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 amendment filed 03/10/2026.
Claims 1, 10, and 16 have been amended. Claims 1, 3-4, 6, 8, 10, 12-13, 15-16, 19, and 21 are pending and have been examined on the merits (claims 1, 10, and 16 being independent).
The amendment filed 03/10/2026 to the claims has been entered.
Response to Arguments
Applicant’s arguments and amendments filed 03/10/2026 have been fully considered.
Applicants assert that the pending claims fully comply with the requirement of 35 U.S.C. 101. Examiner respectfully disagrees. Applicant’s argument and amendments have been considered and are not persuasive. The rejections under 35 U.S.C. 101 have been maintained and clarified in view of the USPTO MPEP 2106.
Applicant’s arguments (see Applicant’s remarks, pages 12-17):
(1) Applicant’s arguments that “Applicant respectfully disagrees. The Office Action has improperly characterized the invention, as the risk relationship resource allocation data in the claims is merely a "field of use" or a type of data being processed, and not a "fundamental economic principle or practice including insurance or mitigating risk."” (see page 15), are not found persuasive.
In response (1): Under Step 2 A, Prong 1 of the 2019 Revised § 101 Guidance, it is determined whether the claims are directed to a judicial exception such as a law of nature, a natural phenomenon, or an abstract idea (See Alice, 134 S. Ct. at 2355) by identifying the specific limitation(s) in the claim that recites abstract idea(s) and then determine whether the identified limitation(s) falls within at least one of the groupings of abstract ideas enumerated in the MPEP 2106.04. The cited limitations as drafted are systems and methods that, under their broadest reasonable interpretation, covers performance of a method of organizing human activity, but for the recitation of the generic computer components. Further, none of the limitations recite technological implementation details for any of the steps but, instead, only recite broad functional language being performed by the generic use of a back-end application computer server (e.g. a computer processor). Managing a risk relationship resource allocation in a way that provides fast results (e.g., processing a requested resource allocation such as a short term disability insurance claim) is a fundamental economic practice long prevalent in commerce systems. If a claim limitation, under its broadest reasonable interpretation, covers a fundamental economic principle or practice but for the general “applying it” to a technological environment, then it falls within the organizing human activity grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
(2) Applicant’s arguments that “Applicant notes, per the December 5, 2025 "Advance notice of change to the MPEP in light of Ex Parte Desjardins" Memo ("December 2025 Memo"), "The full scope of the claim under the BRI should be considered to determine if the claim reflects an improvement in technology or a technical field (e.g., the improvement described int eh specification). In making this determination, it is critical that examiners look at the claim "as a whole," in other words, the claim should be evaluated "as an ordered combination, without ignoring the requirements of the individual steps."” (see page 16), are not found persuasive.
In response (2): In the instant application, the instant claims do not integrate the exception into a practical application because the limits of “via a back-end application computer server”, “a computer processor”, “via a distributed communication network”, “a graphical interactive user interface”, “an email server coupled to the back-end application computer server”, and “a channel of communication with each of the first remote device and the second remote device” (i.e. amount to simply applying the abstract idea to a computer network and/or a computer component (e.g. “apply it”)) do not apply, rely on, or use the judicial exception in a manner that that imposes a meaningful limitation on the judicial exception (i.e. generally linking the use of the judicial exception to a particular technological environment or field of use - see MPEP 2106.05(h) or apply it with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea - see MPEP 2106.05(f)).
The additional limitations (e.g., a risk relationship resource allocation tool, a back-end application computer server, an encrypted database management system, a resource allocation data store, a machine learning trained data science model, a communication port coupled to the back-end application computer server, remote device, a graphical interactive user interface display, distributed communication network, a computer memory, a computer processor, an email server coupled to the back-end application computer server, and a channel of communication with each of the first remote device and the second remote device) as an ordered combination, the invention as a whole does not amount to significantly more than abstract idea (such as calculating and generating data, updating, and sending and displaying data). That is, the additional elements amount to no more than mere instructions to apply the exactly using generic computer component and also it is a business solution to a business problem, not a technical solution to the problem. The claims here, in contrast, are not directed to an improvement in the way computers operate, but on certain independently abstract ideas that use computers as tools, and the recitation in each of the independent claims provides a more efficient way to manage requested insurance claims. Therefore, Applicant’s arguments are not persuasive.
(3) Applicant’s arguments that “The storyboard displays may be associated with a customized video that is automatically created for and/or communicated to the particular claimant on-the-fly and in substantially real time (e.g., within hours of the claim being submitted), thus improving the efficiency of the system and are "significantly more" than simply organizing data.” (see page 16), are not found persuasive.
In response (3): In the instant application, the claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements when considered both individually and as an ordered combination do not amount to significantly more that the abstract idea(s). As discussed above with respect to integration of the abstract idea into a practical application, the additional element of using a computer processor/a server to perform the abstract idea(s) amounts to no more than mere instructions to apply the exception using a generic computer component. Mere instruction to apply an exception using a computer cannot provide an inventive concept. These generic computer components are claimed at a high level of generality to perform their basic functions which amount to no more than generally linking the use of the judicial exception to the particular technological environment. For example, generating a customized video and a customized message merely implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea. Therefore, Applicant’s arguments are not persuasive.
(4) Applicant’s arguments that “For all of these reasons, reconsideration of the 35 USC§ 101 rejection of claim 1 is respectfully requested. The remaining claims depend from Claim 1, or recite similar limitations, and should therefore be allowable for at least the same reasons.” (see page 17), are not found persuasive.
In response (4): In conclusion, thus, independent claims 1, 10, and 16 do no more than require generic, purely conventional computer elements, as an ordered combination, performing generic computer functions, rather than improve computer capabilities. Accordingly, Examiner sustains the eligibility rejection of independent claims 1, 10, and 16. Claims 3-4, 6, 8, 12-13, 15, 19, and 21 depend from claims 1, 10, and 16, and Applicant does not present any additional substantive arguments with respect to these claims. Therefore, Examiner also sustains the rejection of claims 3-4, 6, 8, 12-13, 15, 19, and 21 under 35 U.S.C. § 101, for the same reasons discussed with respect to independent claims 1, 10, and 16.
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, 3-4, 6, 8, 10, 12-13, 15-16, 19, and 21 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter without significantly more.
When considering subject matter eligibility under 35 U.S.C. 101, (1) it must be determined whether the claim is directed to one of the four statutory categories of invention, i.e., process, machine, manufacture, or composition of matter. If the claim does fall within one of the statutory categories, (2a) it must then be determined whether the claim is directed to a judicial exception (i.e., law of nature, natural phenomenon, and abstract idea), and if so (2b), it must additionally be determined whether the claim is a patent-eligible application of the exception. If an abstract idea is present in the claim, any element or combination of elements in the claim must be sufficient to ensure that the claim amounts to significantly more than the abstract idea itself. Examples of abstract ideas include fundamental economic practices; certain methods of organizing human activities; an idea itself; and mathematical relationships/formulas. Alice Corporation Pty. Ltd. v. CLS Bank International, et al., 573 U.S. (2014).
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. In the instant case, the claim(s) as a whole, considering all claim elements both individually and in combination, do not amount to significantly more than an abstract idea.
Step (1): In the instant case, the claims are directed towards a method for managing a risk relationship resource allocation in a way that provides fast results (e.g., processing a requested resource allocation such as a short term disability insurance claim) which contains the steps of receiving, retrieving, executing, generating, arranging, storing, identifying, determining, combining, and transmitting. The claim recites a series of steps and, therefore, is a process. The claims do fall within at least one of the four categories of patent eligible subject matter because claim 1 is direct to a system, claim 10 is direct to a computerized method, and claim 16 is direct to a non-transitory computer readable medium, i.e. machines programmed to carrying out process steps, Step 1-yes.
Step (2A) Prong 1: A method for managing a risk relationship resource allocation in a way that provides fast results (e.g., processing a requested resource allocation such as a short term disability insurance claim) is akin to the abstract idea subject matter grouping of: Certain Methods of Organizing Human Activity as fundamental economic principles or practices including insurance or mitigating risk. As such, the claims include an abstract idea.
The specific limitations of the invention are (a) identified to encompass the abstract idea include: {… receive an indication of a selected requested resource allocation between the enterprise and an entity, retrieve, … the electronic record associated with the selected requested resource allocation, including the set of resource allocation values associated with risk attributes, execute …. automatically determine a workflow for the selected requested resource allocation, wherein the workflow is a process to evaluate an insurance claim, combine the workflow with guideline values to generate a final recommendation, generate …. supporting the determined workflow, the generated user interface display including an initial summary, including a run rules icon, in response to selection of the run rules icon, execute a series of rules, generate a summary of rule results on a category-by-category basis, automatically generate and transmit an approval message to the entity in a case the determined workflow is associated with an automatic claim approval, generate … based on received additional information including an explanation of an approved requested resource allocation and next steps, … including updates to the initial summary, wherein the updated summary …. includes graphical markings indicating one or more changes on the updates summary as compared to the initial summary, arrange to process the requested resource allocation in accordance with the selected workflow, store the processed requested resource allocation in response to a determination the requested resource allocation is approved, perform …. with the processed requested resource allocation via a feedback loop based on the approval, such that …. is continuously adjusted, generate and assign a process approval task to an automated process in response to storage of the processed and approved requested resource allocation, execute the automated process, wherein the assignment activates execution of the automated process, identifying a highest duration likelihood score of the generated plurality of duration likelihood scores, determining the identified highest duration likelihood score is one of above or below a threshold value; in a case the identified highest duration likelihood score is determined to be above the threshold value, selecting a shortest value in the range of values for the identified highest duration likelihood score, automatically generate a customized …. and a customized message explaining the approval of a requested resource allocation, … automatically transmit the initial summary, updates to the initial summary, and approval of the requested resource allocation to …. and the customized message including the additional information and the generated customized ……. in substantially real time.}
As stated above, this abstract idea falls into the (b) subject matter grouping of: Certain Methods of Organizing Human Activity as fundamental economic principles or practices including insurance or mitigating risk as managing a risk relationship resource allocation in a way that provides fast results (e.g., processing a requested resource allocation such as a short term disability insurance claim).
Step (2A) Prong 2: The instant claims do not integrate the exception into a practical application because the limits of “via a back-end application computer server”, “a computer processor”, “via a distributed communication network”, “a graphical interactive user interface”, “an email server coupled to the back-end application computer server”, “a channel of communication with each of the first remote device and the second remote device”, and “video” (i.e. amount to simply applying the abstract idea to a computer network and/or a computer component (e.g. “apply it”)) do not apply, rely on, or use the judicial exception in a manner that that imposes a meaningful limitation on the judicial exception (i.e. generally linking the use of the judicial exception to a particular technological environment or field of use - see MPEP 2106.05(h) or apply it with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea - see MPEP 2106.05(f)).
The instant recited claims including additional elements (e.g., a risk relationship resource allocation tool, a back-end application computer server, an encrypted database management system, a resource allocation data store, a machine learning trained data science model, a communication port coupled to the back-end application computer server, remote device, a graphical interactive user interface display, distributed communication network, a computer memory, a computer processor, an email server coupled to the back-end application computer server, and a channel of communication with each of the first remote device and the second remote device, video) do not improve the functioning of the computer or improve another technology or technical field nor do they recite meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment. The limitations merely use a generic computing technology (Specification paragraph [0074]: processor, a storage device, a resource allocation tool or application, a resource allocation data store, a machine learning trained data science model, a graphical interactive user interface display, a distributed communication network, etc.) as apply it with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea - see MPEP 2106.05(f)).
There is a fundamental difference between computer functionality improvements, on the one hand, and uses of existing computers as tools to perform a particular task, on the other. There is nothing, for example, in the pending claims to suggest that any of the claimed “a back-end application computer server” and “a resource allocation data store”, all of which are suitably programmed, are somehow made more efficient or that the manner in which these elements carry out their basic functions is otherwise improved in any way. Any advantages from the claimed invention do not concern an improvement in computer capabilities but instead relate to an alleged improvement in the fundamental economic practice of providing a risk relationship resource allocation tool in a way that provides fast results (e.g., processing a requested resource allocation such as a short term disability insurance claim), for which a computer is used as a tool in its ordinary capacity. Therefore, the claims are directed to an abstract idea.
Step (2B): When considered individually and in combination, the claims 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 (Claims: e.g., a risk relationship resource allocation tool, a back-end application computer server, an encrypted database management system, a resource allocation data store, a machine learning trained data science model, a communication port coupled to the back-end application computer server, remote device, a graphical interactive user interface display, distributed communication network, a computer memory, a computer processor, an email server coupled to the back-end application computer server, and a channel of communication with each of the first remote device and the second remote device) amount to no more than generally linking the use of the judicial exception to a particular technological environment or merely using generic components as tool to perform an abstract idea.
The computer is merely a platform on which the abstract idea is implemented. Simply executing an abstract concept on a computer does not render a computer “specialized,” nor does it transform a patent-ineligible claim into a patent-eligible one. See Bancorp Servs., LLC v. Sun Life Assurance Co. of Can., 687 F.3d 1266, 1280 (Fed. Cir. 2012). There are no improvements to another technology or technical field, no improvements to the functioning of the computer itself, transformation or reduction of a particular article to a different state or thing or any other meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment as a result of performing the claimed method. Also, the addition of merely novel or non-routine components to the claimed idea does not necessarily turn an abstraction into something concrete (See Ultramercial, Inc. v. Hulu, LLC, _ F.3d_, 2014 WL 5904902, (Fed. Cir. Nov. 14, 2014). Hence, the claims do not recite significantly more than an abstract idea. In conclusion, merely “linking/applying” the exception using generic computer components does not constitute ‘significantly more’ than the abstract idea. (MPEP 2106.05 (f)(h)). Therefore, the claims are not patent eligible under 35 USC 101.
Dependent claims 3-4, 6, 8, 12-13, 15, 19, and 21 when analyzed as a whole and in an ordered combination are held to be patent ineligible under 35 U.S.C. 101 because the additional recited limitation(s) fail(s) to establish that the claim(s) is/are not directed to an abstract idea, as detailed below. The additional recited limitations in the dependent claims only refine the abstract idea.
For instance, in claims 3 and 12, the step of “… executes a series of rules including rules associated with at least one of: (i) a medical rules category, (ii) an employee rules category, (iii) an employer rules category, and (iv) an STD plan rules category.” (i.e., executing rules), in claims 4 and 13, the step of “… wherein a recommended action is provided to an ability analyst when an STD claim fails one of the rules” (i.e., providing a recommended action), in claims 6 and 15, the step of “… wherein the ability analyst can manually override a rule result” (i.e., overriding a rule), in claims 8 and 19, the step of “… a predictive model created using data fields and text flags identified in electronic records of the resource allocation data store, claim data, and bill data …” (i.e., using claim data), in claim 9, the step of “… automatically create a customized video that is communicated to a particular employee on-the-fly and in substantially real time using rules and logic to tailor an explanation so that it is appropriate for an employee's situation” (i.e., creating a video), and in claim 21, the step of “… wherein the process approval task includes all steps that are part of the approval and the automated process completes all of the steps…” (i.e., processing approval steps) are all processes that, under its broadest reasonable interpretation, covers performance of a fundamental economic practice but for the recitation of a generic computer component. Providing a risk relationship resource allocation that provides fast results (e.g., processing a requested resource allocation such as a short term disability insurance claim) is a most fundamental commercial process.
This is an abstract concept with nothing more and is also considered mere instructions to apply an exception akin to a commonplace business method or mathematical algorithm being applied on a general purpose computer, Alice Corp. Pty. Ltd.; Gottschalk and Versata Dev. Group, Inc.; see MPEP 2106.05(f)(2).
In dependent claims 3-4, 6, 8, 12-13, 15, 19, and 21, the steps claimed are rejected under the same analysis and rationale as the independent claims 1, 10, and 16 above. Merely claiming the same process using a machine learning model to perform a risk relationship resource allocation that provides fast results (e.g., processing a short term disability insurance claim) does not change the abstract idea without an inventive concept or significantly more. Clearly, the additional recited limitations in the dependent claims only refine the abstract idea further. Further refinement of an abstract idea does not convert an abstract idea into something concrete.
Therefore, claims 1, 3-4, 6, 8, 10, 12-13, 15-16, 19, and 21 are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter.
Conclusion
The prior art made of record but not relied upon herein but pertinent to Applicant’s disclosure is listed in the enclosed PTO-892.
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 extension fee 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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/YONGSIK PARK/Examiner, Art Unit 3694
March 27, 2026
/BENNETT M SIGMOND/Supervisory Patent Examiner, Art Unit 3694
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