DETAILED ACTION
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 .
Status of Claims
This action is in reply to the amended claims and RCE filed on 11/24/2025, wherein:
Claims 1-18 and 20 have been amended;
Claim 19 remains as previously presented; and
Claims 1-20 are currently pending and have been examined.
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 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. The claims recite a method and system for providing collateral which is considered a judicial exception because it falls under Certain Methods of Organizing Human Activity such as commercial or legal interactions including agreements in the form of contracts and business relations. This judicial exception is not integrated into a practical application as discussed below and the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception as discussed below.
This rejection follows the 2019 Revised Patent Subject Matter Eligibility Guidance, 84 Fed Reg 4, January 7, 2019, pp. 50-57 (“2019 PEG”).
Analysis
Step 1 (Statutory Categories) – 2019 PEG pg. 53 (See MPEP 2106.03)
Claims 1-20 are directed to the statutory category of a process, machine, or manufacture.
Step 2A, Prong 1 (Do the claims recite an abstract idea?) – 2019 PEG pg. 54
For independent claim 1, the claim recites an abstract idea of: providing collateral. The steps of: A method comprising: receiving a creation request to create a first reference account in a legal trust for a first party, with the legal trust managed by a custodia; storing a storage element representing the legal trust; based on the storage element, accessing a computer representation of the legal trust to facilitate the creation request; in accordance with the computer representation, recording receipt of proceeds obtained from the first party and placed in the first reference series account in the legal trust for the first party; reading data representing a high quality liquid asset portfolio according to a specific set of investment criteria for deposit in the first reference series account, with the first reference series account of the legal trust under operation control by a money center bank to segregate securities from those of the first party and the custodian elimination counterparty credit risk, storing data specifying a transfer of the high quality liquid asset portfolio to a segregated central securities depository of a money center bank account at a sovereign central bank, which transfer is entered on books and records of the money center bank corresponding to the money center bank account, as backing a high-quality, redeemable security to segregate the high quality liquid asset portfolio from other securities of the custodian; recording data indicating issuance of the high-quality, redeemable security to an investor, with the high quality, redeemable security being backed by the high quality liquid asset portfolio; generating based on the storage element, data for an electronic visual representation of a daily machine-readable report identifying individual securities held in the high-quality, redeemable security, the report comprising for each security at least one of: (i) a market identification number, (ii) a credit rating, and (iii) a net asset value (NAV); transmitting the data for the electronic visual representation of the daily, machine-readable report to a client system associated with the investor, wherein access to the report is restricted; and in accordance with the data for the electronic visual representation, automatically causing rendering the electronic visual representation of the daily machine readable report; when considered collectively as an ordered combination, recite the abstract idea of providing collateral.
For independent claim 9, the claim recites an abstract idea of: providing collateral. The steps of: A computer implemented method comprising: perform operations comprising: storing a storage element representing the legal trust; based on the storage element, accessing a computer representation of the legal trust to facilitate the creation request; in accordance with the computer representation, recording receipt of proceeds obtained from the first party and placed in the first reference series account in the legal trust for the first party; reading data representing a high quality liquid asset portfolio according to a specific set of investment criteria for deposit in the first reference series account, with the first reference series account of the legal trust under operation control by a money center bank to segregate securities from those of the first party and a custodian elimination counterparty credit risk, storing data specifying a transfer of the high quality liquid asset portfolio to a segregated central securities depository of a money center bank account at a sovereign central bank, which transfer is entered on books and records of the money center bank corresponding to the money center bank account, as backing a high-quality, redeemable security to segregate the high quality liquid asset portfolio from other securities of the custodian; recording data indicating issuance of the high-quality, redeemable security to an investor, with the high quality, redeemable security being backed by the high quality liquid asset portfolio; and generating based on the storage element, data for an electronic visual representation of a daily machine-readable report identifying individual securities held in the high-quality, redeemable security, the report comprising for each security at least one of: (i) a market identification number, (ii) a credit rating, and (iii) a net asset value (NAV); receiving a particular creation request to create a particular reference series account in a particular legal trust for a particular first party, with the particular legal trust managed by a particular custodian; and in response to receiving the particular creation request, perform operations comprising: storing the storage element representing the particular legal trust; based on the storage element, accessing a computer representation of the particular legal trust to facilitate the particular creation request; in accordance with the computer representation, recording receipt of proceeds obtained from the particular first party and placed in the particular reference series account in the particular legal trust for the particular first party; reading data representing a high quality liquid asset portfolio according to a specific set of investment criteria for deposit in the particular reference series account, with the particular reference series account of the particular legal trust under operation control by a money center bank to segregate securities from those of the particular first party and the particular custodian eliminating counterparty credit risk storing data specifying a transfer of the high quality liquid asset portfolio to a segregated central securities depository of a money center bank account at a sovereign central bank, which transfer is entered on books and records of the money center bank corresponding to the money center bank account, as backing a high-quality, redeemable security to segregate the high quality liquid asset portfolio from other securities of the particular custodian; recording data indicating issuance of the high-quality, redeemable security to an investor, with the high quality, redeemable security being backed by the high quality liquid asset portfolio; generating based on the storage element, data for an electronic visual representation of a daily, machine-readable report identifying individual securities held in the high-quality, redeemable security, the report comprising for each security at least one of: (i) a market identification number, (ii) a credit rating, and (iii) a net asset value (NAV); transmitting, the data for the electronic visual representation of the daily, machine-readable report to a client system associated with the investor, wherein access to the report is restricted to the client system; and in accordance with the data for the electronic visual representation, automatically causing rendering on a display, the electronic visual representation of the daily, machine-readable report, when considered collectively as an ordered combination, recite the abstract idea of providing collateral.
For independent claim 13, the claim recites an abstract idea of: providing collateral. The steps of: perform operations comprising: receive a creation request to create a first reference account in a legal trust for a first party, with the legal trust managed by a custodia; store a storage element representing the legal trust; based on the storage element, access a computer representation of the legal trust to facilitate the creation request; in accordance with the computer representation, record receipt of proceeds obtained from the first party and placed in the first reference series account in the legal trust for the first party; read data representing a high quality liquid asset portfolio according to a specific set of investment criteria for deposit in the first reference series account, with the first reference series account of the legal trust under operation control by a money center bank to segregate securities from those of the first party and the custodian, thereby eliminating counterparty credit risk, store data specifying a transfer of the high quality liquid asset portfolio to a segregated central securities depository of a money center bank account at a sovereign central bank, which transfer is entered on books and records of the money center bank corresponding to the money center bank account, as backing a high-quality, redeemable security to segregate the high quality liquid asset portfolio from other securities of the custodian; record data indicating issuance of the high-quality, redeemable security to an investor, with the high quality, redeemable security being backed by the high quality liquid asset portfolio; generate based on the storage element, data for an electronic visual representation of a daily machine-readable report identifying individual securities held in the high-quality, redeemable security, the report comprising for each security at least one of: (i) a market identification number, (ii) a credit rating, and (iii) a net asset value (NAV); transmit the data for the electronic visual representation of the daily, machine-readable report to a client system associated with the investor, wherein access to the report is restricted; and in accordance with the data for the electronic visual representation, automatically causing rendering the electronic visual representation of the daily machine readable report, when considered collectively as an ordered combination, recite the abstract idea of providing collateral.
Independent claims 1, 9, and 13, as drafted, are a process that, under the broadest reasonable interpretation, covers Certain Methods of Organizing Human Activity, since they recite commercial or legal interactions including agreements in the form of contracts and business relations. For independent claim 1, the steps of: A method comprising: receiving a creation request to create a first reference account in a legal trust for a first party, with the legal trust managed by a custodia; storing a storage element representing the legal trust; based on the storage element, accessing a computer representation of the legal trust to facilitate the creation request; in accordance with the computer representation, recording receipt of proceeds obtained from the first party and placed in the first reference series account in the legal trust for the first party; reading data representing a high quality liquid asset portfolio according to a specific set of investment criteria for deposit in the first reference series account, with the first reference series account of the legal trust under operation control by a money center bank to segregate securities from those of the first party and the custodian elimination counterparty credit risk, storing data specifying a transfer of the high quality liquid asset portfolio to a segregated central securities depository of a money center bank account at a sovereign central bank, which transfer is entered on books and records of the money center bank corresponding to the money center bank account, as backing a high-quality, redeemable security to segregate the high quality liquid asset portfolio from other securities of the custodian; recording data indicating issuance of the high-quality, redeemable security to an investor, with the high quality, redeemable security being backed by the high quality liquid asset portfolio; generating based on the storage element, data for an electronic visual representation of a daily machine-readable report identifying individual securities held in the high-quality, redeemable security, the report comprising for each security at least one of: (i) a market identification number, (ii) a credit rating, and (iii) a net asset value (NAV); transmitting the data for the electronic visual representation of the daily, machine-readable report to a client system associated with the investor, wherein access to the report is restricted; and in accordance with the data for the electronic visual representation, automatically causing rendering the electronic visual representation of the daily machine readable report, considered collectively as an ordered combination, is a process that, under the broadest reasonable interpretation, covers Certain Methods of Organizing Human Activity such as commercial or legal interactions including agreements in the form of contracts and business relations. Based on similar reasoning and rationale, the steps of Independent claims 9 and 13 also recite Certain Methods of Organizing Human Activity. Providing collateral through a trust is creating contractual agreements for participants in a business relationship. Hence all the steps of the claim, considered collectively as an ordered combination, fall under the abstract idea of Certain Methods of Organizing Human Activity. If the claim limitations, under the broadest reasonable interpretation, cover Certain Methods of Organizing Human Activity, but for the recitation of computer components, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Other than reciting the abstract idea, the independent claims recite additional elements including generic computer components such as “computer implemented, one or more computers, a database, representation, a display unit of a client system, automatically rendering the report, and a platform comprising: computer systems comprising a processor and memory”, and nothing in the claims precludes the steps from being performed as Certain Methods of Organizing Human Activity. Accordingly, the independent claims recite an abstract idea.
Dependent claims 2-8, 10-12, and 14-20 recite similar limitations as independent claims 1, 9, and 13; and when analyzed as a whole are held to be patent ineligible under 35 U.S.C 101 because the additional recited limitations only refine the abstract idea further. For instance, in claims 2, 3, 7, 14, 17, and 19, the additional limitations of: wherein the high quality liquid asset portfolio includes instruments issued or guaranteed by a sovereign or sovereign governmental agency, wherein the high quality liquid asset portfolio includes instruments issued or guaranteed by the US Government or a US Governmental agency, wherein the high quality liquid asset portfolio includes debt instruments of a sovereign government, under the broadest reasonable interpretation, are further refinements of Certain Methods of Organizing Human Activity such as commercial or legal interactions including agreements in the form of contracts and business relations, because these further describe the high quality liquid asset portfolio.
In claims 4-6, 15, and 16, the limitations of: wherein the high-quality, redeemable security has plural types and redemption features corresponding to the plural types, each of the redemption features corresponding to a number of dates for settling based on a type from the plural types indicating acquisition of the high-quality, redeemable security; wherein for securities that are redeemable in Canada, the redeemable securities are used for Canadian Reinsurance Security Arrangements; wherein the redeemable securities are listed on a securities exchange or securities market having a unique market identification number, under the broadest reasonable interpretation, are further refinements of Certain Methods of Organizing Human Activity such as commercial or legal interactions including agreements in the form of contracts and business relations, because these further describe the securities.
In claims 8 and 18, the limitations of: recording, by the one or more computers, receipt of proceeds obtained from additional parties and place corresponding additional reference series accounts in the legal trust for the additional parties; acquiring additional high quality liquid asset portfolios according to specified sets of investment criteria for deposit in the additional reference series accounts; and issuing additional high-quality, redeemable securities backed by the acquired high quality liquid asset portfolios deposited in the additional reference series accounts, under the broadest reasonable interpretation, are further refinements of Certain Methods of Organizing Human Activity such as commercial or legal interactions including agreements in the form of contracts and business relations because these describe further steps for creating additional trusts for additional parties.
In claims 10-12, the limitations of: wherein the particular first party is a large insurance holding company subject to sovereign insurance regulations regarding capital reserves; wherein a second party that provides the high-quality, redeemable securities is a captive insurance company of the large insurance holding company, which captive insurance company is not subject to a same level of capital reserves regulation as the large insurance holding company, but which has a re-insurance relationship to the large insurance holding company; and wherein a level of capital reserves of the second party is none or reduced capital reserves compared to the first party, under the broadest reasonable interpretation, are further refinements of Certain Methods of Organizing Human Activity such as commercial or legal interactions including agreements in the form of contracts and business relations because these further describe the parties providing securities.
Other than reciting the abstract idea, the dependent claims recite similar additional elements as the independent claims including generic computer components, such as “one or more computers, and the system”. If a claim limitation, under its broadest reasonable interpretation, covers commercial or legal interactions, but for the recitation of computer components, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas.
Step 2A, Prong 2 (Does the claim recite additional elements that integrate the judicial exception into a practical application?) – 2019 PEG pg. 54
This judicial exception is not integrated into a practical application. In particular, independent claims 1, 9, and 13 only recite the additional elements of “computer implemented, one or more computers, a database, representation, a display unit of a client system, automatically rendering the report, and a platform comprising: computer systems comprising a processor and memory”. A plain reading of Figures 1-8, and associated descriptions in the specification in at least: page 9, lines 4-9 stating “the KT-Note Portfolio held in the RefSA may be viewed electronically using a digital investment service (DIS) such as BNY Mellon’s NEXEN system that allows KT-Note holders to view each individual security in the reference KT-Note Portfolio as at the close of business on the prior business day…and produce daily KT-Note Portfolio reports that are automatically emailed to authorized KT-Note holder client systems”, page 12, lines 1-14 stating “Processors suitable for the execution of a computer program include…both general and special purpose microprocessor, and any one or more processors of any kind of digital computer”, page 12, lines 15-25 stating “platform can reside and be executed on the computer system. The system can include a processor device, a memory, a storage device, and input/output interfaces interconnected via a bus…processor is a single-threaded processor…processor is a multi-threaded processor…processor can include multiple processing cores and is capable of processing instructions stored in the memory or on the storage device to display graphical information for a user interface on output monitor device”, and page 12, lines 26-29 stating “the computer system can be connected to a network, e.g. the Internet, through a network interface controller. Other systems, such as the client systems, the counterparty systems, the bank systems, etc.. discussed above can also be connected to the same network or a different network that can communicate with the network”; and page 13, lines 10-20 stating “the invention can be embodied in and/or used with various apparatus, device, and machines for processing data, including by way of example a programmed processor, a computer, or multiple processors or computers”, reveals that generic processors may be used to execute the claimed steps. The additional elements of “computer implemented, one or more computers, a database, representation, a display unit of a client system, automatically rendering the report, and a platform comprising: computer systems comprising a processor and memory” are recited at a high level of generality (i.e., as a generic processor performing generic computer functions) such that it amounts to no more than mere instructions to apply the exception using generic computer components (See MPEP 2106.05(f)) and limits the judicial exception to a particular environment (See MPEP 2106.05(h)). Mere instructions to apply an exception using a generic computer component and limiting the judicial exception to a particular environment doesn’t integrate the abstract idea into a practical application in Step 2A. 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. Hence, independent claims 1, 9, and 13 are directed to an abstract idea.
Dependent claims 2-8, 10-12, and 14-20, recite similar additional elements as the independent claims including generic computer components, such as “one or more computers, and the system”. The judicial exception is not integrated into a practical application because the additional elements in the dependent claims are also recited at a high-level of generality such that it amounts to more no more than mere instructions to apply the exception using generic computer components. Therefore, the additional elements do not integrate the abstract idea into a practical application because they also do not impose any meaningful limits on practicing the abstract idea. Also, the claims do not affect an improvement to another technology or technical field; the claims do not amount to an improvement of the functioning of a computer system itself; the claims do not effect a transformation or reduction of a particular article to a different state or thing; and the claims do not move beyond a general link of the use of an abstract idea to a particular technological environment.
Step 2B (Does the claim recite additional elements that amount to significantly more than the judicial exception?) – 2019 PEG pg. 56
Independent claims 1, 9, and 13 do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements of “computer implemented, one or more computers, a database, representation, a display unit of a client system, automatically rendering the report, and a platform comprising: computer systems comprising a processor and memory” to perform the steps of independent claim 1 for: A method comprising: receiving a creation request to create a first reference account in a legal trust for a first party, with the legal trust managed by a custodia; storing a storage element representing the legal trust; based on the storage element, accessing a computer representation of the legal trust to facilitate the creation request; in accordance with the computer representation, recording receipt of proceeds obtained from the first party and placed in the first reference series account in the legal trust for the first party; reading data representing a high quality liquid asset portfolio according to a specific set of investment criteria for deposit in the first reference series account, with the first reference series account of the legal trust under operation control by a money center bank to segregate securities from those of the first party and the custodian elimination counterparty credit risk, storing data specifying a transfer of the high quality liquid asset portfolio to a segregated central securities depository of a money center bank account at a sovereign central bank, which transfer is entered on books and records of the money center bank corresponding to the money center bank account, as backing a high-quality, redeemable security to segregate the high quality liquid asset portfolio from other securities of the custodian; recording data indicating issuance of the high-quality, redeemable security to an investor, with the high quality, redeemable security being backed by the high quality liquid asset portfolio; generating based on the storage element, data for an electronic visual representation of a daily machine-readable report identifying individual securities held in the high-quality, redeemable security, the report comprising for each security at least one of: (i) a market identification number, (ii) a credit rating, and (iii) a net asset value (NAV); transmitting the data for the electronic visual representation of the daily, machine-readable report to a client system associated with the investor, wherein access to the report is restricted; and in accordance with the data for the electronic visual representation, automatically causing rendering the electronic visual representation of the daily machine readable report, and based on similar reasoning and rationale for the steps of independent claims 9 and 13, amounts to no more than mere instructions to apply the exception using a generic computer component (See MPEP 2106.05(f)) and limits the judicial exception to the particular environment of computers (See MPEP 2106.05(h)). The additional elements of the instant underlying process, when taken in combination, together do not offer significantly more than the sum of the functions of the elements when each is taken alone. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept in Step 2B.
Further, MPEP 2106.05(d)(ii) provides that receiving and transmitting data over a network (see 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)); are well-understood routine and conventional, similar to the independent claims which recite: “receiving a creation request to create a first reference account in a legal trust for a first party, accessing a computer representation of the legal trust, transmitting the data for the electronic visual representation…, wherein access to the report is restricted”. Furthermore, MPEP 2106.05(d)(ii) provides that performing repetitive calculations (see Flook, 437 U.S. at 594, 198 USPQ2d at 199 (recomputing or readjusting alarm limit values), and 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”)) are well-understood, routine, conventional activity, similar to the claimed limitations of the independent claims for: “generating…data for an electronic visual representation…, ”. MPEP 2106.05(d)(ii) provides that electronic recordkeeping (Alice Corp. Pty. Ltd. v. CLS Bank Int'l, 573 U.S. 208, 225, 110 USPQ2d 1984 (2014) (creating and maintaining "shadow accounts"); Ultramercial, 772 F.3d at 716, 112 USPQ2d at 1755 (updating an activity log)), and storing and retrieving information in memory (see Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015); OIP Techs., 788 F.3d at 1363, 115 USPQ2d at 1092-93) are well-understood, routine, conventional activity, similar to the claimed limitations of the independent claims for: “storing a storage element representing the legal trust, storing data specifying a transfer of the high quality liquid asset portfolio to a segregated central securities depository, recording receipt of proceeds obtained from the first party…, reading data representing a high quality liquid asset portfolio…, which transfer is entered on books and records of the money center bank…, recording data indicating issuance of the high-quality, redeemable security to an investor…, ”. Furthermore, the steps for “rendering the electronic report” are merely presenting results of an analysis akin to Electric Power Group, LLC v. Alstom S.A., 830 F.3d 1350, 1354, 119 USPQ2d 1739, 1742 (Fed. Cir. 2016) and are only generally linking the use of the judicial exception to a particular technological environment (see MPEP 2106.05(h)). Therefore, independent claims 1, 9, and 13 are not patent eligible.
In addition, the dependent claims 2-8, 10-12, and 14-20 do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements of the dependent claims of: “one or more computers, and the system” to perform the claimed limitations, amounts to no more than mere instructions to apply the exception using a generic computer component (See MPEP 2106.05(f)). Similar to the independent claims, mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Also, for the same reasoning as the independent claims, the additional elements of the limitations of the dependent claims, when considered individually and as an ordered combination, together do not offer significantly more than the sum of the functions of the elements when each is taken alone and the dependent claims as a whole, do not amount to significantly more than the abstract idea itself. Dependent claims 8 and 18 recite limitations for: “recording…receipt of proceeds…, place corresponding additional reference series accounts in the legal trust…”, which are electronic record keeping, storing and retrieving information in memory that are well understood and conventional functions (see MPEP 2106(d)(ll)). For these reasons, dependent claims 2-8, 10-12, and 14-20 also are not patent eligible under 35 U.S.C. 101.
Subject Matter Overcoming 35 USC §102/§103
Claims 1-20 would be allowable if rewritten to overcome the rejections under 35 U.S.C. 101 set forth in this Office Action.
Examiner’s statement of reasons for the indication of allowable subject matter of independent claims 1, 9, and 13 over prior art were previously given in the Non-final rejection dated 4/20/2023, and are hence not repeated here.
Response to Arguments
Applicant’s arguments with respect to claims 1-20 have been fully considered by the Examiner. Applicant’s arguments and amended claims have been considered with respect to previous rejections pursuant to 35 U.S.C. 112(b) and the previous rejections are withdrawn. Applicant’s arguments with respect to the rejection of claims 1-20 under 35 USC 101 have been fully considered by the Examiner. However, the Examiner does not find the Applicant’s arguments persuasive, and therefore the rejections of claims 1-20 under 35 USC 101 are maintained.
The Applicant argues that under Prong 1 of Step 2A of the 2019 PEG, the claims do not recite an abstract idea because the claims are rooted in database functionality and cannot be performed in the human mind. The Applicant further states on pages 16-18 of their remarks, that the limitations of the independent claims under Prong 2 of Step 2A are indicative of integration into a practical application because they provide an improved user interface for electronic devices. Applicant further argues that the claims do not recite generic computing computers but rather a specific technical solution for segregating securities in a way that reduces counterparty risks. Applicant further argues on page 18 of their Remarks that the claims address a specific technical problem for providing secure collateral mechanisms and the combination of elements amounts to significantly more and provide for a technical improvement in secure collateral transactions between entities.
Examiner respectfully disagrees with Applicant’s argument that the claimed limitations do not recite an abstract idea. Under Prong 1 of the 2019 PEG, the claims do fall under the abstract idea of Certain Method of Organizing Human Activity. If a claim limitation, under its broadest reasonable interpretation, covers commercial or legal interactions including agreements in the form of contracts and business relations, but for the recitation of additional elements including generic computer components, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Under the broadest reasonable interpretation, the claims recite agreements and business relations. Providing collateral through a trust is creating contractual agreements for participants in a business relationship..
Examiner respectfully disagrees with Applicant’s argument that the claimed limitations are indicative of integration into a practical application under Prong 2 of Step 2A of the PEG. Using a computer to: receive a request, store a legal trust, record receipt of proceeds, read a database, store portfolio transfers in a database, record securities in a database, and generate a report for display on a client device; is nothing more than executing instructions to apply the exception to a computer. This is interpreted by the Examiner as using a computer as a tool to perform an abstract idea (See MPEP 2106.05(f)). The additional elements of “computer implemented, one or more computers, a database, representation, a display unit of a client system, automatically rendering the report, and a platform comprising: computer systems comprising a processor and memory” are recited at a high level of generality such that it amounts to no more than mere instructions to apply the exception using generic computer components (See MPEP 2106.05(f)). Although the claimed business process has been improved, there is no improvement to the claimed computer elements, the user interface, databases, or to any other technology or technical field. The only improvements identified in the specification are generic speed and efficiency improvements inherent in applying the use of a computer to any task. Merely implementing an abstract idea on a computer in order to increase the efficiency or speed of the abstract idea itself is not indicative of a technical solution to a technical problem – see MPEP 2106.05(a), underline emphasis added: “However, it is important to keep in mind that an improvement in the abstract idea itself (e.g. a recited fundamental economic concept) is not an improvement in technology. For example, in Trading Technologies Int’l v. IBG, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019), the court determined that the claimed user interface simply provided a trader with more information to facilitate market trades, which improved the business process of market trading but did not improve computers or technology”. Therefore, the claimed limitations do not meet the criteria or considerations as indicative of integration into a practical application.
Examiner respectfully disagrees with Applicant’s further argument that the amended claim limitations in combination amount to “significantly more” and provide for technical improvements in secure collateral transactions. As stated previously, using a computer to: receive a request, store a legal trust, record receipt of proceeds, read a database, store portfolio transfers in a database, record securities in a database, and generate a report for display on a client device; is nothing more than executing instructions to apply the exception to a computer. The additional elements of “computer implemented, one or more computers, a database, representation, a display unit of a client system, automatically rendering the report, and a platform comprising: computer systems comprising a processor and memory” amount to no more than mere instructions to apply the exception using a generic computer component. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. In addition, as indicated further in the Non-final rejection above, the claimed limitations under MPEP 2106.05(d)(ii) amount to well-understood routine and conventional activities of: receiving and transmitting data over a network, the performance of repetitive calculations, electronic recordkeeping, storing and retrieving information in memory, and presenting results of an analysis. Therefore, the rejections of the claims pursuant to 35 USC 101 are maintained.
Conclusion
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/PAUL S SCHWARZENBERG/Primary Examiner, Art Unit 3695 3/13/2026