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 .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 5/28/2026 has been entered.
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 1-5, 8-15 and 18-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (abstract idea) without significantly more.
Analysis
Claim 1: Ineligible.
The claim recites a series of acts. The claim is directed to a process, which is a statutory category of invention (Step 1: YES).
The claim is analyzed to determine whether it is directed to a judicial exception. The claim recites the steps of receiving user information associated with the user and transaction information associated with a transaction of the user with respect to a product or service offered by a vendor; responsive to a credit extension decision with respect to a financing option based on the user information and the transaction information, generating one or more credit offers to present to the user on the interface screen of a mobile device; and responsive to user selection of a selected credit offer via interaction with the interface screen, generating a composite disclosure comprising a first section including payment details for pay back of a loan associated with the selected credit offer and a second section including legal or required disclosure materials associated with the selected credit offer. These limitations, as drafted, are processes that, under its broadest reasonable interpretation, covers performance of the limitations via manual human activity, but for the recitation of generic computer components such as processor and user interface. That is, other than reciting “interface,” nothing in the claim precludes the limitations from practically being performed by organizing human activity. These limitations fall under the fundamental economic practices of the “certain methods of organizing human activity” and “mental processes” groups (Step 2A1-Yes).
Next, the claim is analyzed to determine if it is integrated into a practical application. The claim recites additional limitation of using interface (processor). The processor in the steps is recited at a high level of generality, i.e., as a generic processor performing a generic computer function of processing data. This generic processor limitation is no more than mere instructions to apply the exception using generic computer component. The user interface screen of a mobile device (display) is recited at a high level of generality with the only required function of displaying information, which is a routine function of displays. The claim further recites that the composite disclosure is displayed on a single page on the interface screen to include a plurality of expandable sections that are compressed by default to appear on the single page having a first length, and expanded responsive to selection of a corresponding expansion selector to appear on the single page having a second length longer than the first length, wherein one of the expandable sections comprises an automatic payment section that, when expanded, provides a selectable interface for the user to enter account details for an account from which automatic payment is authorized and select an alternative payment method. This limitation is simply a switch/toggle/selector that allows a user to select “autopay,” and upon selection, provides the user with fields (a second length longer than the first length) to input the autopayment information such as the account information of the user.
The claim further recites wherein a disclosure section of the second portion has a fixed size relative to a screen size of the mobile device, and includes a slide controller operable to slide through portions of the disclosure section that are too large to fit in the fixed size. This limitation is simply display of information on a fixed screen size the has a scroll slide in operable to slide through portions of the information that are too large to fit in the fixed size.
These limitations are considered insignificant extra-solution activities. Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. The claim is directed to the abstract idea (Step 2A2-No).
Next, the claim is analyzed to determine if there are additional claim limitations that individually, or as an ordered combination, ensure that the claim amounts to significantly more than the abstract ideas (whether claim provides inventive concept). As discussed with respect to Step 2A2 above, the additional element in the claim amounts to no more than mere instructions to apply the exception using a generic computer component. The same analysis applies here in Step 2B, i.e., mere instructions to apply an exception using a generic computer component cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. Because the composite disclosure includes a plurality of expandable sections that are compressed by default, and expanded responsive to selection of a corresponding expansion selector, wherein one of the expandable sections comprises an automatic payment section that, when expanded, provides a selectable interface for the user to enter account details for an account from which automatic payment is authorized, was considered to be insignificant extra-solution activity in Step 2A2, it is re-evaluated in Step 2B to determine if it is more than what is well-understood, routine and conventional in the field. The disclosure does not provide any indication that this step is anything other than a conventional step, and Spicola, Sr. et al (USPAP 2013/0322699) at 0019, 0186 and fig. 9; Brown et al. (USPN 10,692,066) at col. 11, lines 17-32, fig. 3C; Walters et al. (USPAP 2021/0366037) at fig. 6, RN {601, 603}; Nguyen et al. (USPAP 2004/0225606) at 0066-0067, figs. 13A-13C, RN {1302}; and Kapczynski et al. (USPN 9443268) at fig. 6A, RN {631}, col. 14, lines 60 through col. 15, lines 3; all indicate that this step is well-understood, routine and conventional in the field (as they are here). Accordingly, a conclusion that the step is well-understood, routine and conventional activity is supported under Berkheimer option 3.
Furthermore, because wherein a disclosure section of the second portion has a fixed size relative to a screen size of the mobile device, and includes a slide controller operable to slide through portions of the disclosure section that are too large to fit in the fixed size, was also considered to be insignificant extra-solution activity in Step 2A2, it is also re-evaluated in Step 2B to determine if it is more than what is well-understood, routine and conventional in the field. The disclosure does not provide any indication that this step is anything other than a conventional step, and Perry, (USPN 5,553,225) at abstract, and fig. 1; Yalovsky. (USPAP 2011/0252302) at 0002, fig. 3; and Dube et al. (USPAP 2015/0026825) at fig. 14, RN {1425}, 0200; all indicate that this step is well-understood, routine and conventional in the field (as they are here). Accordingly, a conclusion that the step is well-understood, routine and conventional activity is supported under Berkheimer option 3.
Viewing the limitations as an ordered combination does not add anything further than looking at the limitations individually. When viewed either individually, or as an ordered combination, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea itself. Therefore, the claim does not amount to significantly more than the recited abstract idea (Step 2B: NO). The claim is not patent eligible.
Claim 11 recites an apparatus claim equivalent of claim 1. This claim is similarly rejected under the same rationale as claim 1, supra.
Claims 2 and 12 further recite wherein the legal or required disclosure materials include a truth in lending disclosure. This further narrows the abstract idea, but does not amount to significantly more than the abstract idea since displaying further information on a user interface and the use of the generic processor do not integrate the abstract idea into a practical application. The claim is similarly rejected under the same rationale as claim 1, supra.
Claims 3-4 and 13-14 further recite wherein the truth in lending disclosure is accessible via selection of a link provided in the composite disclosure; wherein the legal or required disclosure materials further include a second link to a loan agreement defining terms of the selected credit offer, and a third link to a credit score disclosure. These further narrow the abstract idea, and the use of links to access further information does not integrate the abstract idea into a practical application. The claims are similarly rejected under the same rationale as claim 1, supra.
Claims 5 and 15 further recite wherein the composite disclosure comprises an acknowledgement selector to acknowledge review and acceptance of the truth in lending disclosure, and wherein completion of the transaction is disabled until the acknowledgement selector has been selected. These further narrow the abstract idea, and the use of “acknowledgement checkbox” to enable a function does not integrate the abstract idea into a practical application. The claims are similarly rejected under the same rationale as claim 1, supra.
Claims 8-10 and 18-20 further recite wherein one of the expandable sections comprises an expansion to a payment descriptor block to show individual payment amount breakdowns; wherein one of the expandable sections comprises an early payment section that, when expanded, provides an interface for the user to enter proposed early payment amounts and see resulting modifications to loan repayment terms based on the early payment amounts; wherein one of the expandable sections comprises a down payment section that, when expanded, provides an interface for the user to enter information associated with making a down payment with respect to the transaction to reduce a borrowed amount of the loan. These further narrow the abstract idea, and the use of expandable sections to provide more information or interactions with the user does not integrate the abstract idea into a practical application. The claims are similarly rejected under the same rationale as claim 1, supra.
Response to Arguments
Applicant's arguments filed 5/28/2026 have been fully considered but they are not persuasive.
35 USC 101 rejection:
As an initial matter, a Declaration or Affidavit is a consideration for novelty, non-obviousness or both. A declaration/affidavit does not have any impact of subject matter eligibility under 35 U.S.C 101 because unlike 35 U.S.C. 102 or 103 which are evidence based, 35 U.S.C. 101 is a matter of law and such, no tangible evidence or examples are required. Examiner notes that the courts consider the determination of whether a claim is eligible (which involves identifying whether an exception such as an abstract idea is being claimed) to be a question of law. Accordingly, courts do not rely on evidence that a claimed concept is a judicial exception, and in most cases resolve the ultimate legal conclusion on eligibility without making any factual findings. Secondly, as stated above, the newly amended feature (scroll slider) cannot be considered as a technical improvement or improvement to a technical field.
Applicant’s arguments with respect to the scroll slider not being routine and conventional (citing element 562 in Fig. 5 on the disclosure section 560) either individually or in combination with the expandable and fixed size sections that combined different ways to access information into a single interface, is not persuasive.
See the additional following references:
Perry, (USPN 5,553,225) at abstract, and fig. 1;
Yalovsky. (USPAP 2011/0252302) at 0002, fig. 3; and
Dube et al. (USPAP 2015/0026825) at fig. 14, RN {1425}, 0200.
Viewing the limitations as an ordered combination does not add anything further than looking at the limitations individually. When viewed either individually, or as an ordered combination, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea itself. Therefore, the claim does not amount to significantly more than the recited abstract idea (Step 2B: NO). The claim is not patent eligible.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Epting et al (USPAP 2007/0061255) teaches a POS credit system (0017, 0039, figs).
Other references are as cited in PTO-892.
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/OLABODE AKINTOLA/Primary Examiner, Art Unit 3691
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