entity; mapping, by the processor, training courses to the jobs based on the training course parameters and the role to job mappmgs; mapping, by the processor, individuals to the jobs based on the parameters for individuals and the job parameters; and generating, by the processor, the training plan from the mappings for training courses to jobs and the mappings for individuals to jobs, where the training plan identifies at least one of the training courses for each of the individuals. App. Br. 29--31 (Claims App.). EXAMINER'S REJECTION Claims 1, 3, 4, 6, 7, 11, 12, 14, 15, 17, 19, and 20 stand rejected under 35 U.S.C. § 101 because the claimed invention is directed to an abstract idea without significantly more. Final Act. 4--7. DISCUSSION Patent-Eligible Subject Matter To determine whether claims are patent eligible under § 101, we apply the Supreme Court's two-step framework articulated in Alice Corp. v. CLS Bankint'l, 573 U.S. 208 (2014). First, we determine whether the claims are directed to a patent-ineligible concept: laws of nature, natural phenomena, and abstract ideas. Id. at 217. If so, we then proceed to the second step to consider the elements of the claims "individually and 'as an ordered combination"' to determine whether there are additional elements that "'transform the nature of the claim' into a patent-eligible application." Id. 4 Appeal 2017-011447 Application 13/436,230 In other words, the second step is to "search for an 'inventive concept'-i.e., an element or combination of elements that is 'sufficient to ensure that the patent in practice amounts to significantly more than a patent upon the [ ineligible concept] itself."' Id. at 21 7-18 ( alteration in original) ( quoting Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66, 72-73 (2012)). The Federal Circuit has described the Alice step-I inquiry as looking at the "focus" of the claims, their "character as a whole," and the Alice step- two inquiry as looking more precisely at what the claim elements add- whether they identify an "inventive concept" in the application of the ineligible matter to which the claim is directed. See Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d 1350, 1353 (Fed. Cir. 2016); Enfzsh, LLC v. Microsoft Corp., 822 F.3d 1327, 1335-36 (Fed. Cir. 2016); Internet Patents Corp. v. Active Network, Inc., 790 F.3d 1343, 1346 (Fed. Cir. 2015). Because there is no single definition of an "abstract idea" under Alice step 1, the Federal Circuit has adopted (1) the common law, analogy-driven approach (a.k.a. "analogous claim" test) to determine whether a claim is directed to an abstract idea, and (2) has instructed us "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 (Israel) Ltd. v. Openet Telecom, Inc., 841 F.3d 1288, 1294 (Fed. Cir. 2016) (citing Elec. Power Grp., 830 F.3d at 1353-54; accordUSPTO Memorandum, July 2015 Update: Subject Matter Eligibility, 3 (July 30, 2015), https://www.uspto.gov/sites/ default/files/ documents/ieg-july-2015- update. pdf (instructing examiners that "a claimed concept is not identified as 5 Appeal 2017-011447 Application 13/436,230 an abstract idea unless it is similar to at least one concept that the courts have identified as an abstract idea"). The PTO has acknowledged that the Federal Circuit's common law, analogy-driven approach (a.k.a. "analogous claim" test) was effective soon after Alice, but recently concluded that approach has since become impractical as the growing body of Federal Circuit precedent has become increasing more difficult for the Office and Examiners to apply in a predictable manner. In particular, the PTO has issued a new § 101 Memorandum that governs all patent-eligibility analysis under Alice and § 101. See 2019 Revised Patent Subject Matter Eligibility Guidance, 84 Fed. Reg. 50 (Jan. 7, 2019) ("PTO§ 101 Memorandum"). In that§ 101 Memorandum, the PTO has synthesized, for purposes of clarity, predictability, and consistency, key concepts identified by the courts as abstract ideas to explain that the "abstract idea" exception includes the following three groupings: ( 1) Mathematical mathematical calculations; concepts-mathematical formulas or equations, relationships, mathematical (2) Mental processes- concepts performed in the human mind (including an observation, evaluation, judgment, opinion); and (3) 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). 6 Appeal 2017-011447 Application 13/436,230 84 Fed. Reg. at 52. According to the PTO§ 101 Memorandum, "claims that do not recite [subject] matter that falls within these enumerated groupings of abstract ideas should not be treated as reciting abstract ideas," except in rare circumstances. Id. at 53. Even if the claims recite any one of these three groupings of abstract ideas, these claims are still not "directed to" a judicial exception (abstract idea) and, thus, are "patent-eligible" if "the claim as a whole integrates the recited judicial exception into a practical application of that Liudicial] exception." Id. "Integration into a practical application" requires an additional element or a combination of additional elements in the claim to apply, rely on, or use the judicial exception in a manner that imposes a meaningful limit on the judicial exception, such that the claim is more than a drafting effort designed to monopolize the exception. Id. For example, limitations that are indicative of "integration into a practical application" include: 1) Improvements to the functioning of a computer, or to any other technology or technical field - see MPEP § 2106.05(a); 2) Applying the judicial exception with, or by use of, a particular machine-see MPEP § 2106.05(b); 3) Effecting a transformation or reduction of a particular article to a different state or thing-see MPEP § 2106.05(c); and 4) Applying or using the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception - see MPEP § 2106.05(e). 7 Appeal 2017-011447 Application 13/436,230 In contrast, limitations that are not indicative of "integration into a practical application" include: 1) Adding the words "apply it" (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea - see MPEP § 2106.05(±); 2) Adding insignificant extra-solution activity to the judicial exception-see MPEP § 2106.05(g); and 3) Generally linking the use of the judicial exception to a particular technological environment or field of use - see MPEP § 2106.05(h). See PTO§ 101 Memorandum, 84 Fed. Reg. at 54--55 ("Prong Two"). Examiner's Determination of Patent-Ineligibility In rejecting claims 1, 3, 4, 6, 7, 11, 12, 14, 15, 19, and 20 under 35 U.S.C. § 101, the Examiner determines these claims are directed to an abstract idea of "generating a training plan [for an organization]," which is considered (1) a method of organizing human activity or (2) a mental process that can be performed in the human mind or by a human using a pen and paper, and include limitations that are analogous or similar to the concept of gathering, analyzing, and displaying information as discussed in Electric Power Group. Final Act. 4--5; Ans. 6-7 (citing Electric Power Group, LLP v. Alstom S.A., 830 F.3d 1350 (Fed. Cir. 2016) (holding that claims directed to "collecting information, analyzing it, and displaying certain results of the collection and analysis" are not patent-eligible)); see also CyberSource Corp. v. Retail Decisions, Inc., 654 F.3d 1366, 1370 (Fed. Cir. 2011) (holding that claims directed to "a method that can be performed 8 Appeal 2017-011447 Application 13/436,230 in the human mind, or by a human using a pen and paper" are not patent- eligible ). The Examiner also determines the claims fail to amount to "significantly more than the judicial exception" or contain an "inventive concept" because (1) "the invention does not improve any technology or technological field or the functioning of the computer itself'; (2) "the claims recite nothing more than using such generic computer elements to perform generic, well-understood and routine computer functions"; and (3) the claims are "nothing more than a generic computer system on a device." Ans. 7-8. Alice/Mayo-Step 1 (Abstract Idea) Turning to the first step of the Alice inquiry, Appellants argue the claims are not directed to an abstract idea because: (1) "the Examiner has failed to explain why the alleged abstract idea of generating a training map [ sic, plan for an organization] corresponds to a concept that the courts have identified as an abstract idea"; and (2) like the claims in McRO, Inc. v. Bandai Namco Games Am. Inc., 837 F.3d 1299 (Fed. Cir. 2016), "the present application describes significant technical improvements over conventional software training tools, including technical improvements that provide a processor implemented rules based system to retrieve training course parameters, generate a mapping, and to determine segregation rules." App. Br. 15-19. In the Reply, Appellants also argue (1) "the claims [] recite many features [ for example, storing, determining a table in a data repository, mapping fields to a schema of a table, and storing received data in the table according to the schema] that cannot be performed in the human mind or by 9 Appeal 2017-011447 Application 13/436,230 a human using a pen and paper"; (2) the claim features "are not directed to the abstract idea of Electric Power Group (i.e., collecting information, analyzing it, and displaying certain results of the collection and analysis) and are not similar to another other concept that the courts have identified as an abstract idea"; and (3) "[ s ]imilar to McRO, the present application describes a rule-based expert system to perform mappings [] and to generate a training plan" and "recites multiple, detailed segregation rules of the rule-based expert system for determining the hierarchical mapping and the training plan." Reply Br. 4--12. Appellants' arguments are not persuasive. At the outset, we note the newly published PTO § 101 Memorandum now governs all patent-eligibility analysis under Alice and§ 101 effective as of January 7, 2019. In particular, the PTO has now synthesized, for purposes of clarity, predictability, and consistency, the "abstract idea" exception to limit to three categories of abstract ideas as outlined in the PTO§ 101 Memorandum, 84 Fed. Reg. at 54--55. In this case, Appellants' invention relates to a "role mapping and training tool [ e.g., software]" for an organization to effectively utilize its work force and resources in the context of "role mapping and training of its work force for specialized roles and tasks within the organization." Spec. ,r,r 2-3. According to Appellants, the "role mapping and training tool may include a rule-based system determining parameters for tasks, roles, jobs, individuals, and training courses, and determining mappings between the tasks, roles, jobs, individuals, and training courses." Abstract. As correctly recognized by the Examiner (Ans. 6-7), "generating a training plan" for an organization to effectively utilize its work force and 10 Appeal 2017-011447 Application 13/436,230 resources, as recited in Appellants' independent claims 1 and 12, is plainly directed to a "certain method of organizing human activity" because "role mapping and training of [an organization's] work force for specialized roles and tasks within the organization" that uses "a rule-based system [for] determining parameters for tasks, roles, jobs, individuals, and training courses, and determining mappings between the tasks, roles, jobs, individuals, and training courses" (Spec. ,r,r 2-3; Abstract) is nothing more than managing behavior or relationships or interactions between people within an organization using certain rules or instructions-and is thus a subject matter that falls within the three types of abstract ideas identified by the PTO § 101 Memorandum. Moreover, "generating a training plan" for an organization is also a building block of a market economy and, as such, is an "abstract idea" beyond the scope of§ 101. See Alice, 573 U.S. at 220. Alternatively, "generating a training plan" for an organization's work force and resources using rules and parameters, as recited in Appellants' independent claims 1 and 12, also is nothing more than "mental processes" that could be performed in the human mind or by a human using a pen and paper-subject matter that falls within the three types of abstract ideas identified by the PTO § 101 Memorandum. See also CyberSource, 654 F .3d at 13 72-73 ("[A] method that can be performed by human thought alone is merely an abstract idea and is not patent-eligible under§ 101."); see also In re Comiskey, 554 F.3d 967, 979 (Fed. Cir. 2009) ("[M]ental processes-or processes of human thinking-standing alone are not patentable even if they have practical application."); Gottschalk v. Benson, 409 U.S. 63, 67 (1972) ("Phenomena of nature, ... mental processes, and abstract intellectual concepts are not patentable, as they are the basic tools of scientific and 11 Appeal 2017-011447 Application 13/436,230 technological work." (Emphasis added)). Additionally, mental processes remain unpatentable even when automated to reduce the burden on the user of what once could have been done with pen and paper. CyberSource, 654 F.3d at 1375 ("That purely mental processes can be unpatentable, even when performed by a computer, was precisely the holding of the Supreme Court in Gottschalk v. Benson."). For example, steps of "receiving ... [i] training course parameters for an entity ... [ii] role and job parameters for the entity ... [iii] parameters for the individuals associated with the entity" and "storing" the same, as recited in Appellants' method claim 1, can be performed by a human resource employee who simply collects various parameters such as roles and job descriptions within an organization. Similarly, steps of "identifying," "mapping the types and categories or fields for each of the training course parameters" and using "segregation rules to mitigate risk" and "specifies jobs" and then "mapping ... [i] training courses to the job ... [ii] individuals to the jobs" before "generating ... the training plan" can also be performed by the same human resource employee who reviews the jobs, job descriptions, the organization chart of the entity, and then maps the appropriate training courses, and assigns individuals to the jobs in order to generate a training plan on paper. We discern no additional element ( or combination of elements) recited in Appellants' claims 1 and 12 that integrates the judicial exception into a practical application. See PTO§ 101 Memorandum, 84 Fed. Reg. at 54--55 ("Prong Two"). For example, Appellants' claims 1 and 12 do not (1) improve the functioning of a computer or other technology, (2) are not applied with any particular machine (except for a generic computer), (3) do 12 Appeal 2017-011447 Application 13/436,230 not effect a transformation of a particular article to a different state, and ( 4) are not applied in any meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception. See MPEP §§ 2106.0S(a}-(c), (e}-(h). Furthermore, Appellants' reliance on McRO is misplaced. For example, the McRO '576 patent (U.S. Patent No. 6,307,576) describes a computer software for matching audio to a 3D animated mouth movement to provide lip-synced animation. McRO 's claims contain (i) specific limitations regarding a set of rules that "define[] a morph weight set stream as a function of phoneme sequence and times associated with said phoneme sequence" to enable computers to produce "'accurate and realistic lip synchronization and facial expressions in animated characters"' (McRO, 837 F.3d at 1313) and, when viewed as a whole, are directed to (ii) a "technological improvement over the existing, manual 3-D animation techniques" that uses "limited rules in a process specifically designed to achieve an improved technological result in conventional industry practice." McRO, 837 F.3d at 1316. In contrast to McRO, Appellants' claims and Specification are not directed to any type of technologies, but rather "generating a training plan" for an organization to utilize its work force and resources. See Spec. ,r,r 2-3; claims 1 and 12. As previously discussed, such a training plan that uses "a rule-based system [for] determining parameters for tasks, roles, jobs, individuals, and training courses, and determining mappings between the tasks, roles, jobs, individuals, and training courses" (Abstract) does not improve the computer functionality, as discussed in Enfzsh. Instead, generic 13 Appeal 2017-011447 Application 13/436,230 computers are merely used as a tool to facilitate these transactions. Enfish, 822 F.3d at 1335-36, 1338. As correctly recognized by the Examiner, Appellants' "invention does not improve any technology or technological field or the functioning of the computer itself. Ans. 8. Rather, Appellants' solution is a business solution to help an organization better use its work force and resources. For these reasons, we agree with the Examiner's determination that Appellants' claims 1, 3, 4, 6, 7, 11, 12, 14, 15, 17, 19, and 20 are directed to an abstract idea that is not integrated into a practical application. Alice/Mayo-Step 2 (Inventive Concept) In the second step of the Alice inquiry, Appellants argue ( 1) the claims include a combination of elements, for example, "features including, determining segregation rules, generating a hierarchical mapping of roles to jobs, mapping training courses to jobs, mapping individuals to the jobs, and generating a training plan from the mappings" that "amounts to significantly more than the abstract idea of generating a training plan"; and (2) "the Examiner has failed to present any prior art as to suggest that the claimed features are well-understood, routine, and conventional in the field." App. Br. 21-27. Appellants' arguments are not persuasive. Under current Federal Circuit precedent, an "inventive concept" under Alice step 2 can be established by showing, for example, that the patent claims: (1) provide a technical solution to a technical problem unique to the Internet, e.g., a "solution ... necessarily rooted in computer technology in order to overcome a problem specifically arising in the realm of computer networks" (DDR Holdings, 773 F.3d at 1257)); 14 Appeal 2017-011447 Application 13/436,230 (2) transform the abstract idea into "a particular, practical application of that abstract idea," e.g., "installation of a filtering tool at a specific location, remote from the end- users, with customizable filtering features specific to each end user" (BASCOM Global Internet Servs., Inc. v. AT&T Mobility LLC, 827 F.3d 1341, 1352, 1350 (Fed. Cir. 2016)); or (3) "entail[] an unconventional technological solution ([ e.g.,] enhancing data in a distributed fashion) to a technological problem ([e.g.,] massive record flows [that] previously required massive databases)" and "improve the performance of the system itself' (Amdocs, 841 F.3d at 1300, 1302). Similarly, as recognized by the PTO § 101 Memorandum, an "inventive concept" under Alice step 2 can also be evaluated based on whether an additional element or combination of elements: (1) adds a specific limitation or combination of limitations that are not well-understood, routine, conventional activity in the field, which is indicative that an inventive concept may be present (see MPEP § 2106.05(d)); or (2) simply appends well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception, which is indicative that an inventive concept may not be present. See PTO§ 101 Memorandum, 84 Fed. Reg. at 56. In this case, however, we find no element or combination of elements recited in Appellants' claims 1 and 12 that contains any "inventive concept" or adds anything "significantly more" to transform the abstract concept into a patent-eligible application. Alice, 573 U.S. at 221-22. For example, Appellants' abstract idea of "generating a training plan" for an organization's work force and resources using rules and parameters, as 15 Appeal 2017-011447 Application 13/436,230 recited in Appellants' independent claims 1 and 12, is not rooted in computer technology; nor does it (1) provide any technical solution to a technical problem as required by DDR Holdings; (2) provide any particular practical application as required by Bascom; or (3) entail an unconventional technological solution to a technological problem as required by Amdocs. Instead, Appellants' invention simply uses generic computer components to perform the abstract idea of "generating a training plan." In fact, the only "additional elements" recited in Appellants' claims merely implement the abstract idea on generic computing elements (i.e., processor, data storage). See Fig. 3; Spec. ,r,r 21, 27-28. However, the use of a generic computer device does not alone transform an otherwise abstract idea into patent-eligible subject matter. As our reviewing court has observed, "after Alice, there can remain no doubt: recitation of generic computer limitations does not make an otherwise ineligible claim patent- eligible." DDR Holdings, 773 F.3d at 1256 (citing Alice, 573 U.S. at 223). Moreover, Appellants have not shown any specific limitation in claims 1 and 12 beyond the judicial exception that is not "well-understood, routine, and conventional" in the field (see MPEP § 2106.05(d)). Because Appellants' claims 1 and 12 are directed to a patent-ineligible abstract concept and do not recite something "significantly more" under the second prong of the Alice analysis, we sustain the Examiner's rejection of claims 1, 3, 4, 6, 7, 11, 12, 14, 15, 17, 19, and 20 under 35 U.S.C. § 101. 16 Appeal 2017-011447 Application 13/436,230 CONCLUSION On the record before us, we conclude Appellants have not demonstrated the Examiner erred in rejecting claims 1, 3, 4, 6, 7, 11, 12, 14, 15, 17, 19, and 20 under 35 U.S.C. § 101. DECISION As such, we AFFIRM the Examiner's rejection of claims 1, 3, 4, 6, 7, 11, 12, 14, 15, 17, 19, and 20 under 35 U.S.C. § 101. 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 17 Copy with citationCopy as parenthetical citation