DETAILED CORRESPONDENCE
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.
Status of the Application
Applicant's submission filed on December 11, 2025 has been entered.
Information Disclosure Statement
The information disclosure statement (IDS) submitted on December 15, 2025 is in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner.
Response to Amendment
Claims 1 and 11 were amended. Claims 1 and 11 remain pending in the application and are provided to be examined upon their merits.
Claim Rejections - 35 USC § 112
The following is a quotation of the first paragraph of 35 U.S.C. 112(a):
(a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention.
The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112:
The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention.
Claims 1 and 11 are rejected under 35 U.S.C. 112(a) as failing to comply with the written description requirement. The claim(s) contain subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, at the time the application was filed, had possession of the claimed invention.
• Claim 1 recites the limitation "arrange, on the graphical user interface, a list of a plurality of template files arranged in order according to file size" in paragraph 4. The claim lacks written description support because there is no written description of this limitation in the disclosure. See MPEP 2163.03(I). In fact, there is no teaching of the following limitations anywhere in the disclosure: "arrange, on the graphical user interface, a list of a plurality of template files arranged in order according to file size".
• Claim 11 recites the limitation "arranging, on the graphical user interface, a list of a plurality of template files arranged in order according to file size" in paragraph 4. The claim lacks written description support because there is no written description of this limitation in the disclosure. See MPEP 2163.03(I). In fact, there is no teaching of the following limitations anywhere in the disclosure: "arranging, on the graphical user interface, a list of a plurality of template files arranged in order according to file size".
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 and 11 are rejected under 35 U.S.C. § 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
Claims 1 and 11 are directed to the abstract idea of: Claim 1 -: 1, for budgets and cash flow forecasting, to generate a unique company code for a company; generate a graphical user interface enabling a user to create a custom financial plan template associated with the unique company code; arrange, on the graphical user interface, a list of a plurality of template files arranged in order according to file size; upon the user selecting one of the template files arranged according to file size, generate, on the graphical user interface, a plurality of titles to be used in the budgets and cash flow forecasting; enabling, via first of the graphical user interface, the user to create the custom financial plan template with a plurality of combinations corresponding to a subset of the plurality of titles with a plurality of standard hours and save the plurality of combinations with a single confirmation input; enabling, via second of the graphical user interface, the user to apply the custom financial plan template to rates in a currency corresponding to the unique company code for the company to create one or more budgets for the company; after applying the custom financial plan template to create the one or more budgets for the company, perform periodic checks of a government authority to retrieve a current tax table and update tax expenditures based on the current tax table; generate a monthly cash flow prediction for the forthcoming fiscal year based on historical data and the retrieved current tax table for the company; transmit the cash flow prediction to an online secure website; store the cash flow prediction; receive from an entity at the online secure website, security information that enables access to the cash flow prediction, the security information including preprogrammed data authorizing only specific positions within a company access; prevent access to the cash flow prediction to positions other than the specific positions; receive, from the entity, a cost reduction suggestion that provides a cost savings; the monthly cash flow prediction based on the cost reduction suggestion; the monthly cash flow prediction when an employee leaves or joins the company; transmit the recalculated cash flow prediction to key personnel; compare departments actual cash flow to the recalculated cash flow prediction; determine whether each department of the departments adhered to the recalculated cash flow prediction; allocate and share a portion of the cost savings as payment to a head of the department in the form of a dividend, distribution or year end bonus upon determining the department adhered to the recalculated cash flow prediction; compare the actual cash flow to a predetermined value from the one or more budgets created from the custom financial plan template; transmit an alert to the key personnel upon determining that the actual cash flow is less than the predetermined value in the one or more budgets created from the custom financial plan template; identify a set of related interest rate information for responding to the actual cash flow; transmit a payment offer to a client upon determining that the actual cash flow is less than the predetermined value in the one or more budgets created from the custom financial plan template; and implement optimal funding for a predetermined amount of time responsive to the alert being transmitted. (mathematical calculations. fundamental economic principles or practices, commercial or legal interactions, managing personal behavior or relationships or interactions between people, concepts performed in the human mind, (including an observation, evaluation, judgment, opinion). ) Claim 11 -: 11, a method for creating budgets and cash flow forecasts, the method comprising: generating a unique company code for a company; generating a graphical user interface enabling a user to create a custom financial plan template associated with the unique company code; arranging, on the graphical user interface, a list of a plurality of template files arranged in order according to file size; upon the user selecting one of the template files arranged according to file size, generating, on the graphical user interface, a plurality of titles to be used in the budgets and cash flow forecasting; enabling, via first of... enabling, via second... [id. at 1], after applying the custom financial plan template to create the one or more budgets for the company presenting, via the graphical user interface generated a display for at least one prior fiscal year all income categories and all expense categories; receiving, information of the monthly financial distribution for the at least one prior fiscal year: performing periodic checks of a government authority to retrieve a current tax table and updating tax expenditures based on the current tax table; generating, a monthly cash flow prediction for the forthcoming fiscal year based on historical data and the retrieved current tax table for the company; transmitting, the cash flow prediction to an online secure website; storing the cash flow prediction; receiving from an entity at the online secure website, security information that enables access to the cash flow prediction, the security information including preprogrammed data authorizing only specific positions within a company access; preventing access to the cash flow prediction to positions other than the specific positions; receiving, by from the entity, a cost reduction suggestion that provides a cost savings; the monthly cash flow... the monthly cash flow... [id. at 1], transmitting the cash recalculated flow prediction to key personnel; identifying a set of related interest rate information for responding to the actual cash flow; comparing departments actual cash flow to the recalculated cash flow prediction; determining whether each department of the departments adhered to the recalculated cash flow prediction; allocating and sharing a portion of the cost savings as payment to a head of the department in the form of a dividend, distribution or year end bonus upon determining the department adhered to the recalculated cash flow prediction; comparing the actual cash flow to a predetermined value from the one or more budgets created from the custom financial plan template; transmitting an alert to the key personnel upon determining that the actual cash flow is less than the predetermined value in the one or more budgets created from the custom financial plan template; transmitting a payment offer to a client upon determining that the actual cash flow is less than the predetermined value in the one or more budgets created from the custom financial plan template; and implementing optimal funding for a predetermined amount of time responsive to the alert being transmitted. (mathematical calculations. fundamental economic principles or practices, commercial or legal interactions, managing personal behavior or relationships or interactions between people, concepts performed in the human mind, (including an observation, evaluation, judgment, opinion). ) . The identified limitation(s) falls within the subject matter groupings of abstract ideas enumerated in Section I of the 2019 Revised Patent Subject Matter Eligibility Guidance: a) Mathematical concepts – mathematical calculations. b) Certain methods of organizing human activity – fundamental economic principles or practices, commercial or legal interactions, managing personal behavior or relationships or interactions between people, c) Mental processes – concepts performed in the human mind, (including an observation, evaluation, judgment, opinion).
These limitation excerpts, under their broadest reasonable interpretation, fall within the grouping(s) of abstract ideas of: Certain methods of organizing human activity – since: improved system and method for budgeting and cash flow forecasting as recited in the claim limitations, under their broadest reasonable interpretation, covers performance of the limitation(s) as 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). Mental processes – since: the above-underlined as recited in the claim limitations, under their broadest reasonable interpretation, covers performance of the limitation(s) as concepts performed in the human mind, (including an observation, evaluation, judgment, opinion). Mathematical concepts – since: the above-underlined as recited in the claim limitations, under their broadest reasonable interpretation, covers performance of the limitation(s) as mathematical calculations. Therefore, the limitations fall within the above-identified grouping(s) of abstract ideas.
While independent claims 1 and 11 do not explicitly recite verbatim this identified abstract idea, the concept of this identified abstract idea is described by the steps of independent claim 1 and is described by the steps of independent claim 11.
Claim 1: Particularly regarding the analysis under Step 2A of the Office's § 101 Subject Matter Eligibility Test for Products and Processes, independent claim 1 further to the abstract idea includes additional elements of "a system", "the system", "a CPU", "data storage", "screen", "automatically", "electronically", "network", "across a global platform", "access to the online secure website", and "recalculate". However, independent claim 1 does not include additional elements that are sufficient to integrate the exception into a practical application because "a system", "the system", "a CPU", "data storage", "screen", "automatically", "electronically", "network", "across a global platform", "access to the online secure website", and "recalculate" of independent claim 1 recite generic computer and/or field of use components pertaining to the particular technological environment that are recited a high-level of generality that perform functions ("a system for budgets and … data storage configured to", "generate a unique company code for a company", "generate a graphical user interface … the unique company code", "arrange, on the graphical user … according to file size", "upon the user selecting one … and cash flow forecasting", "enabling, via a first screen … a single confirmation input", "enabling, via a second screen … budgets for the company", "after applying the custom financial … budgets for the company", "automatically perform periodic checks of … the current tax table", "generate a monthly cash flow … table for the company", "transmit the cash flow prediction … an online secure website", "store the cash flow prediction in the data storage", "receive electronically, from an entity … the online secure website", "prevent access to the cash … than the specific positions", "receive, from the entity, a … provides a cost savings", "recalculate the monthly cash flow … the cost reduction suggestion", "recalculate the monthly cash flow … or joins the company", "automatically transmit the recalculated cash … personnel over the network", "compare departments actual cash flow … recalculated cash flow prediction", "determine whether each department of … recalculated cash flow prediction", "allocate and share a portion … recalculated cash flow prediction", "compare the actual cash flow … custom financial plan template", "automatically transmit an alert to … custom financial plan template", "automatically identify a set of … the actual cash flow", "transmit a payment offer to … financial plan template; and" and "implement optimal funding for a … alert being automatically transmitted") that merely perform, conduct, carry out, implement, and/or narrow the abstract idea itself (e.g. all or portion(s) of the noted recited steps) and/or that recite generic computer and/or field of use functions that are recited at a high-level of generality that include only steps narrowing the abstract idea [Step 2A Prong I] (e.g. all or portion(s) of the noted recited steps) and/or because the additional method steps comprise or include: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, [Step 2A Prong II] 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(f) (all or portions of the noted step(s)), and adding insignificant extra-solution activity to the judicial exception -- see MPEP 2106.05(g) (all or portions of the "enabling, via a first screen … a single confirmation input", "enabling, via a second screen … budgets for the company", "automatically perform periodic checks of … the current tax table", "store the cash flow prediction in the data storage", "receive electronically, from an entity … the online secure website", "prevent access to the cash … than the specific positions", "recalculate the monthly cash flow … the cost reduction suggestion", "recalculate the monthly cash flow … or joins the company", "automatically transmit the recalculated cash … personnel over the network", "automatically transmit an alert to … custom financial plan template" step(s)), and generally linking the use of the judicial exception to a particular technological environment or field of use -- see MPEP 2106.05(h) (all or portions of the "a system for budgets and … data storage configured to", "generate a graphical user interface … the unique company code", "arrange, on the graphical user … according to file size", "upon the user selecting one … and cash flow forecasting", "enabling, via a first screen … a single confirmation input", "enabling, via a second screen … budgets for the company", "automatically perform periodic checks of … the current tax table", "transmit the cash flow prediction … an online secure website", "store the cash flow prediction in the data storage", "receive electronically, from an entity … the online secure website", "prevent access to the cash … than the specific positions", "recalculate the monthly cash flow … the cost reduction suggestion", "recalculate the monthly cash flow … or joins the company", "automatically transmit the recalculated cash … personnel over the network", "automatically transmit an alert to … custom financial plan template", "automatically identify a set of … the actual cash flow", "implement optimal funding for a … alert being automatically transmitted" step(s)). Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the additional elements do not amount to more than a recitation of the words "apply it" (or an equivalent) or are not more than mere instructions to implement an abstract idea or other exception on a computer, and the additional elements do not add more than insignificant extra-solution activity to the judicial exception, and the additional elements do not amount to more than generally linking the use of a judicial exception to a particular technological environment or field of use. Furthermore, the additional method steps comprise or include: reciting additional elements in implementing the abstract idea that do not constitute significantly more than the abstract idea because they comprise or include well-understood, routine, and conventional activities previously known to the industry (e.g. all or portion(s) of the "enabling, via a first screen … a single confirmation input", "enabling, via a second screen … budgets for the company", "automatically perform periodic checks of … the current tax table", "store the cash flow prediction in the data storage", "receive electronically, from an entity … the online secure website", "prevent access to the cash … than the specific positions", "recalculate the monthly cash flow … the cost reduction suggestion", "recalculate the monthly cash flow … or joins the company", "automatically transmit the recalculated cash … personnel over the network", "automatically transmit an alert to … custom financial plan template", (insignificant extra-solution activity) steps), see Alice Corp., 134 S. Ct. at 2360, and/or that are otherwise not significant toward constituting any inventive concept beyond the abstract idea. (E.g. The above-italicized grounds of rejection apply at least to all or portion(s) of the noted recited steps.) For example regarding well-understood, routine, and conventional activities, the cited rationale have recognized the following computer function as well-understood, routine, and conventional functions when it is claimed or as insignificant extra-solution activity: receiving or transmitting data over a network, e.g., using the Internet to gather data, Intellectual Ventures I v. Symantec Corp., 838 F.3d at 1321, 120 USPQ2d at 1362 (2016) (utilizing an intermediary computer to forward information); TLI Communications LLC v. AV Auto. LLC, 823 F.3d 607, 610, 118 USPQ2d 1744, 1745 (Fed. Cir. 2016) (using a telephone for image transmission); OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1093 (Fed. Cir. 2015) (sending messages over a network); buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014) (computer receives and sends information over a network), performing repetitive calculations, Parker v. Flook, 437 U.S. at 594, 198 USPQ2d at 199 (1978) (recomputing or readjusting alarm limit values); Bancorp Services v. Sun Life, 687 F.3d 1266, 1278, 103 USPQ2d 1425, 1433 (Fed. Cir. 2012) ("The computer required by some of Bancorp's claims is employed only for its most basic function, the performance of repetitive calculations, and as such does not impose meaningful limits on the scope of those claims."), electronic recordkeeping, Alice Corp. Pty. Ltd. v. CLS Bank Int'l, 134 S. Ct. at 2359, 110 USPQ2d at 1984 (2014) (creating and maintaining "shadow accounts"); Ultramercial, Inc. v. Hulu, LLC, 772 F.3d at 716, 112 USPQ2d at 1755 (Fed. Cir. 2014) (updating an activity log), storing and retrieving information in memory, Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015); OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d at 1363, 115 USPQ2d at 1092-93 (Fed. Cir. 2015), and a web browser's back and forward button functionality, Internet Patent Corp. v. Active Network, Inc., 790 F.3d 1343, 1348, 115 USPQ2d 1414, 1418 (Fed. Cir. 2015); and the cited rationale have found the following type of activity to be well-understood, routine, and conventional activity when it is claimed or as insignificant extra-solution activity: recording a customer's order, Apple, Inc. v. Ameranth, Inc., 842 F.3d 1229, 1244, 120 USPQ2d 1844, 1856 (Fed. Cir. 2016), restricting public access to media by requiring a consumer to view an advertisement, Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709, 716-17, 112 USPQ2d 1750, 1755-56 (Fed. Cir. 2014), presenting offers and gathering statistics, OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d at 1362-63, 115 USPQ2d at 1092-93 (Fed. Cir. 2015), determining an estimated outcome and setting a price, OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d at 1362-63, 115 USPQ2d at 1092-93 (Fed. Cir. 2015), and arranging a hierarchy of groups, sorting information, eliminating less restrictive pricing information and determining the price, Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1331, 115 USPQ2d 1681, 1699 (Fed. Cir. 2015). None of the additional elements taken individually or when taken as an ordered combination amount to significantly more than the abstract idea. Accordingly, independent claim 1 is ineligible.
Claim 11: Particularly regarding the analysis under Step 2A of the Office's § 101 Subject Matter Eligibility Test for Products and Processes, independent claim 11 further to the abstract idea includes additional elements of "screen", "the system", "automatically", "data storage", "electronically", "network", "across a global platform", "access to the online secure website", and "recalculating". However, independent claim 11 does not include additional elements that are sufficient to integrate the exception into a practical application because "screen", "the system", "automatically", "data storage", "electronically", "network", "across a global platform", "access to the online secure website", and "recalculating" of independent claim 11 recite generic computer and/or field of use components pertaining to the particular technological environment that are recited a high-level of generality that perform functions ("a method for creating budgets … forecasts, the method comprising", "generating a unique company code for a company", "generating a graphical user interface … the unique company code", "arranging, on the graphical user … according to file size", "upon the user selecting one … and cash flow forecasting", "enabling, via a first screen … a single confirmation input", "enabling, via a second screen … budgets for the company", "after applying the custom financial … budgets for the company", "presenting, via the graphical user … and all expense categories", "receiving, by the system, information … one prior fiscal year", "automatically performing periodic checks of … the current tax table", "generating, by the system, a … table for the company", "transmitting, by the system, the … an online secure website", "storing the cash flow prediction in a data storage", "receiving electronically, from an entity … the online secure website", "preventing access to the cash … than the specific positions", "receiving, by the system from … provides a cost savings", "recalculating, by the system, the … the cost reduction suggestion", "recalculating the monthly cash flow … or joins the company", "automatically transmitting the cash recalculated … personnel over the network", "automatically identifying a set of … the actual cash flow", "comparing departments actual cash flow … recalculated cash flow prediction", "determining whether each department of … recalculated cash flow prediction", "allocating and sharing a portion … recalculated cash flow prediction", "comparing the actual cash flow … custom financial plan template", "automatically transmitting an alert to … custom financial plan template", "transmitting a payment offer to … financial plan template; and" and "implementing optimal funding for a … alert being automatically transmitted") that merely perform, conduct, carry out, implement, and/or narrow the abstract idea itself (e.g. all or portion(s) of the noted recited steps) and/or that recite generic computer and/or field of use functions that are recited at a high-level of generality that include only steps narrowing the abstract idea [Step 2A Prong I] (e.g. all or portion(s) of the noted recited steps) and/or because the additional method steps comprise or include: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, [Step 2A Prong II] 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(f) (all or portions of the noted step(s)), and adding insignificant extra-solution activity to the judicial exception -- see MPEP 2106.05(g) (all or portions of the "enabling, via a first screen … a single confirmation input", "enabling, via a second screen … budgets for the company", "presenting, via the graphical user … and all expense categories", "automatically performing periodic checks of … the current tax table", "storing the cash flow prediction in a data storage", "receiving electronically, from an entity … the online secure website", "preventing access to the cash … than the specific positions", "recalculating, by the system, the … the cost reduction suggestion", "recalculating the monthly cash flow … or joins the company", "automatically transmitting the cash recalculated … personnel over the network", "automatically transmitting an alert to … custom financial plan template" step(s)), and generally linking the use of the judicial exception to a particular technological environment or field of use -- see MPEP 2106.05(h) (all or portions of the "a method for creating budgets … forecasts, the method comprising", "generating a graphical user interface … the unique company code", "arranging, on the graphical user … according to file size", "upon the user selecting one … and cash flow forecasting", "enabling, via a first screen … a single confirmation input", "enabling, via a second screen … budgets for the company", "presenting, via the graphical user … and all expense categories", "automatically performing periodic checks of … the current tax table", "transmitting, by the system, the … an online secure website", "storing the cash flow prediction in a data storage", "receiving electronically, from an entity … the online secure website", "preventing access to the cash … than the specific positions", "recalculating, by the system, the … the cost reduction suggestion", "recalculating the monthly cash flow … or joins the company", "automatically transmitting the cash recalculated … personnel over the network", "automatically identifying a set of … the actual cash flow", "automatically transmitting an alert to … custom financial plan template", "implementing optimal funding for a … alert being automatically transmitted" step(s)). Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claim 1 also applies hereto. Furthermore, the additional method steps comprise or include: reciting additional elements in implementing the abstract idea that do not constitute significantly more than the abstract idea because they comprise or include well-understood, routine, and conventional activities previously known to the industry (e.g. all or portion(s) of the "enabling, via a first screen … a single confirmation input", "enabling, via a second screen … budgets for the company", "presenting, via the graphical user … and all expense categories", "automatically performing periodic checks of … the current tax table", "storing the cash flow prediction in a data storage", "receiving electronically, from an entity … the online secure website", "preventing access to the cash … than the specific positions", "recalculating, by the system, the … the cost reduction suggestion", "recalculating the monthly cash flow … or joins the company", "automatically transmitting the cash recalculated … personnel over the network", "automatically transmitting an alert to … custom financial plan template", (insignificant extra-solution activity) steps), see Alice Corp., 134 S. Ct. at 2360, and/or that are otherwise not significant toward constituting any inventive concept beyond the abstract idea. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited steps.) See discussion above regarding Claim 1 for pertinent previously cited rationale finding well-understood, routine, and conventional activities. None of the additional elements taken individually or when taken as an ordered combination amount to significantly more than the abstract idea. Accordingly, independent claim 11 is ineligible.
Independent Claims: Nothing in independent claims 1 and 11 improves another technology or technical field, improves the functioning of any claimed computer device itself, applies the abstract idea with any particular machine, solves any computer problem with a computer solution, or includes any element that may otherwise be considered to amount to significantly more than the abstract idea.
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§101 Subject Matter Eligibility Test for Products and Processes
Response to Arguments
Regarding indefiniteness and/or lack of written description rejections under 35 U.S.C. § 112, the Applicant's arguments submitted December 11, 2025 (hereinafter "REMARKS") in response to the Official Correspondence mailed August 14, 2025 (hereinafter "Final Correspondence") have been fully considered but are not persuasive. Further to the August 14, 2025 Final Correspondence, the reiterated grounds of rejection are fully set forth above under the 35 U.S.C. § 112 heading as applied to the herein examined current claims.
• Specifically, the Applicant argued:
"[] Applicant has identified support for and further amended independent claims 1 and 11. []
'Applicant respectfully submits that Figures 2 and 10 of the Specification show that the template files are arranged according to file size, regardless of the dates shown (e.g. "LOCAL OFFICE CONSOLIDATED REPORTS.xlsm" in Figures 2 and 10 is listed above another entry using the file size). (See Applicant's previous explanation and use of Figures 2 and 10 to arrange the templates according to file size.) Applicant's Figures 2 and 10 are reproduced below to show such support.
"[] Template files arranged according to file size
"[] Applicant's Figures 2 and 10
"Applicant accordingly respectfully submits that claims 1 and 11 are supported by the specification. "
(REMARKS, pp. 6-7).
However, the above-quoted arguments submitted December 11, 2025 at REMARKS pp. 6-7 regarding rejections under 35 U.S.C. § 112 have been fully considered, but are not persuasive. An objective standard for determining compliance with the written description requirement is, "does the description clearly allow persons of ordinary skill in the art to recognize that he or she invented what is claimed." In re Gosteli, 872 F.2d 1008, 1012, 10 USPQ2d 1614, 1618 (Fed. Cir. 1989). Under Vas-Cath, Inc. v. Mahurkar, 935 F.2d 1555, 1563-64, 19 USPQ2d 1111, 1117 (Fed. Cir. 1991), to satisfy the written description requirement, an applicant must convey with reasonable clarity to those skilled in the art that, as of the filing date sought, he or she was in possession of the invention, and that the invention, in that context, is whatever is now claimed. The test for sufficiency of support in a parent application is whether the disclosure of the application relied upon "reasonably conveys to the artisan that the inventor had possession at that time of the later claimed subject matter." Ralston Purina Co. v. Far-Mar-Co., Inc., 772 F.2d 1570, 1575, 227 USPQ 177, 179 (Fed. Cir. 1985) (quoting In re Kaslow, 707 F.2d 1366, 1375, 217 USPQ 1089, 1096 (Fed. Cir. 1983)). The introduction of claim changes which involve narrowing the claims by introducing elements or limitations which are not supported by the as-filed disclosure is a violation of the written description requirement of 35 U.S.C. 112(a) or pre-AIA 35 U.S.C. 112, first paragraph. See, e.g., Fujikawa v. Wattanasin, 93 F.3d 1559, 1571, 39 USPQ2d 1895, 1905 (Fed. Cir. 1996) (a "laundry list" disclosure of every possible moiety does not constitute a written description of every species in a genus because it would not "reasonably lead" those skilled in the art to any particular species); In re Ruschig, 379 F.2d 990, 995, 154 USPQ 118, 123 (CCPA 1967) ("If n-propylamine had been used in making the compound instead of n-butylamine, the compound of claim 13 would have resulted. Appellants submit to us, as they did to the board, an imaginary specific example patterned on specific example 6 by which the above butyl compound is made so that we can see what a simple change would have resulted in a specific supporting disclosure being present in the present specification. The trouble is that there is no such disclosure, easy though it is to imagine it.") (emphasis in original); Rozbicki v. Chiang, 590 Fed.App'x 990, 996 (Fed. Cir. 2014) (non-precedential) (The court found that patentee, "while attempting to obtain the broadest claim language possible during prosecution, cannot now improperly narrow its language by importing limitations not supported by the claim language or written description."). In Ex parte Ohshiro, 14 USPQ2d 1750 (Bd. Pat. App. & Inter. 1989), the Board affirmed the rejection under 35 U.S.C. 112, first paragraph, of claims to an internal combustion engine which recited "at least one of said piston and said cylinder (head) having a recessed channel." The Board held that the application which disclosed a cylinder head with a recessed channel and a piston without a recessed channel did not specifically disclose the "species" of a channeled piston. See also Purdue Pharma L.P. v. Faulding Inc., 230 F.3d 1320, 1328, 56 USPQ2d 1481, 1487 (Fed. Cir. 2000) ("[T]he specification does not clearly disclose to the skilled artisan that the inventors... considered the... ratio to be part of their invention.... There is therefore no force to Purdue's argument that the written description requirement was satisfied because the disclosure revealed a broad invention from which the [later-filed] claims carved out a patentable portion"). Pertaining to Figs. 2 and 10 in the "Detailed Description of the Drawings" of the Substitute Specification Without Markings filed 1/11/2016: the Specification [as amended] recites 'Figure 2 illustrates the System and Method for Budgeting and Cash Flow Forecasting template having the header: "Client Matter_Budget 21, and enterprise performance management (EPM) tab 22, which the user clicks on next, open file icon 23, which brings up Open pop up Box 24, name list 25 and the individual file "Local Office Standard Hrs. Rates Workings Days" 26, which is an Excel spreadsheet file format .xls.' Substitute Specification, p. 37 ; and 'Figure 10 illustrates the system and method for budgeting and cash flow forecasting 10 template showing the header "Core Model BM PLANSHELL model Local Office Budget" 60, the Server Folder 61, the directory tree 62 showing "Company", where the "Local Office Consolidated Master Input.xlm" template 66 is located, and the company icon.' Substitute Specification, p. 38 . The "Size" column shown in both Figs. 2 and 10 is not referred to either by description(s) or with reference numeral(s), and neither to "arrange" nor "arranging" the lists according to any specific criteria is disclosed . The Office also notes that the five (5) files illustrated in each of the "name list 25" shown in Fig. 2 and contents of the "Server Folder 61" shown in Fig. 10 of the Drawings filed June 30, 2015 further each appear to be sorted alphanumerically by file name [although there is no written description of any such "arranging" or to "arrange" either by file name (as noted by the Office) or by file size (as now claimed without support by the Applicant)]. The Office refers the Applicant to see the current rejection based upon the currently pending claims under the 35 U.S.C. § 112 heading above.
Regarding eligibility rejections under 35 U.S.C. § 101, the Applicant's arguments submitted December 11, 2025 (hereinafter "REMARKS") in response to the Official Correspondence mailed August 14, 2025 (hereinafter "Final Correspondence") have been fully considered but are not persuasive. Further to the August 14, 2025 Final Correspondence, the reiterated grounds of rejection are fully set forth above under the 35 U.S.C. § 101 heading as applied to the herein examined current claims.
• Specifically, the Applicant argued:
"[] Applicant has further amended independent claims 1 and 11 to place claims 1 and 11 closer in line with the USPTO's patent eligibility examples. (See USPTO Subject Matter Eligibility Examples: Abstract Ideas, January 7, 2019.) [I]ndependent claim 1 recites []:
"[amended claim language].
"Applicant respectfully submits that amended claims 1 and 11 are patent eligible for similar reasons as claim 1 of Example 42 of the USPTO's patent eligibility examples. In Example 42 of the USPTO's patent eligibility examples, the USPTO determined claim 1 to be patent eligible as including a judicial exception integrated into a practical application. The USPTO considered the claim as a whole integrated the mental process into a practical manner [].
"[] Applicant's claims 1 and 11 include the step of automatically identifying a set of related interest rate information for responding to the actual cash flow as well as arranging a list of a plurality of template files on the graphical user interface in an order according to file size. See Specification p. 42, 11.15-19. Allowed remote users can access through the system a list of template files and the related interest rate sets - all shared information that is available in real time in a standardized format.
"To the extent that the determination of the file size and interest rate calculations could be performed in the human mind under the broadest reasonable interpretation, Applicant respectfully submits that this step is integrated into a practical application under step 2B. [T]he system includes the graphical user interface automatically arranging the template files based on file size, and the system includes identifying sets of related interest rate information.
"As with Example 42 in the USPTO patent eligibility guidelines, Applicant respectfully submits that claims 1 and 11 are [] integrated into a practical application due to the specific way that the template files are displayed based on file size and due to the identification of the interest rate calculations, which results in an improved user interface for a system for budgets and cash flow forecasting.
"[] Applicant respectfully asserts that claims 1 and 11 are now in condition for allowance. []"
(REMARKS [as abridged], pp. 7-10).
Respectively nonetheless, the above-quoted arguments submitted December 11, 2025 at REMARKS pp. 7-10 regarding rejections under 35 U.S.C. § 101 have been fully considered, but are not persuasive. Considerably, the Office respectfully disagrees with the Applicant's above-quoted factual allegations and legal conclusion. Regarding the Applicant's reference(s) to one or more Subject Matter Eligibility Examples: Abstract Ideas, the Office notes that the examples are presented as hypothetical and only intended to be interpreted based on the fact patterns set forth therein as other fact patterns may have different eligibility outcomes.
In response to Applicant's argument that the claimed subject matter provides any improvement to any technology or technical field, the alleged improvement(s) in the abstract idea itself (e.g. a recited fundamental economic concept) is not an improvement in technology. Example(s) that the courts have indicated may not be sufficient to show an improvement in computer-functionality: i. Generating restaurant menus with functionally claimed features, Ameranth, 842 F.3d at 1245, 120 USPQ2d at 1857; ii. Accelerating a process of analyzing audit log data when the increased speed comes solely from the capabilities of a general-purpose computer, FairWarning IP, LLC v. Iatric Sys., 839 F.3d 1089, 1095, 120 USPQ2d 1293, 1296 (Fed. Cir. 2016); iii. Mere automation of manual processes, such as using a generic computer to process an application for financing a purchase, Credit Acceptance Corp. v. Westlake Services, 859 F.3d 1044, 1055, 123 USPQ2d 1100, 1108-09 (Fed. Cir. 2017) or speeding up a loan-application process by enabling borrowers to avoid physically going to or calling each lender and filling out a loan application, LendingTree, LLC v. Zillow, Inc., 656 Fed. App'x 991, 996-97 (Fed. Cir. 2016) (non-precedential); iv. Recording, transmitting, and archiving digital images by use of conventional or generic technology in a nascent but well-known environment, without any assertion that the invention reflects an inventive solution to any problem presented by combining a camera and a cellular telephone, TLI Communications, 823 F.3d at 611-12, 118 USPQ2d at 1747; vi. Instructions to display two sets of information on a computer display in a non-interfering manner, without any limitations specifying how to achieve the desired result, Interval Licensing LLC v. AOL, Inc., 896 F.3d 1335, 1344-45, 127 USPQ2d 1553, 1559-60 (Fed. Cir. 2018); vii. Providing historical usage information to users while they are inputting data, in order to improve the quality and organization of information added to a database, because "an improvement to the information stored by a database is not equivalent to an improvement in the database's functionality," BSG Tech LLC v. Buyseasons, Inc., 899 F.3d 1281, 1287-88, 127 USPQ2d 1688, 1693-94 (Fed. Cir. 2018); viii. Arranging transactional information on a graphical user interface in a manner that assists traders in processing information more quickly, Trading Technologies v. IBG LLC, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019);
Examples that the courts have indicated may not be sufficient to show an improvement to technology include: i. A commonplace business method being applied on a general purpose computer, Alice Corp., 573 U.S. at 223, 110 USPQ2d at 1976; Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015); iv. Delivering broadcast content to a portable electronic device such as a cellular telephone, when claimed at a high level of generality, Affinity Labs of Tex. v. Amazon.com, 838 F.3d 1266, 1270, 120 USPQ2d 1210, 1213 (Fed. Cir. 2016); Affinity Labs of Tex. v. DirecTV, LLC, 838 F.3d 1253, 1262, 120 USPQ2d 1201, 1207 (Fed. Cir. 2016); v. A general method of screening emails on a generic computer, Symantec, 838 F.3d at 1315-16, 120 USPQ2d at 1358-59; vi. An advance in the informational content of a download for streaming, Affinity Labs of Tex. v. DirecTV, LLC, 838 F.3d 1253, 1263, 120 USPQ2d 1201, 1208 (Fed. Cir. 2016); vii. Selecting one type of content (e.g., FM radio content) from within a range of existing broadcast content types, or selecting a particular generic function for computer hardware to perform (e.g., buffering content) from within a range of well-known, routine, conventional functions performed by the hardware, Affinity Labs of Tex. v. DirecTV, LLC, 838 F.3d 1253, 1264, 120 USPQ2d 1201, 1208 (Fed. Cir. 2016);
Contrary to the Applicant's above-quoted assertions, the Applicant's alleged invention as delineated by the currently pending claims appears to be deeply rooted in the abstract idea. The Applicant's claims do not purport to improve the functioning of the computer itself, or to improve any other technology or technical field, rather "the focus of the claims is not on [] an improvement in computers as tools, but on certain independently abstract ideas that use computers as tools." Electric Power Group, LLC, v. Alstom, 830 F.3d 1350, 1354, 119 U.S.P.Q.2d 1739, 1742 (Fed. Cir. 2016). The Federal Circuit has held that "communicating requests to a remote server and receiving communications from that server, i.e., communication over a network" is itself an abstract idea. See ChargePoint, Inc. v. SemaConnect, Inc., 2019 U.S.P.Q.2d at 108516: "It is clear from the language of claim 1 that the claim involves an abstract idea--namely, the abstract idea of communicating requests to a remote server and receiving communications from that server, i.e., communication over a network. [] We therefore continue our analysis to determine whether the focus of claim 1, as a whole, is the abstract idea. As explained below, we conclude that it is." ChargePoint, Inc. v. SemaConnect, Inc., 2019 U.S.P.Q.2d 108512 (Fed. Cir. 2019).
'[T]he "invention" is what is claimed'. Zoltek Corp. v. United States, 672 F.3d 1309, 1318, 102 USPQ2d 1001, 1008 (Fed. Cir. 2012). The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. See Alice Corp., 134 S. Ct. at 2358: 'Stating an abstract idea "while adding the words 'apply it'" is not enough for patent eligibility. Mayo, supra, at ___, 132 S. Ct. 1289, 182 L. Ed. 2d 321, 325. Nor is limiting the use of an abstract idea "'to a particular technological environment.'" Bilski, supra, at 610-611, 130 S. Ct. 3218, 177 L. Ed. 2d 792.' F For Step 2B, relying on what the courts have recognized, or those in the art would recognize, as elements that are well-understood, routine and conventional, the claims in the present application are ineligible under Step 2B. For example, the courts have recognized the following computer functions to be well-understood, routine, and conventional functions when they are claimed in a merely generic manner: performing repetitive calculations, receiving, processing, and storing data, electronically scanning or extracting data from a physical document, electronic recordkeeping, automating mental tasks, and receiving or transmitting data over a network, e.g., using the Internet to gather data. Courts have held computer-implemented processes not to be significantly more than an abstract idea (and thus ineligible) where the claim as a whole amounts to nothing more than generic computer functions merely used to implement an abstract idea, such as an idea that could be done by a human analog (i.e., by hand or by merely thinking).
The Office refers the Applicant to see the current rejection based upon the currently pending claims under the 35 U.S.C. § 101 heading above.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
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Any inquiry concerning this communication or earlier communications from the examiner should be directed to SLADE E. SMITH whose telephone number is 571- 272-8645. The examiner can normally be reached Monday through Tuesday from 10:30 AM to 6:30 PM.
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Sincerely,
/SLADE E SMITH/Primary Examiner, Art Unit 3696 01/09/2026