DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application is being examined under the pre-AIA first to invent provisions.
Status of Claims
Claims 26-28, 30-32, 34-36, 39-50 and 76-77 are pending in the instant application per claim amendments and remarks filed on 04/16/2026. Claim 26 has only been amended. Claims 1-25, 29, 33, 37-38, 51-75 and 78 continue to be shown as cancelled.
This Office Action is a final rejection in response to the claim amendments and the remarks filed on 16 APRIL 2026 by Applicant, for its original application filed on 09/12/2008 that is titled: “Client Relationship Manager”.
Accordingly, amended Claims 26-28, 30-32, 34-36, 39-50 and 76-77 are now being rejected herein.
(NOTE: Latest ‘amendments to the claims’ filed by the Applicant in on 04/16/2026 are shown as bold and underlined additions, and all deletions may not be shown, or may not be underlined when stricken through. Underlined amendments to the claims that are shown below are from previously submitted claim amendments by the Applicant.)
Claim Rejections - 35 USC §101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 26-28, 30-32, 34-37, 39-50 and 76-77 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (abstract idea) without significantly more, wherein Claim 26 is the only independent system claim.
Exemplary Analysis.
Claim 26: Ineligible.
The claim recites a series of steps. The claim is directed to a system, which is a statutory category of invention (Step 1 -- YES).
The claim is analyzed to determine whether it is directed to a judicial exception. The claim recites the limitations for a client relationship management system (with a financial institution) that are directed to collecting information about a client and creating an automated client profile, complete a client profile that serves as a repository for reference, rating the client profile in terms of risk, compiling information to generate a validation summary and transmitting the information, setting and updating expectations regarding account usage, creating a client profile, validating the client profile, and reviewing the validating account. These limitations, as drafted, are processes/steps that, under its broadest reasonable interpretation, covers performance of the limitations in the mind or as a method of organizing human activity, but for the recitation of generic computer and generic computer components. That is, other than reciting “a client computer and a network data channel” using “a client information collection terminal, a validation terminal and a subsequent review terminal”; as well as “a validation summary generator, a client activity expectations generator having computer-executable instructions, and a client profile generator”, nothing in the claim precludes the limitations from practically being performed in the human mind or by organizing human activity. For example, but for the recitation of generic computer and generic computer components language, the claims of the instant application are directed to performance of certain transactions (account usage/ activity) and risk determination, which are directed to an abstract idea. Finally, the claim also updates the validation summary in one of the steps to include “client profile is updated and as the system prompts for missing until all necessary client information is collected”. These limitations are mental processes or organizing human activities of the group “Certain Methods of Organizing Human Activity” (Step 2A1 -- YES), which include fundamental economic principles or practices; commercial or legal interactions; and managing personal behavior or relationships or interactions between people.
Next, the claim is analyzed to determine if it is integrated into a practical application. The claims recite additional limitations of: using an operator screen, a client display screen, a GUI (graphical user interface), a client information collection terminal containing logic to only ask for information needed, a validation summary window (user interface) and a server to perform the steps, like dynamically updating features, which are mainly parts of a computer; and subsequent review terminal further comprising a subsequent review date setter configured to set the subsequent review date based on the updated risk determination. The processor (computer) in the steps is recited at a high level of generality, i.e., as a generic processor performing a generic computer function of processing data. And claim amendments added as: “wherein the information fields have a logic background to query for necessary subsequent client information based on previously collected client information” and “subsequent review terminal limitation” in Claim 26, are no more than an extra-solution activities. These generic processor and additional limitations are no more than mere instructions to apply the exception using generic computer and component/s. The computer, the interface and the terminal are tools used to perform the abstract idea. Accordingly, these additional limitations do not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Thus, the claim is directed to the abstract idea (Step 2A2 -- NO).
Next, the claim is analyzed to determine if there are additional claim limitations that individually, or as an ordered combination, to include the latest claim amendments, ensure that the claim amounts to significantly more than the abstract ideas (whether claims provide inventive concept). As discussed with respect to Step 2A2 above, the additional elements in the claims amount to no more than mere instructions to apply the exception using a generic computer and generic computer components. The same analysis applies here in Step 2B, i.e., mere instructions to apply an exception using a generic computer component cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. For the additional steps of using an operator screen, a client display screen and a server to perform the steps that were considered extra-solution activity in Step 2A, this has been re-evaluated in Step 2B and determined to be well-understood, routine, conventional activity in the field. The background does not provide any indication that the client relationship management system is anything other than a generic, off-the-shelf computer and component/s, and the Symantec, TLI, and OIP Techs. court decisions (MPEP 2106.05(d)(II)) indicate that mere collection or receipt of data over a network is a well‐understood, routine, and conventional function when it is claimed in a merely generic manner (as it is here). For these reasons, there is no inventive concept and the claim is not patent eligible. Accordingly, a conclusion that the aforementioned extra-solution elements are well-understood, routine and conventional activity is supported under Berkheimer options 2 and 3, respectively.
Viewing the limitations as an ordered combination does not add anything further than looking at the limitations individually. When viewed either individually, or as an ordered combination, to include the latest claim amendments like dynamically updating features, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea itself. Therefore, the claim does not amount to significantly more than the recited abstract idea (Step 2B -- NO), and the claim is not patent eligible.
The analysis above applies to all statutory categories of the invention including independent Claim 26. Furthermore, the dependent Claims 27-28, 30-32, 34-36, 39-50 and 76-77 do not resolve the issues raised in rejection of independent Claim 26, and these dependent claims further narrow independent Claim 26 with additional steps and limitations.
Therefore, the aforesaid Claims 26-28, 30-32, 34-37, 39-50 and 76-77 are rejected under 35 U.S.C. §101 as being directed to non- statutory subject matter.
Response to Arguments
Applicant's remarks (on pages 8-11) and claim amendments dated 16 APRIL 2026 with respect to the rejection of pending Claims 26-28, 30-32, 34-36, 39-50 and 76-77 have been carefully considered, but they are not persuasive. Thus, the rejection under 35 USC 101 is being maintained herein, as described above.
In response to Applicant’s arguments of 04/16/2026 that latest amendment of “rating the client profile in terms of risk,” added by the Applicant won’t overcome the 101 rejection. Because it is part of “certain methods of organizing human activity” under fundamental economic principles (to include hedging, mitigating risk, etc.); and that many aspects of “the client profile” were already rejected before under 35 USC 101 in the last Office Action. Further, the Applicant has argued by stating that “the processor and additional limitations are not generic” are not persuasive, and Examiner respectfully disagrees and notes that it doesn’t overcome the 101 rejection.
In further response to the Applicant’s 04/16/2026 argument – {“perform a validation based on dynamically updated client information as the dynamically updated client information is gathered and displayed in a user interface in each category of the client profile;”} and {“only ask for information needed and create an automated client profile based on the baseline of expected activity ”}, Examiner respectfully disagrees. Examiner notes that Applicant’s own Specification does not describe anything more than a general purpose computer with a display screen for “dynamically updating client profile” as described on its page 5 as ---
{“The subsequent review terminal of the client relationship management system can include a client profile updater configured to update the client profile with an updated risk determination, if there is a change in the client information, and a subsequent review date setter configured to set the subsequent review date based on the updated risk determination.”}
In further response to the Applicant’s 04/16/2026 argument – {“a client profile generator configured to create the client profile with a risk determination automatically generated for the client based on the dynamically updated client activity expectations generator;”} and {“as each of the categories of the client profile is updated and as the system prompts for missing information until all necessary client information is collected;”}, Examiner respectfully disagrees. Examiner notes that the Applicant’s own Specification does not describe anything special about “client profile generator 204” on pages 12-13 as ---
{“The client information collection terminal 200 includes the collection module 201, the validation summary generator 202, the client activity expectation generator 203, and the client profile generator 204. The collection module 201 collects the four stages of client information necessary to generate a client profile, as described in steps 101-104 above.
The validation summary generator 202 compiles, in real-time, the collected information and checks for any incomplete client information in each of the four sections of the client profile.”}
Lastly, dependent claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements are simply steps performed by a generic computer. The claim merely amounts to the application or instructions to apply the abstract idea on a processor, and is considered to amount to nothing more than requiring a generic processor to merely carry out the abstract idea itself.
For these reasons the rejection under 35 USC §101 directed to non-statutory subject matter set forth in this office action is maintained.
NOTE: Examiner notes that the previous Responses to Arguments from more than one previous Office Action/s are incorporated from the previous Office Actions by reference as recited in full here, but such previous Responses have not been retained herein for brevity.
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office Action. Accordingly, THIS ACTION IS MADE FINAL. See at least MPEP §706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
The prior art made of record and not relied upon, and listed in Form 892, that is considered pertinent to the Applicant's disclosure and review for not traversing already issued patents and/or claimed inventions by the claims of the current invention of the Applicant. Examiner notes that Form 892 contains more references than those cited in the rejection above under 35 USC 103, and that all the references cited on said Form 892 are relevant to this application and form a part of the body of prior art.
Any inquiry concerning this communication or earlier communications from the Examiner should be directed to SANJEEV MALHOTRA whose telephone number is (571) 272-7292. The Examiner can normally be reached during 8:30-17:00 hours, Monday-Friday on IFP Flexible schedule.
If attempts to reach the Examiner by telephone are unsuccessful, the examiner’s supervisor, Abhishek Vyas, can be reached on (571) 270-1836. The facsimile/fax phone number for the organization, where this application or proceeding is assigned, is (571) 273-8300.
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Electronic Communications
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/S.M./
Examiner, Art Unit 3691
sanjeev.malhotra@uspto.gov
/ABHISHEK VYAS/Supervisory Patent Examiner, Art Unit 3691
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