DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application is being examined under the pre-AIA first to invent provisions.
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 37-38, 40-44, 46-48, 56-62 and 64-66 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (abstract idea) without significantly more.
Analysis
Claim 43: Ineligible.
STEP 1:
The claim recites a series of steps. The claim is directed to a process, which is a statutory category of invention (Step 1: YES).
STEP 2A (PRONG 1):
The claim is analyzed to determine whether it is directed to a judicial exception. The claim recites the limitations of:
receiving, by a companion mobile device from a primary mobile application associated with the primary policyholder with a first set of login credentials associated with the primary policyholder, authorization for a secondary account associated with a companion mobile application associated with a secondary policyholder for the primary insurance policy, wherein the primary insurance policy is stored on a server, and wherein the primary mobile application is installed on the primary mobile device and the companion mobile application is installed on the companion mobile device;
providing, by the companion mobile device to the server via the companion mobile application, the authorizations wherein the authorization includes a second set of login credentials associated with the secondary policyholder;
pairing the companion mobile device with the primary mobile device based on a validation of the authorization;
receiving, by the companion mobile device from the server, access to the companion mobile application on the companion mobile device in response to the validation;
accessing, using token password, a first subset of the primary insurance policy information, wherein the first subset of the primary insurance policy information is defined by option information provided by the primary mobile device based on one or more rules designated by the primary policyholder in the primary mobile application, and wherein the option information comprises a set of attributes specifying one or more types of information accessible to the secondary account through the companion mobile application;
displaying, via the companion mobile application, the first subset if the primary insurance policy information; and
submitting, to the server via the companion mobile application, a policy claim associated with the primary insurance policy and with the secondary policyholder using the second set of login credentials and without requiring the first set of login credential, wherein the policy claim comprises at least a portion of the first subset of the primary insurance policy information.
Examiner submits that the foregoing bolded limitation(s) constitute fundamental economic practice. In other words, the claim describes a process for allowing a primary insurance policyholder to restrict certain information accessible to a secondary insurance policyholder via authorization using token password (credentials) (that is, controlling access to resources using generic computer hardware running generic computer software that performs the abstract functions routine to the process of restricting access to resources). Initially, the primary insurance policyholder logs into the app and provides an authorization for a secondary insurance policyholder to access certain information as may be allowed by the primary policyholder (based on defined rules set by primary policyholder) when using the secondary insurance policyholder’s credentials. These limitations, as drafted, are processes that, under its broadest reasonable interpretation, covers performance of the limitations via fundamental human activities, but for the recitation of generic computer components. These limitations fall under the subgroup “managing personal behavior/relationship/interactions between people” of “certain methods of organizing human activity” group (Step 2A1-Yes). See MPEP 2106.04(a)-(c)
STEP 2A (PRONG 2):
Next, the claim is analyzed to determine if it is integrated into a practical application. Examiner submits that the foregoing italicized limitation(s) constitute the additional elements. The claim recites additional elements of mobile devices with appropriate application installed to perform the steps, and server (all considered processors); pairing devices based on validation of the authorization; using token password to access information, and displaying subset on policy information that is defined by attributes provided by the primary policyholder based on one or more rules designated by the primary policyholder. The processors (servers and mobile devices) in the steps are recited at a high level of generality, i.e., as generic processors performing generic computer functions of processing data. These generic processors limitation are no more than mere instructions to apply the exception using generic computer components. (see MPEP 2106.05(f)). Displaying subset of information is basically displaying generic information which is common to displays. (see MPEP 2106.05(f))
Furthermore, the additional elements of pairing devices based on validation, and using token password to access information, are insignificant extra-solution activities. (see MPEP 2106.05(g)).
Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. The claim is directed to the abstract idea (Step 2A2-No). See MPEP 2106.04(II)(A)(2) and MPEP 2106.04(d)(2)
STEP 2B:
Next, the claim is analyzed to determine if there are additional claim limitations that individually, or as an ordered combination, ensure that the claim amounts to significantly more than the abstract ideas (whether claim provides inventive concept). As discussed with respect to Step 2A2 above, the additional element in the claim amounts to no more than mere instructions to apply the exception using a generic computer component. 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. Because the steps of pairing devices based on validation, and using token password to access information, were considered to be extra-solution activities in Step 2A, they are re-evaluated in Step 2B to determine if they are more than what is well-understood, routine and conventional in the field. The disclosure does not provide any indication that pairing of devices based on validation is anything other than conventional. Furthermore, the disclosure further teaches that the technique of pairing devices to confirm identity of devices is well known to a person of ordinary skill in the art (0047: “[S]uch pairing techniques would be known to a person of ordinary skill in the art”). Accordingly, a conclusion that the pairing step is well-understood, routine and conventional activity is supported under Berkheimer option 1. See MPEP 2106.05(d)).
Also, the disclosure does not provide any indication that using token password to access information is anything other than conventional and Leetham (USPN 9,075,991) at col. 1, lines 21-26 indicates that this step is well-understood, routine and conventional in the field (as they are here). Accordingly, a conclusion that these steps are well-understood, routine and conventional activities is supported under Berkheimer option 3. See MPEP 2106.05(d))
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, 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). The claim is not patent eligible. See MPEP 2106.05
Claim 37 recites a corresponding machine equivalent of claim 43. This claim is similarly rejected under the same rationale as claim 43, supra.
Claims 38 and 44 recite updating the first subset of the primary insurance policy information based on at least one change to the primary insurance policy information. Updating information is also part of the abstract idea identified in claim 43, and is similarly rejected under the same rationale as claim 43, supra.
Claims 40 and 46 recite wherein the change to the primary insurance policy information is received from a server, nfc device or cloud-based network. Receiving information from a server, nfc device or cloud network is no more than mere instructions to apply the exception using generic computer components. These additional elements are as addressed in the Steps 2A2 and B in the claim 43 analysis above. Therefore, this claim is similarly rejected under the same rationale as claim 43, supra.
Claims 41 and 47 recite wherein the change to the primary insurance policy information is submitted by at least one of the primary policyholder, an insurance company that provides the primary insurance policy, or the secondary policyholder. Submitting or sending information is also part of the abstract idea identified in claim 43, and is similarly rejected under the same rationale as claim 43, supra.
Claims 42 and 48 recite wherein the option information further comprises a second subset of the primary insurance policy information accessible by a second secondary account, wherein the second subset of information is different from the first subset of information. This limitation is also part of the abstract idea identified in claim 43, and is similarly rejected under the same rationale as claim 43, supra.
Claim 56 and 57 recite wherein the at least one change to the primary insurance policy information is received at the companion device. This limitation is also part of the abstract idea identified in claim 43, and is similarly rejected under the same rationale as claim 43, supra.
Claim 58 and 59 recite wherein the one or more rules include defining the option information based on a familial relationship between the primary policyholder and the secondary policyholder. This limitation is also part of the abstract idea identified in claim 43, and is similarly rejected under the same rationale as claim 43, supra.
Claims 60-62 recite wherein the companion mobile application and primary mobile application are accessible to the secondary policyholder on one or more additional companion mobile devices; and wherein the primary mobile application is accessible to the primary policyholder on one or more additional primary mobile devices. These limitations are also part of the abstract idea identified in claim 43, and are similarly rejected under the same rationale as claim 43, supra.
Claim 64 recites wherein the companion mobile device is paired with the primary mobile device after validating the authorization of the secondary policyholder, the validation comprising confirming device identity and user credentials prior to permitting access to policy information.
This limitation further narrows the abstract idea, but is nonetheless part of the abstract idea identified in claim 43. The additional elements, as similarly analyzed in claim 43 above, do not integrate the abstract idea into a practical application. The claimed invention as a whole also does not amount to significantly more than the abstract idea. The claim is similarly rejected under the same rationale as claim 43, supra.
Claim 65 recites wherein the token password is to govern access to the first subset of the primary insurance policy information according to the one or more rules.
This limitation further narrows the abstract idea, but is nonetheless part of the abstract idea identified in claim 43. The additional elements, as similarly analyzed in claim 43 above, do not integrate the abstract idea into a practical application. The claimed invention as a whole also does not amount to significantly more than the abstract idea. The claim is similarly rejected under the same rationale as claim 43, supra.
Claim 66 recites, wherein the processor is further configured to execute the instructions to: enforce primary policyholder-defined rules to dynamically restrict the first subset of the primary insurance policy information; and automatically update the companion mobile device in real-time to reflect changes to the primary policy information.
These limitations further narrow the abstract idea, but are nonetheless part of the abstract idea identified in claim 43. The additional elements, as similarly analyzed in claim 43 above, do not integrate the abstract idea into a practical application. The claimed invention as a whole also does not amount to significantly more than the abstract idea. The claim is similarly rejected under the same rationale as claim 43, supra.
Response to Arguments
Applicant's arguments filed 10/14/2025 with respect to the 101 rejection have been fully considered but they are not persuasive.
Applicant argues that the Examiner improperly reduces the claimed subject matter to mere concept of “submitting a policy claim” while disregarding the specific technological mechanism recited in the claims. Furthermore, Applicant asserts that Examiner ignored the central technical features of the claimed subject matter such as the pairing step, the use of token password step, and the defining step.
Examiner respectfully disagrees. Examiner as provided a clear analysis of the rejection highlighting the claimed abstract idea, as well as the additional elements. The responses to these limitations are provided in the analysis above. The analysis concludes that the claim limitations, individually, or as an ordered combination do not amount to “significantly more” than an abstract idea.
As noted in the analysis above, the claim simply describes a process for allowing a primary policyholder to restrict certain information accessible to a secondary policyholder via authorization. Using various devices to achieve same is as a result of said authorization and subsequent validation. This is an abstract concept except for the use of user devices with appropriate applications and server. These devices are recited at a high level of generality, i.e., as generic processors performing generic computer functions. These generic processors limitations are no more than mere instructions to apply the exception using generic computer components.
The primary policyholder simply acts as an “administrator” with separate login credentials from the other allowed users (secondary policyholders), the secondary policyholder credentials being created by the “administrator” for others. The “administrator” is also able to define the access level for “others”. This access level then determines what information is displayable to the others based on the created secondary policyholder credentials. This is not an improvement in computer functionality. These are well-understood, routine and conventional activities. See Eicher and Schepis references cited below.
Finally, Applicant is encouraged the study the CAFC decision in Prism Techs. v. T-Mobile USA, Inc. (non-precedential) (see attached, particularly pages 5-7).
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Eicher et al. (USPAP 2011/0313870) at 0130-0131 teaches the concept of allowing a primary accountholder (policyholder) restrict certain information accessible to a secondary accountholder (policyholder) via authorization or based on rules, and displaying a subset of information based on such authentication credentials.
Schepis et al. (USPN 8918903) at col. 1, lines 7-25 similarly teaches the concept of allowing a primary accountholder (policyholder) restrict certain information accessible to a secondary accountholder (policyholder) via authorization or based on rules, and displaying a subset of information based on such authentication credentials.
The other references cited in the PTO-892 are as discussed in the previous office actions.
THIS ACTION IS MADE FINAL. 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.
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/OLABODE AKINTOLA/Primary Examiner, Art Unit 3691