Prosecution Insights
Last updated: April 19, 2026
Application No. 13/569,343

Longevity Retirement Protection Fund System And Method

Final Rejection §101
Filed
Aug 08, 2012
Examiner
SHARVIN, DAVID P
Art Unit
3692
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Milliman Inc.
OA Round
10 (Final)
36%
Grant Probability
At Risk
11-12
OA Rounds
3y 12m
To Grant
61%
With Interview

Examiner Intelligence

Grants only 36% of cases
36%
Career Allow Rate
100 granted / 276 resolved
-15.8% vs TC avg
Strong +25% interview lift
Without
With
+24.9%
Interview Lift
resolved cases with interview
Typical timeline
3y 12m
Avg Prosecution
37 currently pending
Career history
313
Total Applications
across all art units

Statute-Specific Performance

§101
38.1%
-1.9% vs TC avg
§103
26.7%
-13.3% vs TC avg
§102
13.3%
-26.7% vs TC avg
§112
15.2%
-24.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 276 resolved cases

Office Action

§101
Notice of Pre-AIA or AIA Status The present application is being examined under the pre-AIA first to invent provisions. Examiner notes that the claims have been affirmed to be properly rejected under 35 USC 101 three separate times by the PTAB 8 August 2024, 14 April 2021, and 2 April 2018. The Applicant has not meaningfully addressed the PTAB decision or reasoning in the present arguments. Response to Arguments Applicant's arguments filed 30 June 2025 with respect to the 101 rejection have been fully considered but they are not persuasive. Applicant argues the claims recite significantly more than the abstract idea and the claims are integrated into a practical application. Specifically, the Applicant argues the amendment (outside information input module) with no specific reasoning as to how the claim limitation integrates the abstract idea into a practical application. Using a module to acquire information that is external to the system is merely using a computer to receive information, but in the current claims is an aspect of the abstract idea related to determining projected longevity even though the acquire information is never used in the current claims. Applicant argues that the rejection is not sufficient in showing the general purpose processors are generic computer components. The Board specifically addressed the processors and the arguments in the most recent decision dated 8/8/24 pages 11-12 as well as the Denial for a Rehearing dated 11/4/24 pages 5-7 and the Examiner repeats the Boards binding decision on this issue. The Applicant argues that the Examiner’s reference to previous PTAB decisions is not relevant to the current claims, but this is incorrect as the most recent decision involves all of the current amendments except for those dated 1/2/25 and 6/30/25 and the Applicant has repeatedly raised substantially similar arguments the PTAB did not find persuasive, including arguments with respect to non-amended claim limitations. 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 1-37 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. In the instant case, claim 1 is directed to a method of “calculating periodic payments to participants to automatically provide periodic payments for the duration of the participants lifetimes”. Claim 1 is directed to the abstract idea of “financial insurance and mitigating risk” which is grouped under “organizing human activity… fundamental economic practice (mitigating risk) and commercial or legal interactions (agreements in the form of contracts and legal obligations are similar to financial insurance)” in prong one of step 2A (See 2019 Revised Patent Subject Matter Eligibility Guidance). Claim 1 recites automatically calculating periodic financial payments to participants using an electronic longevity retirement protection system automatically provide periodic payments for the duration of the participants’ lifetimes through the steps of receiving a financial investment and associating it with an account, receiving an electronic funds transfer from each participant and associating such financial investment with an account, acquiring information related to the estimated longevity [of] the financial participant, determining a projected longevity, investing, calculate a risk assessment, automatically determine investment assets to buy and sell based on a participant’s risk tolerance level, calculate a risk assessment for the participants, calculating projected assets and payments, monitoring periodic redemption payments and actual cumulative assets, determining the difference between the periodic redemption payments and the projected periodic redemption payments, calculating the difference between actual and projected (subtraction), buy and sell the investment assets based on information, determining an expected redemption pattern for each participant by calculating an actuarial present value of the stream of expected redemptions based on the financial investment of each participant, expected longevity of the participant, an expected rate of return on the financial investment, and an estimated cost of operating a longevity retirement protection fund for the participant, automatically providing periodic redemption payments, ceasing to make periodic redemption payments upon death, and calculating a surplus. Accordingly, the claim recites an abstract idea (See 2019 Revised Patent Subject Matter Eligibility Guidance). This judicial exception is not integrated into a practical application because, when analyzed under prong two of step 2A (See 2019 Revised Patent Subject Matter Eligibility Guidance), the additional elements of the claim such as a projected longevity processor, an outside information input module, an investment management processor, a periodic redemption recalculation processor, a trading processor, a projected redemption calculation processor, a redemption payment processor and a database to perform the receiving, calculating, investing, determining, and adjusting represent the use of a computer as a tool to perform an abstract idea and/or does no more than generally link the abstract idea to a particular field of use (MPEP 2106.05(f)&(h)). Therefore, the additional elements do not integrate the abstract idea into a practical application as they do no more than represent a computer performing functions that correspond to (i.e. implement) the acts of financial insurance and mitigating risk. When analyzed under step 2B (See 2019 Revised Patent Subject Matter Eligibility Guidance), the claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception itself. The processors of the claims are considered to be generic because they are described at a high level of generality and a general-purpose processor is flexible and designed to be programmed to perform many functions. The specification at [0036]-[0038] describe the processors as being virtual processors of a main processor under the broadest reasonable interpretation of the claims. The database is described and functions as a database is intended to function, that is to say store and retrieve data from memory, see fig 2 and [0036]-[0038]. Although part of the abstract idea, performing repetitive calculations, receiving, processing, and storing data, electronic record keeping, and automating mental tasks are generic computer functions and much of the claims are generic computer functions being performed by generic computer components, further showing that merely using the computer to implement the abstract idea or “apply it” fails to meaningfully limit the abstract idea. Viewed as a whole, the combination of elements recited in the claims merely describe the concept of financial insurance and mitigating risk using computer technology (e.g. a processor). Therefore, the use of these additional elements does no more than employ a computer as a tool to automate and/or implement the abstract idea, which cannot provide significantly more than the abstract idea itself (MPEP 2106.05(I)(A)(f) & (h)). Dependent claims 2-19 and 23-37 do not remedy the deficiencies of the independent claims and are rejected accordingly. The dependent claims do not contain additional limitations that meaningfully limit the abstract idea of the claims because the limitations are generic computer functions (performing repetitive calculations, receiving, processing, and storing data, electronic recordkeeping, see MPEP 2106.05(d)) and extra solution activity, and further steps of the abstract idea of providing periodic payments by further refining the abstract idea with obtaining actuarially relevant medical information, which further refines the longevity calculation, something that is extremely widespread in the annuity and life insurance industry. In this case, all claims have been reviewed and are found to be substantially similar and linked to the same abstract idea (see Content Extraction and Transmission LLC v. Wells Fargo (Fed. Cir. 2014)). Claim Objections Claims 1 and 21 objected to because of the following informalities: the claims should read "related to the estimated longevity of the financial participant”. Appropriate correction is required. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Dellinger US 20110131149 Chen US 20030233301 Lyons US 20080281742 Lutnick US 20070226123 Anderson US 5,754,980. Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See 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. Any inquiry concerning this communication or earlier communications from the examiner should be directed to DAVID P SHARVIN whose telephone number is (571)272-9863. The examiner can normally be reached M-F 9 am - 5 pm EST. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Ryan Donlon can be reached at 571-270-3602. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /DAVID P SHARVIN/Primary Examiner, Art Unit 3692
Read full office action

Prosecution Timeline

Aug 08, 2012
Application Filed
Jun 16, 2014
Non-Final Rejection — §101
Sep 29, 2014
Applicant Interview
Sep 29, 2014
Applicant Interview (Telephonic)
Oct 20, 2014
Response Filed
Feb 09, 2015
Non-Final Rejection — §101
Jun 17, 2015
Notice of Allowance
Aug 17, 2015
Response after Non-Final Action
Aug 18, 2015
Response after Non-Final Action
Jan 27, 2016
Response after Non-Final Action
Apr 07, 2016
Response after Non-Final Action
Apr 11, 2016
Response after Non-Final Action
Apr 25, 2016
Response after Non-Final Action
Mar 29, 2018
Response after Non-Final Action
Jun 01, 2018
Request for Continued Examination
Jun 05, 2018
Response after Non-Final Action
Jun 25, 2018
Non-Final Rejection — §101
Oct 01, 2018
Response Filed
Jan 17, 2019
Final Rejection — §101
Apr 22, 2019
Request for Continued Examination
Apr 29, 2019
Response after Non-Final Action
Jun 04, 2019
Non-Final Rejection — §101
Sep 09, 2019
Response Filed
Dec 23, 2019
Final Rejection — §101
Mar 30, 2020
Notice of Allowance
May 28, 2020
Response after Non-Final Action
Jun 03, 2020
Response after Non-Final Action
Jul 29, 2020
Response after Non-Final Action
Sep 24, 2020
Response after Non-Final Action
Sep 24, 2020
Response after Non-Final Action
Sep 25, 2020
Response after Non-Final Action
Sep 25, 2020
Response after Non-Final Action
Apr 12, 2021
Response after Non-Final Action
Jun 11, 2021
Request for Continued Examination
Jun 16, 2021
Response after Non-Final Action
Jun 17, 2021
Non-Final Rejection — §101
Nov 16, 2021
Response Filed
Dec 07, 2021
Final Rejection — §101
May 04, 2022
Notice of Allowance
Sep 02, 2022
Response after Non-Final Action
Sep 15, 2022
Response after Non-Final Action
Jan 14, 2023
Response after Non-Final Action
Mar 22, 2023
Response after Non-Final Action
Mar 23, 2023
Response after Non-Final Action
Mar 24, 2023
Response after Non-Final Action
Mar 24, 2023
Response after Non-Final Action
Aug 06, 2024
Response after Non-Final Action
Oct 08, 2024
Response after Non-Final Action
Oct 31, 2024
Response after Non-Final Action
Jan 02, 2025
Request for Continued Examination
Jan 04, 2025
Response after Non-Final Action
Feb 27, 2025
Non-Final Rejection — §101
Jun 30, 2025
Response Filed
Jan 16, 2026
Final Rejection — §101 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

11-12
Expected OA Rounds
36%
Grant Probability
61%
With Interview (+24.9%)
3y 12m
Median Time to Grant
High
PTA Risk
Based on 276 resolved cases by this examiner. Grant probability derived from career allow rate.

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