James J. ZenniDownload PDFPatent Trials and Appeals BoardApr 8, 202014090650 - (D) (P.T.A.B. Apr. 8, 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. 14/090,650 11/26/2013 James J. Zenni JR. 10-1403-US-CON 9407 20306 7590 04/08/2020 MCDONNELL BOEHNEN HULBERT & BERGHOFF LLP 300 S. WACKER DRIVE 32ND FLOOR CHICAGO, IL 60606 EXAMINER SHARVIN, DAVID P ART UNIT PAPER NUMBER 3692 MAIL DATE DELIVERY MODE 04/08/2020 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 JAMES J. ZENNI JR. ____________ Appeal 2018-008305 Application 14/090,650 Technology Center 3600 ____________ Before ANTON W. FETTING, PHILIP J. HOFFMANN, and BRADLEY B. BAYAT, Administrative Patent Judges. FETTING, Administrative Patent Judge. DECISION ON APPEAL STATEMENT OF THE CASE1 James J. Zenni Jr. (Appellant2) seeks review under 35 U.S.C. § 134(a) of a final rejection of claims 1, 2, 6–10, 12–19, 23–27, and 29–34, the only 1 Our decision will make reference to the Appellant’s Appeal Brief (“Appeal Br.,” filed March 5, 2018) and Reply Brief (“Reply Br.,” filed August 22, 2018), and the Examiner’s Answer (“Ans.,” mailed June 22, 2018), and Final Action (“Final Act.,” mailed October 4, 2017). 2 We use the word “Appellant” to refer to “applicant” as defined in 37 C.F.R. § 1.42. Appellant identifies the real party in interest as ZAPP Systems, L.L.C. (Appeal Br. 1). Appeal 2018-008305 Application 14/090,650 2 claims pending in the application on appeal. We have jurisdiction over the appeal pursuant to 35 U.S.C. § 6(b). The Appellant invented a way of identification, sourcing, and acquisition of distressed debt. Specification para. 46. An understanding of the invention can be derived from a reading of exemplary claim 18, which is reproduced below (bracketed matter and some paragraphing added). 18. A method facilitating the identification, sourcing, and acquisition of distressed debt, the method carried out by a computing system comprising at least one user interface, at least one communication interface, at least one processor, and data storage having stored thereon instructions executable by the at least one processor for carrying out the method, the method comprising: [1] the computing system downloading loan-profile data records from at least one loan- profile data source in at least one first automated manner, wherein each received loan- profile data record is associated with an original loan from a respective original lender to a respective original borrower for a respective original loan amount, wherein said at least one first automated manner involves at least one of execution of at least one macro, execution of a least one script, or execution of at least one batch download, and wherein each downloaded loan-profile data record includes data that reflects one or more loan characteristics of the loan associated with that loan- profile data record; [2] the computing system processing each downloaded loan- profile data record in at least one second automated manner to Appeal 2018-008305 Application 14/090,650 3 extract one or more loan characteristics of the loan associated with that loan-profile data record, wherein processing each downloaded loan- profile data record in at least one second automated manner comprises processing by one or more optical-character- recognition (OCR) algorithms; [3] the computing system storing in at least one third automated manner at least a subset of the downloaded loan-profile data records in a manner that is organized at least according to at least one of the extracted loan characteristic included in the respective received loan-profile data records; [4] the computing system receiving special-purpose-vehicle- (SPV)-modeling data records from at least one SPV-modeling data source; [5] the computing system mining at least a subset of the received SPV-modeling data records to extract therefrom and store associations between respective original loans and respective downstream pieces of said respective original loans, wherein the stored associations include identifications of respective downstream lending institutions currently holding said respective downstream pieces of said respective original loans, wherein receiving SPV-modeling data records comprises repeatedly receiving updated data feeds and responsively updating at least one stored association of the stored associations; [6] the computing system presenting via the at least one user interface (i) access to the stored subset of downloaded loan-profile data records from the at least one loan-profile data source according to the manner in which the subset is stored and (ii) access to the stored associations extracted from the subset of the SPV-modeling data records, Appeal 2018-008305 Application 14/090,650 4 wherein said access to the downloaded loan-profile data records from the at least one loan-profile data source and said access to the stored associations extracted from the subset of the SPV- modeling data records are correlated with one another by at least one loan characteristic; and [7] the computing system providing via the at least one user interface a single display comprising respective points of access to respective cross-referenced displays of stored data, wherein the cross-referenced displays include displays that respectively pertain to target companies, target loans, target pieces of target loans, and a distressed-loan universe, wherein the display pertaining to the target companies comprises a list of target companies, wherein the display pertaining to the target loans comprises a plurality of target loans, wherein each target loan is associated with one of the target companies, wherein the display pertaining to the target pieces of target loans comprises data reflecting an extent to which target pieces of target loans associated with at least one target company have been identified, located, and acquired, and wherein the display pertaining to the distressed-loan universe comprises data organized on a macro-loan level and reflecting loans being evaluated as potentially distressed. Claims 1, 2, 6–10, 12–19, 23–27, and 29–34 stand rejected under 35 U.S.C. § 101 as directed to a judicial exception without significantly more. Appeal 2018-008305 Application 14/090,650 5 ISSUES The issues of eligible subject matter turn primarily on whether the claims recite more than abstract conceptual advice of results desired. ANALYSIS STEP 13 Claim 18, as a method claim, nominally recites one of the enumerated categories of eligible subject matter in 35 U.S.C. § 101. The issue before us is whether it is directed to a judicial exception without significantly more. STEP 2 The Supreme Court set forth a framework for distinguishing patents that claim laws of nature, natural phenomena, and abstract ideas from those that claim patent-eligible applications of those concepts. First, . . . determine whether the claims at issue are directed to one of those patent-ineligible concepts. If so, we then ask, “[w]hat else is there in the claims before us? To answer that question, . . . consider the elements of each claim both individually and “as an ordered combination” to determine whether the additional elements “transform the nature of the claim” into a patent- eligible application. [The Court] described step two of this analysis as a 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.” Alice Corp. v. CLS Bank Int’l, 573 U.S. 208, 217–18 (2014) (citations omitted). To perform this test, we must first determine what the claims are directed to. This begins by determining whether the claims recite one of the 3 For continuity of analysis, we adopt the steps nomenclature from 2019 Revised Patent Subject Matter Eligibility Guidance, 84 Fed. Reg. 50 (Jan. 7, 2019) (“Revised Guidance”). Appeal 2018-008305 Application 14/090,650 6 judicial exceptions (a law of nature, a natural phenomenon, or an abstract idea). Then, if the claims recite a judicial exception, determining whether the claims at issue are directed to the recited judicial exception, or whether the recited judicial exception is integrated into a practical application of that exception, i.e., that the claims “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 judicial exception.” Revised Guidance, 84 Fed. Reg. at 54. If the claims are directed to a judicial exception, then finally determining whether the claims provide an inventive concept because the additional elements recited in the claims provide significantly more than the recited judicial exception. STEP 2A Prong 1 At a high level, and for our preliminary analysis, we note that method claim 18 recites downloading data, extracting characteristics data after optical character recognition (OCR), storing data, receiving modelling data, mining to extract association data, presenting access to data, and providing a display of data. Downloading is receiving data. OCR and data extraction are rudimentary and conventional forms of data analysis. Mining to extract data is further rudimentary data analysis. Presenting access to data is data display and reception of access instructions. Thus, claim 18 recites receiving, analyzing, storing, and displaying data. None of the limitations recite technological implementation details for any of these steps, but instead recite only results desired by any and all possible means. From this we see that claim 18 does not recite the judicial exceptions of either natural phenomena or laws of nature. Appeal 2018-008305 Application 14/090,650 7 Under Supreme Court precedent, claims directed purely to an abstract idea are patent ineligible. As set forth in the Revised Guidance, which extracts and synthesizes key concepts identified by the courts, abstract ideas include (1) mathematical concepts,4 (2) certain methods of organizing human activity,5 and (3) mental processes.6 Among those certain methods of organizing human activity listed in the Revised Guidance are commercial or legal interactions. Like those concepts, claim 18 recites the concept of presenting commercial financial analysis. Specifically, claim 18 recites operations that would ordinarily take place in advising one to present a financial analysis from downloaded financial data subjected to analysis, modelling, and access. The advice to present a financial analysis from downloaded financial data subjected to analysis, modelling, and access involves displaying financial analysis of distressed commercial loans, which is an economic act, and acquiring loan data, which is an act ordinarily performed in the stream of commerce. For example, claim 18 recites “the display pertaining to the distressed-loan universe comprises data organized on a macro-loan level and reflecting loans being evaluated as potentially 4 See, e.g., Gottschalk v. Benson, 409 U.S. 63, 71–72 (1972); Bilski v. Kappos, 561 U.S. 593, 611 (2010); Mackay Radio & Telegraph Co. v. Radio Corp. of Am., 306 U.S. 86, 94 (1939); SAP America, Inc. v. InvestPic, LLC, 898 F.3d 1161, 1163 (Fed. Cir. 2018). 5 See, e.g., Bilski, 561 U.S. at 628; Alice, 573 U.S. at 219–20; Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709, 715 (Fed Cir. 2014); Smart Sys. Innovations, LLC v. Chicago Transit Auth., 873 F.3d 1364, 1383 (Fed. Cir. 2017); In re Marco Guldenaar Holding B.V., 911 F.3d 1157, 1160–61 (Fed. Cir. 2018). 6 See, e.g., Benson, 409 U.S. at 67; CyberSource Corp. v. Retail Decisions, Inc., 654 F.3d 1366, 1371–72 (Fed. Cir. 2011); Intellectual Ventures I LLC v. Symantec Corp., 838 F.3d 1307, 1318 (Fed. Cir. 2016). Appeal 2018-008305 Application 14/090,650 8 distressed,” which is an activity that would take place whenever one is performing commercial loan acquisition that might include distressed loans. Similarly, claim 18 recites “downloading loan-profile data records,” which is also characteristic of acquiring commercial debt. The Examiner determines the claims to be directed to facilitating the identification, sourcing, and acquisition of distressed debt. Final Act. 4. The preamble to claim 18 recites that it is a method facilitating the identification, sourcing, and acquisition of distressed debt. The steps in claim 18 result in displaying financial analysis from downloaded financial data subjected to analysis, modelling, and access absent any technological mechanism other than a conventional computer for doing so. As to the specific limitations, limitations 1 and 4 recite receiving data. Limitations 2, 3, and 5–7 recite generic and conventional analyzing, storing, and displaying of loan data, which advise one to apply generic functions to get to these results. The limitations thus recite advice for presenting a financial analysis from downloaded financial data subjected to analysis, modelling, and access. To advocate presenting a financial analysis from downloaded financial data subjected to analysis, modelling, and access is conceptual advice for results desired and not technological operations. The Specification at paragraph 46 describes the invention as relating to identification, sourcing, and acquisition of distressed debt. Thus, all this intrinsic evidence shows that claim 18 recites presenting commercial financial analysis. This is consistent with the Examiner’s determination. This in turn is an example of commercial or legal interactions as a certain method of organizing human activity because acquiring debt is a commercial interaction. The concept of presenting commercial financial Appeal 2018-008305 Application 14/090,650 9 analysis by presenting a financial analysis from downloaded financial data subjected to analysis, modelling, and access is one idea for analyzing such debt. The steps recited in claim 18 are part of how this might conceptually be premised. Our reviewing court has found claims to be directed to abstract ideas when they recited similar subject matter. Trading Techs. Int’l, Inc. v. IBG LLC, 921 F.3d 1378, 1384 (Fed. Cir. 2019) (display to help users process information more quickly); Affinity Labs of Texas, LLC v. Amazon.com Inc., 838 F.3d 1266, 1271 (2016) (customizing user interface and tailoring content). Alternately, this is an example of concepts performed in the human mind as mental processes because the steps of receiving, analyzing, storing, and displaying data mimic human thought processes of observation, evaluation, judgment, and opinion, perhaps with paper and pencil, where the data interpretation is perceptible only in the human mind. See In re TLI Commc’ns LLC Patent Litig., 823 F.3d 607, 611 (Fed. Cir. 2016); FairWarning IP, LLC v. Iatric Sys., Inc., 839 F.3d 1089, 1093–94 (Fed. Cir. 2016). Claim 18, unlike the claims found non-abstract in prior cases, uses generic computer technology to perform data reception, analysis, storage, and display and does not recite an improvement to a particular computer technology. See, e.g., McRO, Inc. v. Bandai Namco Games Am. Inc., 837 F.3d 1299, 1314 (Fed. Cir. 2016) (finding claims not abstract because they “focused on a specific asserted improvement in computer animation”). As such, claim 18 recites receiving, analyzing, storing, and displaying data, and not a technological implementation or application of that idea. Appeal 2018-008305 Application 14/090,650 10 From this we conclude that at least to this degree, claim 18 recites presenting commercial financial analysis by presenting a financial analysis from downloaded financial data subjected to analysis, modelling, and access, which is a commercial and legal interaction, one of certain methods of organizing human activity identified in the Revised Guidance, and, thus, an abstract idea. STEP 2A Prong 2 The next issue is whether claim 18 not only recites, but is more precisely directed to this concept itself or whether it is instead directed to some technological implementation or application of, or improvement to, this concept i.e. integrated into a practical application.7 At the same time, we tread carefully in construing this exclusionary principle lest it swallow all of patent law. At some level, “all inventions . . . embody, use, reflect, rest upon, or apply laws of nature, natural phenomena, or abstract ideas.” Thus, an invention is not rendered ineligible for patent simply because it involves an abstract concept. “[A]pplication[s]” of such concepts “ ‘to a new and useful end,’ ” we have said, remain eligible for patent protection. Accordingly, in applying the § 101 exception, we must distinguish between patents that claim the “ ‘buildin[g] block[s]’ ” of human ingenuity and those that integrate the building blocks into something more. Alice, 573 U.S. at 217 (alteration in original, citations omitted). Taking the claim elements separately, the operation performed by the computer at each step of the process is expressed purely in terms of results, devoid of implementation details. Steps 1 and 4 are pure data gathering 7 See, e.g., Alice, 573 U.S. at 223, discussing Diamond v. Diehr, 450 U.S. 175 (1981). Appeal 2018-008305 Application 14/090,650 11 steps. Limitations describing the nature of the data do not alter this. The limitation listing three download manners is no more than a recital of conventional coding styles, viz. coding textual commands as a macro, a script, and a batch command file. None of these styles would be considered technological implementations by those of ordinary skill, but instead conceptual ideas for how such commands might be packaged. Step 3 recites basic conventional data operations such as generating, updating, and storing data. Step 7 is insignificant post solution activity, such as storing, transmitting, or displaying the results. Steps 2, 5, and 6 recite generic computer processing expressed in terms of results desired by any and all possible means and so present no more than conceptual advice. The recitation of using OCR processing in step 2 is conventional data representation change. No technological implementation details for the OCR process are recited. All purported inventive aspects reside in how the data is interpreted and the results desired, and not in how the process physically enforces such a data interpretation or in how the processing technologically achieves those results. Viewed as a whole, Appellant’s claim 18 simply recites the concept of presenting commercial financial analysis by presenting a financial analysis from downloaded financial data subjected to analysis, modelling, and access as performed by a generic computer. This is no more than conceptual advice on the parameters for this concept and the generic computer processes necessary to process those parameters, and do not recite any particular implementation. Claim 18 does not, for example, purport to improve the functioning of the computer itself. Nor does it effect an improvement in any other Appeal 2018-008305 Application 14/090,650 12 technology or technical field. The 28 pages of Specification only spell out different generic equipment8 and parameters that might be applied using this concept and the particular steps such conventional processing would entail based on the concept of presenting commercial financial analysis by presenting a financial analysis from downloaded financial data subjected to analysis, modelling, and access under different scenarios. They do not describe any particular improvement in the manner a computer functions. Instead, claim 18 at issue amounts to nothing significantly more than an instruction to apply presenting commercial financial analysis by presenting a financial analysis from downloaded financial data subjected to analysis, modelling, and access using some unspecified, generic computer. Under our precedents, that is not enough to transform an abstract idea into a patent- eligible invention. See Alice, 573 U.S. at 225–26. None of the limitations reflect an improvement in the functioning of a computer, or an improvement to other technology or technical field, applies or uses a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition, implements a judicial exception with, or uses a judicial exception in conjunction with, a particular machine or manufacture that is integral to the claim, effects a transformation or reduction of a particular article to a different state or thing, or applies or uses 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. 8 The Specification describes a laptop computer, a desktop computer, a tablet device, a cell phone, a personal digital assistant. Spec. para. 92. Appeal 2018-008305 Application 14/090,650 13 We conclude that claim 18 is directed to achieving the result of presenting commercial financial analysis by advising one to present a financial analysis from downloaded financial data subjected to analysis, modelling, and access, as distinguished from a technological improvement for achieving or applying that result. This amounts to commercial or legal interactions, which fall within certain methods of organizing human activity that constitute abstract ideas. The claim does not integrate the judicial exception into a practical application. STEP 2B The next issue is whether claim 18 provides an inventive concept because the additional elements recited in the claim provide significantly more than the recited judicial exception. The introduction of a computer into the claims does not generally alter the analysis at Mayo step two. the mere recitation of a generic computer cannot transform a patent-ineligible abstract idea into a patent-eligible invention. Stating an abstract idea “while adding the words ‘apply it’” is not enough for patent eligibility. Nor is limiting the use of an abstract idea “‘to a particular technological environment.’” Stating an abstract idea while adding the words “apply it with a computer” simply combines those two steps, with the same deficient result. Thus, if a patent’s recitation of a computer amounts to a mere instruction to “implement[t]” an abstract idea “on . . . a computer,” that addition cannot impart patent eligibility. This conclusion accords with the pre-emption concern that undergirds our § 101 jurisprudence. Given the ubiquity of computers, wholly generic computer implementation is not generally the sort of “additional feature[e]” that provides any “practical assurance that the Appeal 2018-008305 Application 14/090,650 14 process is more than a drafting effort designed to monopolize the [abstract idea] itself.” Alice, 573 U.S. at 223–24 (alteration in original, citations omitted). “[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. We determine that they do not. Taking the claim elements separately, the function performed by the computer at each step of the process is purely conventional. Using a computer for receiving, analyzing, storing, and displaying data amounts to electronic data query and retrieval—one of the most basic functions of a computer. All of these computer functions are generic, routine, conventional computer activities that are performed only for their conventional uses. See Elec. Power Grp. v. Alstom S.A., 830 F.3d 1350, 1353 (Fed. Cir. 2016). Also see In re Katz Interactive Call Processing Patent Litig., 639 F.3d 1303, 1316 (Fed. Cir. 2011) (“Absent a possible narrower construction of the terms ‘processing,’ ‘receiving,’ and ‘storing,’ . . . those functions can be achieved by any general purpose computer without special programming”). None of these activities is used in some unconventional manner nor do any produce some unexpected result. Appellant does not contend they invented any of these activities. In short, each step does no more than require a generic computer to perform generic computer functions. As to the data operated upon, “even if a process of collecting and analyzing information is ‘limited to particular content’ or a particular ‘source,’ that limitation does not make the collection and analysis other than abstract.” SAP America, Inc. v. InvestPic LLC, 898 F.3d 1161, 1168 (Fed. Cir. 2018) (citation omitted). Considered as an ordered combination, the computer components of Appellant’s claim 18 add nothing that is not already present when the steps Appeal 2018-008305 Application 14/090,650 15 are considered separately. The sequence of data reception-analysis-storage- display is equally generic and conventional. See Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709, 715 (Fed. Cir. 2014) (sequence of receiving, selecting, offering for exchange, display, allowing access, and receiving payment recited an abstraction), Inventor Holdings, LLC v. Bed Bath & Beyond, Inc., 876 F.3d 1372, 1378 (Fed. Cir. 2017) (sequence of data retrieval, analysis, modification, generation, display, and transmission), Two-Way Media Ltd. v. Comcast Cable Communications, LLC, 874 F.3d 1329, 1339 (Fed. Cir. 2017) (sequence of processing, routing, controlling, and monitoring). The ordering of the steps is therefore ordinary and conventional. We conclude that claim 18 does not provide an inventive concept because the additional elements recited in the claim do not provide significantly more than the recited judicial exception. REMAINING CLAIMS Claim 18 is representative. The remaining method claims merely describe process parameters. We conclude that the method claims at issue are directed to a patent-ineligible concept itself, and not to the practical application of that concept. As to the structural claims, they are no different from the method claims in substance. The method claims recite the abstract idea implemented on a generic computer; the system claims recite a handful of generic computer components configured to implement the same idea. This Court has long “warn[ed] . . . against” interpreting § 101“in ways that make patent eligibility ‘depend simply on the draftsman’s art.’ Alice, 573 U.S. at 226 (alteration in original, citations omitted). As a corollary, the claims are not directed to any particular machine. Appeal 2018-008305 Application 14/090,650 16 LEGAL CONCLUSION From these determinations we further determine that the claims do not recite an improvement to the functioning of the computer itself or to any other technology or technical field, a particular machine, a particular transformation, or other meaningful limitations. From this we conclude the claims are directed to the judicial exception of the abstract idea of certain methods of organizing human activity as exemplified by the commercial and legal interaction of presenting commercial financial analysis by advising one to present a financial analysis from downloaded financial data subjected to analysis, modelling, and access, without significantly more. APPELLANT’S ARGUMENTS As to Appellant’s Appeal Brief arguments, we adopt the Examiner’s determinations and analysis from Final Action 4–6 and Answer 3–7 and reach similar legal conclusions. We now turn to the Reply Brief. We are not persuaded by Appellant’s argument that “the claimed invention is a patent-eligible improvement to a graphical user interface and therefore non-abstract under part one of Alice.” Reply Br. 4 (emphasis omitted). Appellant argues this on the basis that that the asserted claims are akin to the claims found patent-eligible in Core Wireless Licensing S.A.R.L. v. LG Electronics, Inc., 880 F.3d 1356 (Fed. Cir. 2018). Reply Br. 5. But the Court in Trading Techs. Int’l, Inc. v. IBG LLC addressed Appellant’s Core Wireless argument. Relying principally on Core Wireless, TT argues the claimed invention provides an improvement in the way a computer operates. We do not agree. The claims of the ’999 patent do not improve the functioning of the computer, make it operate more efficiently, or solve any technological problem. Instead, they Appeal 2018-008305 Application 14/090,650 17 recite a purportedly new arrangement of generic information that assists traders in processing information more quickly. Trading Techs. Int’l, Inc. v. IBG LLC, 921 F.3d at 1093 (citations omitted). The instant claims do not improve the functioning of the computer, make it operate more efficiently, or solve any technological problem. Instead, they recite a purportedly new arrangement of generic information that assists users in processing information more quickly. Appellant admits as much. “[T]he claimed invention improves a user’s identification of relevant information in a timely fashion.” Reply Br. 6. We are not persuaded by Appellant's argument that “the claimed invention is similar to that of Trading Techs. Int’l, Inc. v. CQG, Inc., No. 2016-1616 (Fed. Cir. Jan. 18, 2017) (non-precedential).” Reply Br. 7. Appellant cites to Trading Techs. Int’l, Inc. v. CQG, Inc., 875 Fed. Appx. 1001 (Fed. Cir. 2017). First, this case is non-precedential and two related precedential cases with user interfaces had the claims held ineligible. Trading Techs. Int’l, Inc. v. IBG LLC, 921 F.3d 1084 (Fed. Cir. 2019) and Trading Techs. Int’l, Inc. v. IBG LLC, 921 F.3d 1378 (Fed. Cir. 2019). Second, the claims do not recite and the Specification does not describe structure associated with the interface, only data content. In Trading Technologies, in response to a similar argument that the claims “provide a particular graphical user interface that improves usability, visualization, and efficiency,” the Court determined that “[t]he claims are focused on providing information to traders in a way that helps them process information more quickly, not on improving computers or technology. . . . The “tool for presentation” here is simply a generic computer.” Trading Techs., 921 F.3d at 1384–85 (citations omitted). Similarly here, the claims Appeal 2018-008305 Application 14/090,650 18 are not focused on an interface, but on providing information to users in a way that helps them process information more quickly, not on improving computers or technology and the tool for presentation is a generic computer. We are not persuaded that “Appellant’s claims are clearly distinguishable from those of Electric Power Group.” Reply Br. 8 (emphasis omitted). Appellant cites to Elec. Power Grp., 830 F.3d at 1353. As we determine supra under Step 2-Prong 1, claim 18 recites receiving, analyzing, storing, and displaying data. Appellant contends that “the claim recites how the outcome is achieved and is focused on a detailed and specific solution to an identified problem in the prior state of the art.” Reply Br. 9. But the claims are specific only in the sense they are specified using words. All steps are generic and conventional computer operations devoid of technological implementation details. We are not persuaded by Appellant’s argument that “the Examiner has improperly over-generalized the claims.” Reply Br. 10. A thorough analysis at both overall and specific levels is provided supra. We are not persuaded by Appellant’s argument that “the Examiner has failed to fully consider each dependent claim.” Reply Br. 11 (emphasis omitted). Appellant repeats the Examiner’s findings as to the dependent claims at page 12 of the Reply Brief. Thus, Appellant acknowledges that the Examiner stated that he considered all claims. A separate written analysis for each claim is not required under compact prosecution because issues may be summarized where appropriate. Appellant does not argue the differences in the dependent claims with any particularity. Appeal 2018-008305 Application 14/090,650 19 CONCLUSIONS OF LAW The rejection of claims 1, 2, 6–10, 12–19, 23–27, and 29–34 under 35 U.S.C. § 101 as directed to a judicial exception without significantly more is proper. CONCLUSION The rejection of claims 1, 2, 6–10, 12–19, 23–27, and 29–34 is affirmed. In summary: Claims Rejected 35 U.S.C. § Basis Affirmed Reversed 1, 2, 6–10, 12–19, 23–27, 29–34 101 Eligibility 1, 2, 6–10, 12–19, 23–27, 29–34 No time period for taking any subsequent action in connection with this appeal may be extended under 37 C.F.R. § 1.136(a). AFFIRMED Copy with citationCopy as parenthetical citation