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 .
Acknowledgments
The submission (RCE and Amendment) filed on 11/10/25 is acknowledged.
Status of Claims
Claims 21-40 are pending.
In the Amendment filed on 11/10/25, claims 1-20 were cancelled and claims 21-40 were added.
Claims 21-40 are rejected.
PTAB Decision
Applicant's instant submission on 11/10/25 follows a PTAB decision issued on 09/09/25 . The PTAB decision affirmed rejections under 35 U.S.C. 112(a) (claims 1-20) and 112(b) (claims 18-20) and issued a new ground of rejection under 35 U.S.C. 101 (claims 1-20).
Response to Arguments
Regarding the rejections under 35 U.S.C. 112
The offending subject matter on the basis of which the PTAB upheld the rejections is not included in new claims 21-40. Therefore, the claim rejections are moot.
Regarding the rejection under 35 U.S.C. 101
Applicant's arguments have been fully considered but are not persuasive.
The Office responds to Applicant's arguments below.
Clarification of the record
Applicant writes:
Claims 1-20 were rejected under 35 U.S.C. § 101 as being directed to a judicial exception without significantly more. Without conceding the propriety of the Examiner's rejection, by the present amendment and response, Applicant amends the claims as presented and discussed with the Examiner during the Examiner Interview to include the patent eligible subject matter discussed with the Examiner. Applicant submits that the present claims overcome the subject matter eligibility rejection for at least the reasons discussed during the Examiner Interview, i.e., the claims are statutory under Step 2A, Prong Two of the current guidance. (Response, p. 8)
To the extent that the above statement of Applicant asserts facts, directly or indirectly, it is incorrect. Clarification is provided below.
As indicated above, Applicant's instant submission follows a PTAB decision. As indicated above, the PTAB decision issued a new ground of rejection under 35 U.S.C. 101 (claims 1-20).
Accordingly, contrary to Applicant's assertions of fact: (1) the outstanding rejection under 35 U.S.C. 101 is the PTAB's rejection, not the Examiner's; (2) claims 1-20 were not rejected under 35 U.S.C. 101 in the Final Office Action dated 01/09/24; and (3) there was no interview such as alleged by Applicant (and accordingly, there was no patent eligible subject matter, and no reasons therefor, that were discussed at such alleged interview).
Step 2A, Prong Two1
For the purposes of the 101 analysis, the subject matter of instant independent claims 21, 31 and 40 does not differ significantly from that of the independent claims rejected under 35 U.S.C. 101 by the PTAB. As such, the PTAB's analysis of the appealed claims under Step 2A, Prong 2, applies to the instant claims, explains why they do not amount to a practical application, and addresses Applicant's remarks. Therefore, the PTAB's Step 2A, Prong 2, analysis of the appealed claims is set forth below2, with annotations in brackets indicating the correspondence between the steps of appealed claim 1 in the PTAB's analysis and the steps of instant claim 21 (or 31 or 40). The absence of an annotation indicates that that portion of the PTAB's analysis applies to claim 21 as a whole.
STEP 2A Prong 2
Taking the claim elements separately, the operation performed by the computer at each step of the process is expressed purely in terms of results, devoid of implementation details. Each step recites little more than a conceptual idea.
Step 1 receives data representing user data for authentication. Such representation is itself an abstraction both as an abstract representation and as the features being conceptual ideas. No technological implementation details for such authentication are recited. Step 1 recites the authentication is for access to a digital wallet. There is no step accessing such a wallet, and no technological implementation details for such a wallet are recited. [This applies to instant claim 21, steps 1 and 2.]
Steps 2, 9, and 10 display a transaction history, a transaction element, and a notification. Display of data is generic and conventional, and no technological implementation details are recited. [This applies to instant claim 21, step 8; instant claim 21, step 9 (last step); and instant claim 40, last step, as indicated respectively below. This also applies to instant claim 21, step 1 in respect of the displaying. This also applies to instant claim 21, step 7 since the displaying of the transaction history (appealed claim 1, step 2) involves the transmitting of the transaction history (claim 21, step 7).]
Step 2 recites the transaction history is associated with the digital wallet of step 1. Step 2 does not recite the manner or degree of such association or how it is represented. [This applies to instant claim 21, step 8. This also applies to instant claim 21, step 3, since the displaying of the transaction history (appealed claim 1, step 2) involves the determining of the transaction history (claim 21, step 3).]
Step 9 recites the display is added during the transaction history display. Such timing is generic and conventional and no technological implementation details are recited. There is nothing technological about the timing relationship nor does it create an inventive structural relationship. Step 9 does not recite the manner or character of the recited interface element that is added. [This applies to instant claim 21, step 9 (last step).]
Step 10 further characterizes the notification as information somehow associated with loan terms. Step 10 does not recite the manner or degree of such association or how it is represented. [This applies to instant claim 40, last step.]
Step 3 recites performing a risk analysis of conversions. No technological implementation details are recited and no risk algorithm is recited. Risk analysis is itself another category of abstract idea. See Bilski above. Step 3 recites three data items relied on in the analysis, but these are simply mathematical parameters. [This applies to instant claim 21, step 4.]
Step 4 recites filtering the transactions. No technological implementation details are recited and no filter algorithm is recited. Filtering is a generic conventional part of data queries. [Although instant claims 21, 31 and 40 do not recite the filtering step in question, this applies to instant claim 21, step 5, which amounts to a filtering step.]
Steps 5-7 recite determining qualifications, budget information, and a transaction. Determining is a synonym for generic black box data analysis. No technological implementation details are recited and no determining algorithms are recited. Steps 5-7 recite data items relied on or produced in the analysis, but these are simply generic analytic parameters. [This applies to instant claim 21, step 5. This also applies to instant claim 21, step 3, which does not have an exact counterpart in appealed claim 1 but recites determining a transaction history. This also applies to instant claim 31, last 2 steps, which are comparable to appealed claim 1, step 6 (determining budget information …).]
Step 8 recites generating data for an interface element to enable the user to initiate a conversion of a transaction to an installment loan. No step recites the actual such conversion. No technological implementation details are recited and no generating algorithm is recited. Step 8 recites the interface element comprises a selectable button for the user interface. Such selectable buttons are generic and conventional, being universal to graphical user interfaces. No technological implementation details for the button structure and operation are recited. [This applies to instant claim 21, step 6. This also applies to instant claim 21, step 7 in respect of the claim language "transmitting … the data to the client device."]
In summary, steps 1, 2, 8, and 10 recite basic conventional data operations such as generating, updating, and storing data. Steps 3-7 and 9 recite generic computer processing expressed in terms of results desired by any and all possible means and so present no more than conceptual advice. All purported inventive aspects reside in how the data is interpreted and the results desired, and not in how the process physically enforces such a data interpretation or in how the processing technologically achieves those results.
Viewed as a whole, Appellant's claim 1 simply recites the concept of managing commercial payments by offering to convert qualified cash transactions to installment loan payments based on risk analysis and maintain a total beneath a cap as performed by a generic computer. This is no more than conceptual advice on the parameters for this concept and the generic computer processes necessary to process those parameters, and do not recite any particular implementation.
Claim 1 does not, for example, purport to improve the functioning of the computer itself. Nor does it affect an improvement in any other technology or technical field. The Specification only spells out different generic equipment9 and parameters that might be applied using this concept and the particular steps such conventional processing would entail based on the concept of managing commercial payments by offering to convert qualified cash transactions to installment loan payments based on risk analysis and maintain a total beneath a cap under different scenarios. It does not describe any particular improvement in the manner a computer functions.
(FN 9: The Specification describes a personal computer, a smart phone, laptop/tablet computer, wristwatch with appropriate computer hardware, eyeglasses with appropriate computer hardware, and/or other types of computing devices capable of transmitting and/or receiving data, such as an iPad. Spec. para. 29.)
Instead, claim 1 at issue amounts to nothing significantly more than an instruction to apply managing commercial payments by offering to convert qualified cash transactions to installment loan payments based on risk analysis and maintain a total beneath a cap using some unspecified, generic computer. Under our precedents, that is not enough to transform an abstract idea into a patent-eligible invention. See Alice, 573 U.S. at 225-26.
None of the limitations reflects an improvement in the functioning of a computer, or an improvement to other technology or technical field, applies or uses a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition, implements a judicial exception with, or uses a judicial exception in conjunction with, a particular machine or manufacture that is integral to the claim, effects a transformation or reduction of a particular article to a different state or thing, or applies or uses the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception.
We conclude that claim 1 is directed to achieving the result of managing commercial payments by advising one to offer to convert qualified cash transactions to installment loan payments based on risk analysis and maintain a total beneath a cap, as distinguished from a technological improvement for achieving or applying that result. This amounts to commercial or legal interactions, which fall within certain methods of organizing human activity that constitute abstract ideas. The claim does not integrate the judicial exception into a practical application.
For the purposes of the 101 analysis, the subject matter of instant independent claims 31 and 40 does not differ significantly from that of instant independent claim 21. Moreover, the PTAB's analysis of appealed claim 1 set forth above addresses the key content of instant claims 31 and 41 that differs from instant claim 21, as per the bracketed annotations above.
The PTAB Decision's Section 101 analysis of the other appealed claims applies also to the other instant claims. Furthermore, the PTAB Decision's Section 101 analysis of the other appealed claims addresses the system components of instant claim 21 (client device and server system). The PTAB Decision's Section 101 analysis of the other appealed claims is set forth below.3
REMAINING CLAIMS
Claim 1 is representative. The other independent method claim 11 is substantially similar at least as regards this analysis. The remaining method claims merely describe process parameters. We conclude that the method claims at issue are directed to a patent-ineligible concept itself, and not to the practical application of that concept.
As to the structural claims, they
are no different from the method claims in substance. The method claims recite the abstract idea implemented on a generic computer; the system claims recite a handful of generic computer components configured to implement the same idea. This Court has long "warn[ed] against" interpreting § 101 "in ways that make patent eligibility 'depend simply on the draftsman's art.'
Alice, 573 U.S. at 226. As a corollary, the claims are not directed to any particular machine.
Finally, the Examiner notes that Applicant's instant arguments in toto are quite similar to a portion of Applicant's arguments that the PTAB Decision quoted and responded to in issuing the rejection under 35 U.S.C. 101. Accordingly, a portion of the PTAB Decision's response to Applicant's (Appellant's) arguments is particularly applicable as addressing Applicant's instant arguments and therefore is set forth below.4
APPELLANT'S ARGUMENTS
As there is no Appeal Brief, we respond to Appellant's most recent eligibility arguments filed February 18, 2022 (Remarks). …
We are not persuaded by Appellant's argument that
the limitations relate to a specific usage (real-time data determinations and displays in user interfaces) in a specific situation (when converting interface data for provision of interface elements and selectable buttons) to provide a particular practical application that improves technology (e.g., to provide real-time analysis and data output based on current data and determinations).
Remarks 11.
The only specificity in the claims is that they are specified using words. No technological implementation details are recited. Real time analysis and output are improvements to information, not technology, "the claims are focused on providing information to traders in a way that helps them process information more quickly, not on improving computers or technology. . . . The "tool for presentation" here . . . is simply a generic computer." Trading Techs. Int'l, Inc. V. IBG LLC, 921 F.3d 1378, 1384-85 (Fed. Cir. 2019)(citations omitted).
We are not persuaded by Appellant's argument that
a problem in the present technology [is] where the presentation of interface data for transaction histories is static and does not provide users with additional options for displaying installment loan offers and conversion options. Thus, the present claims selectively analyze data in real-time in order to provide real-time creation of user interface elements having selectable buttons to initiate processes for these conversions. Using these processes, a user is not required to refresh or load additional user interfaces. Thus, the present application provides solutions to a more convenient, faster, and more streamlined version of user interface data display.
Remarks 11.
Managing commercial payments is an administrative problem, not a technological problem. The claims recite a conceptual administrative solution devoid of technological implementation details. Such conceptual functional claiming is generally insufficient to confer eligibility.
At that level of generality, the claims do no more than describe a desired function or outcome, without providing any limiting detail that confines the claim to a particular solution to an identified problem. The purely functional nature of the claim confirms that it is directed to an abstract idea, not to a concrete embodiment of that idea.
Affinity Labs of Texas, LLC V. Amazon.com Inc., 838 F.3d 1266, 1269 (Fed. Cir. 2016).
Further, to the extent Appellant argues the claims produce a useful result, utility is not at issue and is generally insufficient to confer eligibility. "That the automation can 'result in life altering consequences,' is laudable, but it does not render it any less abstract." Univ. of Fla. Research Found., Inc. V. Gen. Elec. Co., 916 F.3d 1363, 1369 (Fed. Cir. 2019). "[U]tility is not the test for patent eligibility under the Supreme Court's cases." In re Smith, No. 2022-1310, 2022 WL 4112730, at *3 (Fed. Cir. Sept. 9, 2022)(non-precedential)(citing Ass'n for Molecular Pathology V. Myriad Genetics, Inc., 569 U.S. 576, 591 (2013)). "[T]he utility of an abstract idea is insufficient to confer patent eligibility." In re Elbaum, No. 2023-1418, 2023 WL 8794636, at *2 (Fed. Cir. Dec. 20, 2023) (non-precedential)(citing Genetic Techs. Ltd. V. Merial L.L.C., 818 F.3d 1369, 1380 (Fed. Cir. 2016)).
Subject Matter Distinguishable From Prior Art
The cited prior art of record, either alone or in combination, fails to expressly teach or suggest the features found in independent claim 21, 31 or 40.
Among the closest prior art: Cueli teaches converting a previously completed transaction to an installment loan, including displaying a list of transactions and a list of installment loan options; Dennison teaches a bill pay application that determines if a user has sufficient funds to pay a bill, and lends a user money if the user has insufficient funds to pay a bill; Jagalpure teaches determining at a merchant POS if (multiple) transactions are eligible for an installment loan plan; Elyada teaches presenting search results, analyzing the search results, and finding keywords to group the search results, where additional keywords may be added to the UI over time as they are found, while the user interacts with the search results; Sanchez teaches split bill payment; Goodwin teaches an intelligent payment system that determines the best payment instrument to use for a current transaction and presents a rank-ordered list of payment instruments; Walker, Pinto, Ferreira da Silva, and Welch teach, inter alia, details of converting transactions to installment loans; Macedo teaches, inter alia, details of digital wallets in the context of converting transactions to installment loans; Griffin and Barkas teach, inter alia, details of bill payment services and determining that users have insufficient funds to pay bills; at least Berry, Pinto, Barkas, Ferreira da Silva, Griffin, and Walker teach inter alia, a maximum cap on an installment loan amount or on a similar spending amount; Plews teaches, inter alia, real time functionality in apps, including live in-app notifications, regarding updates, progress of a journey and location data, new info/messages received, and responses to a support ticket; and Hart teaches updating a list of transactions and related information displayed in a GUI, in response to generation/receipt of updated/revised information regarding the transactions or in response to user input.
However, in particular, as per the subject matter indicated by the PTAB decision (p. 15) as not taught by the prior art, the cited prior art of record fails to expressly teach or suggest all of the features in independent claim 21, 31 or 40 and more specifically the limitations of: updating the user interface by adding the interface element to the user interface during the displaying the transaction history in the user interface on the client device (claim 21), updating, by the server system at the client device, the user interface by adding the interface element to the user interface during the displaying the transaction history in the user interface on the client device (claim 31), and updating the user interface by the server system on the device, wherein the updating comprises adding the selectable interface option for the conversion offer to the user interface during the displaying the transaction history in the user interface (claim 40), in combination with the other claim limitations of claim 21, 31 or 40, respectively.
Claim Objections
Claim 21 is objected to because of the following informalities:
Claim 21 recites:
… wherein the client-side side operations … :
In the context of the claims and the disclosure as a whole, the underlined word appears to be a clerical error and should be omitted.
Appropriate correction is required.
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 21-40 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 21-40 are directed to a system or method, which are/is one of the statutory categories of invention. (Step 1: YES)
Claims 21, 31 and 40 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 system for determining an eligible transaction and presenting an offering to convert the eligible transaction (to an installment loan) (claim 21); a method for presenting a flip offer to convert a transaction (to an installment loan), and monitoring additional transactions to determine if a total transaction amount exceeds a limit, which would invalidate the flip offer (claim 31); and a method for presenting an offer to convert a transaction (to an installment loan) based on determining that the user has insufficient funds to meet a payment for a transaction (claim 40) (see the Abstract, which clarifies that the conversion/flip offer is paradigmatically for converting a transaction into an installment loan).
For claim 21, the limitations (indicated below in bold) of:
a client device comprising a first non-transitory memory and one or more first hardware processors coupled to the first non-transitory memory and configured to read instructions from the first non-transitory memory to cause the system to perform client-side operations comprising:
displaying an authentication interface in an application on the client device that enables authenticating a user to access a digital wallet; and
a server system comprising a second non-transitory memory and one or more second hardware processors coupled to the second non-transitory memory and configured to read instructions from the second non-transitory memory to cause the system to perform server-side operations comprising:
authenticating the user that enables access to the digital wallet of the user based on an authentication input received via the authentication interface;
determining a transaction history comprising a plurality of transactions associated with the digital wallet;
performing a risk analysis of the plurality of transactions for different conversion offers based on the transaction history and eligibility factors for the plurality of transactions for the different conversion offers;
determining a transaction from the plurality of transactions for a conversion offer based on the risk analysis and a risk threshold associated with the user;
generating data for an interface element transmissible to the client device of the user that enables the interface element to be displayed on a user interface of the application, wherein the interface element enables the user to initiate a conversion of the transaction based on the conversion offer via a selectable button presented in the user interface; and
transmitting the transaction history and the data to the client device;
wherein the client-side side operations further comprise:
displaying the transaction history in the user interface based on the server system authenticating the user, wherein the transaction history is displayed with the plurality of transactions associated with the digital wallet; and
updating the user interface by adding the interface element to the user interface during the displaying the transaction history in the user interface on the client device.
as drafted, constitute a process that, under the broadest reasonable interpretation, covers "certain methods of organizing human activity," specifically, "fundamental economic practices or principles" and/or "commercial or legal interactions," but for recitation of generic computer components. The Examiner notes that "fundamental economic practices" or "fundamental economic principles" describe concepts relating to the economy and commerce, including hedging, insurance, and mitigating risks, and "commercial interactions" or "legal interactions" include agreements in the form of contracts, legal obligations, advertising, marketing or sales activities or behaviors, and business relations. MPEP 2106.04(a)(2)II.A.,B. If a claim limitation, under its broadest reasonable interpretation, covers "fundamental economic practices or principles" and/or "commercial or legal interactions," but for recitation of generic computer components, then it falls within the "certain methods of organizing human activity" grouping of abstract ideas. Accordingly, claim 21 recites an abstract idea. (Step 2A - Prong 1: YES. The claims recite an abstract idea.)
For claim 31, the limitations (indicated below in bold) of:
authenticating, at a server system of a service provider, a user that enables access to an account of the user via a user interface on a client device of the user, wherein the account is associated with a transaction history of transactions processed using a plurality of payment instruments associated with the account;
transmitting, by the server system to the client device, the transaction history;
displaying the transaction history by the client device in the user interface;
performing, at the server system, a risk analysis of a conversion of one or more of the transactions to a flip offer associated with an amount of the one or more of the transactions;
generating, by the server system, data for an interface element, wherein the interface element comprises a selectable interface option that enables the user to accept the flip offer;
transmitting the data by the server system to the client device;
updating, by the server system at the client device, the user interface by adding the interface element to the user interface during the displaying the transaction history in the user interface on the client device;
monitoring, by the server system through the digital wallet, additional transactions performed by the user; and
determining, by the server system, whether the flip offer remains valid based on the monitoring, wherein the flip offer is invalidated if a total amount of at least one of the transactions or the additional transactions meets a budget cap.
as drafted, constitute a process that, under the broadest reasonable interpretation, covers "certain methods of organizing human activity," specifically, "fundamental economic practices or principles" and/or "commercial or legal interactions," but for recitation of generic computer components. The Examiner notes that "fundamental economic practices" or "fundamental economic principles" describe concepts relating to the economy and commerce, including hedging, insurance, and mitigating risks, and "commercial interactions" or "legal interactions" include agreements in the form of contracts, legal obligations, advertising, marketing or sales activities or behaviors, and business relations. MPEP 2106.04(a)(2)II.A.,B. If a claim limitation, under its broadest reasonable interpretation, covers "fundamental economic practices or principles" and/or "commercial or legal interactions," but for recitation of generic computer components, then it falls within the "certain methods of organizing human activity" grouping of abstract ideas. Accordingly, claim 31 recites an abstract idea. (Step 2A - Prong 1: YES. The claims recite an abstract idea.)
For claim 40, the limitations (indicated below in bold) of:
displaying a transaction history in a user interface on a device of the user, wherein the transaction history comprises previous transactions associated with funding instruments linked to a digital wallet;
determining, by a server system based on the digital wallet of the user, that the user has insufficient funds linked to the digital wallet to satisfy one of an upcoming payment for a transaction or a payment for a previous transaction made for one of the previous transactions using a corresponding one of the funding instruments;
performing a risk analysis by the server system for a conversion offer for at least one of the previous transactions into an amount corresponding to the upcoming payment or the payment;
generating the conversion offer for the at least one of the previous transactions by the server system;
generating a selectable interface option by the server system for the user interface on the device that enables the user to convert the one of the subset of the previous transactions to a loan via the user interface;
updating the user interface by the server system on the device, wherein the updating comprises adding the selectable interface option for the conversion offer to the user interface during the displaying the transaction history in the user interface; and
displaying a notification by the server system in the user interface on the device with the transaction history, wherein the notification comprises information associated with a validity of the conversion offer and one or more terms for the conversion offer.
as drafted, constitute a process that, under the broadest reasonable interpretation, covers "certain methods of organizing human activity," specifically, "fundamental economic practices or principles" and/or "commercial or legal interactions," but for recitation of generic computer components. The Examiner notes that "fundamental economic practices" or "fundamental economic principles" describe concepts relating to the economy and commerce, including hedging, insurance, and mitigating risks, and "commercial interactions" or "legal interactions" include agreements in the form of contracts, legal obligations, advertising, marketing or sales activities or behaviors, and business relations. MPEP 2106.04(a)(2)II.A.,B. If a claim limitation, under its broadest reasonable interpretation, covers "fundamental economic practices or principles" and/or "commercial or legal interactions," but for recitation of generic computer components, then it falls within the "certain methods of organizing human activity" grouping of abstract ideas. Accordingly, claim 40 recites an abstract idea. (Step 2A - Prong 1: YES. The claims recite an abstract idea.)
This judicial exception is not integrated into a practical application. Claims 21, 31 and 40 recite the additional elements of a client device comprising a first non-transitory memory and one or more first hardware processors coupled to the first non-transitory memory and configured to read instructions from the first non-transitory memory to cause the system to perform client-side operations; displaying an authentication interface in an application on the client device; digital (wallet); a server system comprising a second non-transitory memory and one or more second hardware processors coupled to the second non-transitory memory and configured to read instructions from the second non-transitory memory to cause the system to perform server-side operations; the authentication interface; an interface element to be displayed on a user interface of the application, wherein the interface element enables; a selectable button presented in the user interface; the user interface; updating the user interface by adding the interface element to the user interface; and the user interface on the client device (the foregoing recited in claim 21); a server system of a service provider; a user interface on a client device of the user; the client device; wherein the interface element comprises a selectable interface option; updating, by the server system at the client device, the user interface by adding the interface element to the user interface; digital (wallet) (the foregoing recited in claim 31); and a user interface on a device of the user; digital (wallet); a server system; generating a selectable interface option by the server system for the user interface on the device; updating the user interface by the server system on the device, wherein the updating comprises adding the selectable interface option for the conversion offer to the user interface (the foregoing recited in claim 40), that implement the abstract idea. These additional elements are not described by the applicant and they are recited at a high level of generality (i.e., one or more generic computer elements performing generic computer functions), such that they amount to no more than mere instructions to apply the exception using generic computer elements. Accordingly, even in combination 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. (Step 2A - prong 2: NO. The additional elements do not integrate the abstract idea into a practical application.)
The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception itself. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements of a client device comprising a first non-transitory memory and one or more first hardware processors coupled to the first non-transitory memory and configured to read instructions from the first non-transitory memory to cause the system to perform client-side operations; displaying an authentication interface in an application on the client device; digital (wallet); a server system comprising a second non-transitory memory and one or more second hardware processors coupled to the second non-transitory memory and configured to read instructions from the second non-transitory memory to cause the system to perform server-side operations; the authentication interface; an interface element to be displayed on a user interface of the application, wherein the interface element enables; a selectable button presented in the user interface; the user interface; updating the user interface by adding the interface element to the user interface; and the user interface on the client device (the foregoing recited in claim 21); a server system of a service provider; a user interface on a client device of the user; the client device; wherein the interface element comprises a selectable interface option; updating, by the server system at the client device, the user interface by adding the interface element to the user interface; digital (wallet) (the foregoing recited in claim 31); and a user interface on a device of the user; digital (wallet); a server system; generating a selectable interface option by the server system for the user interface on the device; updating the user interface by the server system on the device, wherein the updating comprises adding the selectable interface option for the conversion offer to the user interface (the foregoing recited in claim 40), to perform the noted steps amount to no more than mere instructions to apply the exception using generic computer elements. Mere instructions to apply an exception using generic computer elements cannot provide an inventive concept ("significantly more"). Accordingly, even in combination, these additional elements do not provide significantly more. As such, claims 21, 31 and 40 are not patent eligible. (Step 2B: NO. The claims do not provide significantly more.)
Dependent claims 22-30 and 32-39 are similarly rejected because they further define/narrow the abstract idea of independent claims 21, 31 and 40 as discussed above, and/or do not integrate the abstract idea into a practical application or provide an inventive concept such as would render the claims eligible, whether each is considered individually or as an ordered combination.
As for further defining/narrowing the abstract idea:
Dependent claims 22 and 32 merely further describe determining budget information for the user that is associated with the digital wallet, wherein the budget information includes a preestablished amount required to be paid from the user to a payee, wherein the transaction for the conversion offer is determined further based on the budget information.
Dependent claims 23 and 33 merely further describe wherein the preestablished amount is associated with a recurring bill of the user having one or more past payments by the user, and wherein the budget information is determined, at least in part, based on the one or more past payments.
Dependent claims 24 and 34 merely further describe determining that the budget information indicates that the user owes the preestablished payment amount at a future time.
Dependent claims 25 and 35 merely further describe displaying a notification … with the transaction history …, wherein the notification comprises information associated with validity information and terms of the flip offer.
Dependent claims 26 and 36 merely further describe prior to the determining the transaction (claim 26) / the performing the risk analysis (claim 36), filtering the (plurality of) transactions by transaction types to remove certain transactions (from the plurality of transactions) that are associated with credit purchases or a partner service provider.
Dependent claim 27 merely further describes wherein the risk analysis is further based on a payment instrument of the … wallet used for one or more of the plurality of transactions, and determining, … based on the risk analysis and the filtering, that a subset of the filtered plurality of transactions qualifies for the different conversion offers; while similarly dependent claim 37 merely further describes determining, … based on the risk analysis and the filtering, that a subset of the filtered transactions qualifies for the conversion.
Dependent claims 28 and 38 merely further describe scoring (filtered) transactions for conversion (offers), and selecting transactions from the subset of (filtered) transactions based a highest score.
Dependent claim 29 merely further describes wherein the conversion offer comprises an offer for an installment loan.
Dependent claims 30 and 39 merely further describe converting the transaction to an amount available to the user based on the flip offer.
As for additional elements:
Claim 22 recites “the server-side operations” and "digital" (wallet). This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claims 24 and 26 recite “the server-side operations.” This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claim 25 recites “the client-side operations,” "the client device" and "the user interface." This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claim 27 recites "digital" (wallet), “the server-side operations” and "a recommendation engine." This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claim 28 recites “the server-side operations” and "the recommendation engine." This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claim 30 recites “the server-side operations” and "receiving a selection of the selectable button via the interface element in the user interface." This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claim 32 recites "digital" (wallet). This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claim 35 recites "the client device" and "the user interface." This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claims 37 and 38 recite a "recommendation engine." This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claim 39 recites "receiving a selection of the selectable button via the interface element in the user interface." This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claims 23, 29, 33, 34 and 36 do not recite any additional elements, and accordingly, for the reasons provided above with respect to the independent claims, are not patent eligible.
Therefore, dependent claims 22-30 and 32-39 are not patent eligible.
Conclusion
The prior art made of record and not relied upon, as set forth in the accompanying Notice of References Cited (PTO-892), is considered pertinent to applicant's disclosure. Description of the cited prior art is provided above ("Subject Matter Distinguishable From Prior Art").
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/DWP/
Examiner, Art Unit 3626
/JESSICA LEMIEUX/Supervisory Patent Examiner, Art Unit 3626
1 This is the only step of the 101 analysis that Applicant addresses.
2 This PTAB analysis is from the PTAB Decision issued 09/09/2025, pp. 21-25.
3 This PTAB analysis is from the PTAB Decision issued 09/09/2025, p. 27.
4 This PTAB analysis is from the PTAB Decision issued 09/09/2025, pp. 28-30.