DETAILED CORRESPONDENCE
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.
Status of the Application
Applicant's submission filed on January 22, 2026 has been entered.
Response to Amendment
Claims 1, 7, and 13 have been amended. Claims 1-20 remain pending in the application and are provided to be examined upon their merits.
Claim Rejections - 35 USC § 112
The following is a quotation of the first paragraph of 35 U.S.C. 112(a):
(a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention.
The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112:
The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention.
Claims 1-20 are rejected under 35 U.S.C. 112(a) as failing to comply with the written description requirement. The claim(s) contain subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, at the time the application was filed, had possession of the claimed invention.
• Claim 1 recites the limitation "not human readable" in paragraph 5. The claim lacks written description support because there is no written description of this limitation in the disclosure. See MPEP 2163.03(I). In fact, there is no teaching of the following limitations anywhere in the disclosure: "not human readable". The Specification states "rather than human readable" at Specification par. [0059]. "[R]ather than" is a phrase used to indicate preference or choice, showing that "read[ing]" by one thing [e.g., "machine"] is chosen or preferred over another [e.g., "human"]. "[R]ather than" emphasizes a choice or contrast between two options, highlighting what is preferred or more suitable in a given context, but does not preclude or connote the impossibility of "read[ing]" by a "human", as under the proper broadest reasonable interpretation of "not human readable", as herein rejected as being claimed without written description support.
Claims 2-6 are also rejected on the same grounds due to their dependency on the above-rejected Claim 1.
• Claim 7 recites the limitation "not human readable" in paragraph 11. The claim lacks written description support because there is no written description of this limitation in the disclosure. See MPEP 2163.03(I). In fact, there is no teaching of the following limitations anywhere in the disclosure: "not human readable". The Specification states "rather than human readable" at Specification par. [0059]. "[R]ather than" is a phrase used to indicate preference or choice, showing that "read[ing]" by one thing [e.g., "machine"] is chosen or preferred over another [e.g., "human"]. "[R]ather than" emphasizes a choice or contrast between two options, highlighting what is preferred or more suitable in a given context, but does not preclude or connote the impossibility of "read[ing]" by a "human", as under the proper broadest reasonable interpretation of "not human readable", as herein rejected as being claimed without written description support.
Claims 8-12 are also rejected on the same grounds due to their dependency on the above-rejected Claim 7.
• Claim 13 recites the limitation "not human readable" in paragraph 5. The claim lacks written description support because there is no written description of this limitation in the disclosure. See MPEP 2163.03(I). In fact, there is no teaching of the following limitations anywhere in the disclosure: "not human readable". The Specification states "rather than human readable" at Specification par. [0059]. "[R]ather than" is a phrase used to indicate preference or choice, showing that "read[ing]" by one thing [e.g., "machine"] is chosen or preferred over another [e.g., "human"]. "[R]ather than" emphasizes a choice or contrast between two options, highlighting what is preferred or more suitable in a given context, but does not preclude or connote the impossibility of "read[ing]" by a "human", as under the proper broadest reasonable interpretation of "not human readable", as herein rejected as being claimed without written description support.
Claims 14-20 are also rejected on the same grounds due to their dependency on the above-rejected Claim 13.
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 a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
Claims 1-20 are directed to the abstract idea of: Claim 1 -: 1, a method of standardizing healthcare payment information to analyze the validity of a healthcare provider's unpaid bill, comprising: acquiring claims data from one or more insurance providers, wherein the claims data is in a non-standardized format comprising one or more of a text; converting, by a claims conversion, the non-standardized claims data into a standardized format, wherein converting comprises that, for each respective insurance provider, to extract information located at specific locations within the non-standardized format; storing- the standardized claims data as standardized EOB data, the standardized EOB data including provider name, dates of service, patient identity, patient responsibility, total charge, and discount amount; acquiring a patient's identity; receiving a healthcare provider's unpaid bill and converting the healthcare provider's unpaid bill into a readable dataset by applying extracting text values for predetermined query terms by identifying text located immediately following, immediately below, or within a predetermined distance from each query term, the predetermined distance being measured as a percentage of an image size; initiating a bill validation, wherein the bill validation executes the following steps: identifying a healthcare provider's identity; identifying from the readable dataset of the healthcare provider's unpaid bill one or more of the following: an amount due and a service date; accessing and extracting patient-specific claims data, wherein the patient-specific claims data corresponds to the patient's identity; executing a data comparison in real time to determine if any of the standardized claims data corresponds to the healthcare provider's identity, the amount due, and the service date identified on the healthcare provider's unpaid bill; and responsive to one of the patient-specific claims data corresponding to the healthcare provider's identity, the amount due, and the service date identified on the healthcare provider's unpaid bill, notifying the patient over a communication that the healthcare provider's unpaid bill has been validated, thereby providing the patient with immediate access to up-to-date payment information. (fundamental economic principles or practices, commercial or legal interactions, managing personal behavior or relationships or interactions between people, concepts performed in the human mind, (including an observation, evaluation, judgment, opinion). ) Claim 2 -: 2, the method of claim 1, wherein the patient's identity is identified by one or more of a name, a user login, a social security number, a date of birth, or a zip code. Claim 3 -: 3, the method of claim 1, further including receiving the healthcare provider's unpaid bill as a first image taken and converting the first image to a dataset of alphanumeric characters, wherein the dataset includes the healthcare provider's identity, the amount due, and the service date. Claim 4 -: 4, the method of claim 1, further comprising displaying on a patient mobile a comparison of the amount of the healthcare provider's unpaid bill that the patient is required to pay as calculated by the healthcare provider and the amount of the healthcare provider's unpaid bill that the patient is required to pay as reported by patient-specific claims data. Claim 5 -: 5, the method of claim 4, further comprising displaying a selectable to pick whether to pay the amount of the healthcare provider's unpaid bill as calculated by the healthcare provider or the amount of the healthcare provider's unpaid bill that the patient is required to pay as reported by patient-specific claims data. Claim 6 -: 6, the method of claim 1, further comprising: responsive to none of the patient-specific claims data corresponding to the healthcare provider's identity, the amount due, and the service date identified on the healthcare provider's unpaid bill, generating a message containing an explanation that the healthcare provider's unpaid bill has not been validated by the patient-specific claims data; and transmitting the message to the one user over the communication, so that the patient has immediate access to up-to-date payment information. (fundamental economic principles or practices, commercial or legal interactions, managing personal behavior or relationships or interactions between people, concepts performed in the human mind, (including an observation, evaluation, judgment, opinion). ) Claim 7 -: 7, a method of standardizing healthcare payment information to analyze the validity of a healthcare provider's unpaid bill, comprising: acquiring a patient's... [id. at 1], acquiring a first image of the healthcare provider's unpaid bill for a patient; converting the first image to a dataset of alphanumeric characters by applying extracting text values for predetermined query terms by identifying text located immediately following, immediately below, or within a predetermined distance from each query term, the predetermined distance being measured as a percentage of an image size, wherein the dataset includes a healthcare provider's identity, an amount due, and a service date; initiating a bill... [id. at 1], acquiring claims data originating from one or more insurance providers, wherein the claims data is in a non-standardized format comprising one or more of a text; converting, by a claims conversion, the non-standardized claims data from one or more insurance providers into a standardized format, wherein converting... [id. at 1], storing- the standardized claims data acquired claims data as standardized EOB data, the standardized EOB data including provider name, dates of service, patient identity, patient responsibility, total charge, and discount amount; accessing, retrieving the standardized claims data that corresponds to the patient's identity; matching in real time the dataset of the healthcare provider's unpaid bill to a claim in the retrieved standardized claims data that corresponds to the patient's identity; determining if the amount due listed on the healthcare provider's unpaid bill matches an amount that the patient must pay out-of-pocket as provided in the matched claim; responsive to determining that the amount due listed on the healthcare provider's unpaid bill matches the amount that the patient must pay out-of-pocket as provided in the matched claim, notifying the patient via a patient that the healthcare provider's unpaid bill has been validated; and responsive to a user initiation received via the patient, effecting a payment transaction to the healthcare provider based on the validated amount, wherein the payment transaction is executed over a communication. (fundamental economic principles or practices, commercial or legal interactions, managing personal behavior or relationships or interactions between people, concepts performed in the human mind, (including an observation, evaluation, judgment, opinion). ) Claim 8 -: 8, the method of claim 7, wherein the bill validation further includes: performing a scoring when validating the amount due listed on the healthcare provider's unpaid bill, wherein the scoring calculates whether any of the standardized claims data in the contains enough similarities to the healthcare provider's identity, the amount due, and the service date to exceed a predetermined scoring threshold to validate the amount due listed on the healthcare provider's unpaid bill; wherein the step of notifying that the healthcare provider's bill has been validated occurs when one of the standardized claims data exceeds the predetermined scoring threshold. Claim 9 -: 9, the method of claim 7, wherein the patient's identity is identified by one or more of a name, user login information, a social security number, a date of birth, or a zip code. Claim 10 -: 10, the method of claim 7, further comprising displaying on a patient mobile a comparison of the amount of the healthcare provider's unpaid bill that the patient is required to pay as calculated by the healthcare provider and the amount of the healthcare provider's unpaid bill that the patient is required to pay as reported by the standardized claims data. Claim 11 -: 11, the method of claim 10, further comprising displaying a selectable to pick whether to pay the amount of the healthcare provider's unpaid bill as calculated by the healthcare provider or the amount of the healthcare provider's unpaid bill that the patient is required to pay as reported by standardized claims data. Claim 12 -: 12, the method of claim 7, further comprising: responsive to none of the standardized claims data matching the dataset, generating a message containing an explanation that the healthcare provider's unpaid bill has not been validated by the standardized claims data; and transmitting the message to the patient, so that the patient has immediate access to up-to-date payment information. (mathematical relationships, mathematical calculations. fundamental economic principles or practices, commercial or legal interactions, managing personal behavior or relationships or interactions between people, concepts performed in the human mind, (including an observation, evaluation, judgment, opinion). ) Claim 13 -: 13, a method of standardizing healthcare records to analyze the validity of a healthcare provider's unpaid bill, comprising: acquiring claims data in a non-standardized format comprising one or more of a text originating from one or more insurance providers; converting, by a... [id. at 1], wherein converting comprises that, for each respective insurance provider, to extract information located at specific locations within the non-standardized format, and wherein the standardized format comprises standardized EOB data, the standardized EOB data including provider name, dates of service, patient identity, patient responsibility, total charge, and discount amount; identifying a patient's identity; acquiring the healthcare provider's unpaid bill for the patient and converting the healthcare provider's unpaid bill into a dataset of alphanumeric characters by applying extracting text values for predetermined query terms by identifying text located immediately following, immediately below, or within a predetermined distance from each query term, the predetermined distance being measured as a percentage of an image size and identifying a healthcare provider's identity, an amount due, and a service date; initiating a bill... [id. at 1], identifying standardized claims data that corresponds to the patient's identity; determining if the dataset of the healthcare provider's unpaid bill matches a claim in the retrieved standardized claims data that corresponds to the patient's identity; determining if the amount due listed on the healthcare provider's unpaid bill in real time matches the amount that the patient must pay out-of-pocket as provided in the matched claim; responsive to matching the amount due listed on the healthcare provider's unpaid bill to the amount that the patient must pay out-of-pocket as provided in the matched claim, notifying the patient that the healthcare provider's unpaid bill has been validated; and responsive to patient authorization on a patient, effecting a payment transaction to the healthcare provider based on the validated amount, wherein the payment transaction is executed over a communication. (fundamental economic principles or practices, commercial or legal interactions, managing personal behavior or relationships or interactions between people, concepts performed in the human mind, (including an observation, evaluation, judgment, opinion). ) Claim 14 -: 14, the method of claim 13, further including providing, on a graphic, the patient with an option to initiate a payment to the healthcare provider. Claim 15 -: 15, the method of claim 13, further including storing- the standardized claims data in the standardized format. Claim 16 -: 16, the method of claim 13, wherein the bill validation further includes: performing a scoring... [id. at 8], wherein the step of generating a message containing a confirmation that the healthcare provider's bill has been validated occurs when one of the standardized claims data exceeds the predetermined scoring threshold. Claim 17 -: 17, the method of claim 13, wherein the patient's identity is identified by one or more of a name, a social security number, a date of birth, or a zip code. Claim 18 -: 18, the method of claim 13, further comprising displaying on a... [id. at 10], Claim 19 -: 19, the method of claim 18, further comprising displaying a selectable on the patient mobile to pick whether to pay the amount of the healthcare provider's unpaid bill as calculated by the healthcare provider or the amount of the healthcare provider's unpaid bill that the patient is required to pay as reported by standardized claims data. Claim 20 -: 20, the method of claim 13, further comprising: responsive to none... transmitting the... [id. at 12], (mathematical relationships, mathematical calculations. fundamental economic principles or practices, commercial or legal interactions, managing personal behavior or relationships or interactions between people, concepts performed in the human mind, (including an observation, evaluation, judgment, opinion). ) . The identified limitation(s) falls within the subject matter groupings of abstract ideas enumerated in Section I of the 2019 Revised Patent Subject Matter Eligibility Guidance: a) Mathematical concepts – mathematical relationships, mathematical calculations. b) Certain methods of organizing human activity – fundamental economic principles or practices, commercial or legal interactions, managing personal behavior or relationships or interactions between people, c) Mental processes – concepts performed in the human mind, (including an observation, evaluation, judgment, opinion).
These limitation excerpts, under their broadest reasonable interpretation, fall within the grouping(s) of abstract ideas of: Certain methods of organizing human activity – since: healthcare provider bill validation as recited in the claim limitations, under their broadest reasonable interpretation, covers performance of the limitation(s) as fundamental economic principles or practices, (including hedging, insurance, mitigating risk); commercial or legal interactions, (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations); managing personal behavior or relationships or interactions between people, (including social activities, teaching, and following rules or instructions). Mental processes – since: the above-underlined as recited in the claim limitations, under their broadest reasonable interpretation, covers performance of the limitation(s) as concepts performed in the human mind, (including an observation, evaluation, judgment, opinion). Mathematical concepts – since: the above-underlined as recited in the claim limitations, under their broadest reasonable interpretation, covers performance of the limitation(s) as mathematical relationships, mathematical calculations. Therefore, the limitations fall within the above-identified grouping(s) of abstract ideas.
While independent claims 1, 7, and 13 do not explicitly recite verbatim this identified abstract idea, the concept of this identified abstract idea is described by the steps of independent claim 1 and is described by the steps of independent claim 7 and is described by the steps of independent claim 13.
Claim 1: Specifically with respect to the analysis under Step 2A of the Office's § 101 Subject Matter Eligibility Test for Products and Processes, independent claim 1 further to the abstract idea includes an additional element of "first computer network", "PDF", "file", "binary", "server", "optical character recognition", "predetermined extraction program", "relational spacing", "storing", "EOB database", "machine-readable relational data format that is not human readable", "second computer network", "machine readable", "relative spatial analysis", "pixels", "digital", "module", "automatically". However, independent claim 1 does not include additional elements that are sufficient to integrate the exception into a practical application because "first computer network", "PDF", "file", "binary", "server", "optical character recognition", "predetermined extraction program", "relational spacing", "storing", "EOB database", "machine-readable relational data format that is not human readable", "second computer network", "machine readable", "relative spatial analysis", "pixels", "digital", "module", "automatically" of independent claim 1 recite generic computer and/or field of use components pertaining to the particular technological environment that are recited a high-level of generality that perform functions ("acquiring claims data from one … or a text file", "converting, by a claims conversion … into a standardized format", "wherein converting comprises using optical … within the non-standardized format" and "storing the standardized claims data … charge, and discount amount" "receiving, over a second computer … machine readable dataset by", "applying optical character recognition and, … a digital image size" and "initiating a bill validation module, … executes the following steps" "automatically identifying from the machine … and a service date", "automatically accessing the EOB database … to the patient's identity", "executing a data comparison algorithm … provider's unpaid bill; and" and "responsive to one of the … to up-to-date payment information") that merely perform, conduct, carry out, implement, and/or narrow the abstract idea itself (e.g. all or portion(s) of the noted recited steps) and/or that recite generic computer and/or field of use functions that are recited at a high-level of generality that include only steps narrowing the abstract idea [Step 2A Prong I] (e.g. all or portion(s) of the noted recited steps) and/or because the additional method steps comprise or include: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, [Step 2A Prong II] adding the words "apply it" (or an equivalent) 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) (all or portions of the "acquiring claims data from one … or a text file", "converting, by a claims conversion … into a standardized format", "wherein converting comprises using optical … within the non-standardized format", "storing the standardized claims data … charge, and discount amount", "receiving, over a second computer … machine readable dataset by", "applying optical character recognition and, … a digital image size", "initiating a bill validation module, … executes the following steps", "automatically identifying from the machine … and a service date", "automatically accessing the EOB database … to the patient's identity", "executing a data comparison algorithm … provider's unpaid bill; and", "responsive to one of the … to up-to-date payment information" step(s)), and adding insignificant extra-solution activity to the judicial exception -- see MPEP 2106.05(g) (all or portions of the "acquiring claims data from one … or a text file", "converting, by a claims conversion … into a standardized format", "wherein converting comprises using optical … within the non-standardized format", "storing the standardized claims data … charge, and discount amount", "receiving, over a second computer … machine readable dataset by", "applying optical character recognition and, … a digital image size", "automatically identifying from the machine … and a service date", "automatically accessing the EOB database … to the patient's identity", "executing a data comparison algorithm … provider's unpaid bill; and", "responsive to one of the … to up-to-date payment information" step(s)), and generally linking the use of the judicial exception to a particular technological environment or field of use -- see MPEP 2106.05(h) (all or portions of the "acquiring claims data from one … or a text file", "converting, by a claims conversion … into a standardized format", "wherein converting comprises using optical … within the non-standardized format", "storing the standardized claims data … charge, and discount amount", "receiving, over a second computer … machine readable dataset by", "applying optical character recognition and, … a digital image size", "initiating a bill validation module, … executes the following steps", "automatically identifying from the machine … and a service date", "automatically accessing the EOB database … to the patient's identity", "executing a data comparison algorithm … provider's unpaid bill; and", "responsive to one of the … to up-to-date payment information" step(s)). Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the additional elements do not amount to more than a recitation of the words "apply it" (or an equivalent) or are not more than mere instructions to implement an abstract idea or other exception on a computer, and the additional elements do not add more than insignificant extra-solution activity to the judicial exception, and the additional elements do not amount to more than generally linking the use of a judicial exception to a particular technological environment or field of use. Moreover, the additional method step comprises or includes: reciting additional elements in implementing the abstract idea that do not constitute significantly more than the abstract idea because they comprise or include well-understood, routine, and conventional activities previously known to the industry (e.g. all or portion(s) of the "acquiring claims data from one … or a text file", "converting, by a claims conversion … into a standardized format", "wherein converting comprises using optical … within the non-standardized format", "storing the standardized claims data … charge, and discount amount", "receiving, over a second computer … machine readable dataset by", "applying optical character recognition and, … a digital image size", "automatically identifying from the machine … and a service date", "automatically accessing the EOB database … to the patient's identity", "executing a data comparison algorithm … provider's unpaid bill; and", "responsive to one of the … to up-to-date payment information", (insignificant extra-solution activity) steps), see Alice Corp., 134 S. Ct. at 2360, and/or that are otherwise not significant toward constituting any inventive concept beyond the abstract idea. (E.g. The above-italicized grounds of rejection apply at least to all or portion(s) of the noted recited steps.) For example regarding well-understood, routine, and conventional activities, the cited rationale have recognized the following computer function as well-understood, routine, and conventional functions when it is claimed or as insignificant extra-solution activity: receiving or transmitting data over a network, e.g., using the Internet to gather data, Intellectual Ventures I v. Symantec Corp., 838 F.3d at 1321, 120 USPQ2d at 1362 (2016) (utilizing an intermediary computer to forward information); TLI Communications LLC v. AV Auto. LLC, 823 F.3d 607, 610, 118 USPQ2d 1744, 1745 (Fed. Cir. 2016) (using a telephone for image transmission); OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1093 (Fed. Cir. 2015) (sending messages over a network); 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), performing repetitive calculations, Parker v. Flook, 437 U.S. at 594, 198 USPQ2d at 199 (1978) (recomputing or readjusting alarm limit values); 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."), electronic recordkeeping, Alice Corp. Pty. Ltd. v. CLS Bank Int'l, 134 S. Ct. at 2359, 110 USPQ2d at 1984 (2014) (creating and maintaining "shadow accounts"); Ultramercial, Inc. v. Hulu, LLC, 772 F.3d at 716, 112 USPQ2d at 1755 (Fed. Cir. 2014) (updating an activity log), storing and retrieving information in memory, Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015); OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d at 1363, 115 USPQ2d at 1092-93 (Fed. Cir. 2015), and electronically scanning or extracting data from a physical document, Content Extraction and Transmission, LLC v. Wells Fargo Bank, 776 F.3d 1343, 1348, 113 USPQ2d 1354, 1358 (Fed. Cir. 2014) (optical character recognition); and the cited rationale have found the following type of activity to be well-understood, routine, and conventional activity when it is claimed or as insignificant extra-solution activity: recording a customer's order, Apple, Inc. v. Ameranth, Inc., 842 F.3d 1229, 1244, 120 USPQ2d 1844, 1856 (Fed. Cir. 2016), restricting public access to media by requiring a consumer to view an advertisement, Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709, 716-17, 112 USPQ2d 1750, 1755-56 (Fed. Cir. 2014), identifying undeliverable mail items, decoding data on those mail items, and creating output data, Return Mail, Inc. v. U.S. Postal Service, -- F.3d --, -- USPQ2d --, slip op. at 32 (Fed. Cir. August 28, 2017), presenting offers and gathering statistics, OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d at 1362-63, 115 USPQ2d at 1092-93 (Fed. Cir. 2015), determining an estimated outcome and setting a price, OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d at 1362-63, 115 USPQ2d at 1092-93 (Fed. Cir. 2015), and arranging a hierarchy of groups, sorting information, eliminating less restrictive pricing information and determining the price, Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1331, 115 USPQ2d 1681, 1699 (Fed. Cir. 2015). None of the additional elements taken individually or when taken as an ordered combination amount to significantly more than the abstract idea. Accordingly, independent claim 1 is ineligible.
Claim 7: Specifically pertaining to the analysis under Step 2A of the Office's § 101 Subject Matter Eligibility Test for Products and Processes, independent claim 7 further to the abstract idea includes an additional element of "digital", "optical character recognition", "relative spatial analysis", "pixels", "module", "computer", "network", "PDF", "file", "binary", "server", "predetermined extraction program", "relational spacing", "storing", "EOB database", "machine-readable relational data format that is not human readable", "automatically", "computing". However, independent claim 7 does not include additional elements that are sufficient to integrate the exception into a practical application because "digital", "optical character recognition", "relative spatial analysis", "pixels", "module", "computer", "network", "PDF", "file", "binary", "server", "predetermined extraction program", "relational spacing", "storing", "EOB database", "machine-readable relational data format that is not human readable", "automatically", "computing" of independent claim 7 recite generic computer and/or field of use components pertaining to the particular technological environment that are recited a high-level of generality that perform functions ("acquiring a first digital image … bill for a patient", "converting the first digital image … alphanumeric characters by", "applying optical character recognition and, … a digital image size", "wherein the digital dataset includes … and a service date", "initiating a bill validation module, … executes the following steps", "acquiring claims data originating from … or a text file", "converting, by a claims conversion … into a standardized format", "wherein converting comprises using optical … within the non-standardized format", "storing the standardized claims data … charge, and discount amount", "automatically accessing, via a computer network, the EOB database", "retrieving the standardized claims data … to the patient's identity", "automatically matching in real time … to the patient's identity", "automatically determining if the amount … in the matched claim", "responsive to determining that the … has been validated; and" and "responsive to a user initiation … a secure communication channel") that merely perform, conduct, carry out, implement, and/or narrow the abstract idea itself (e.g. all or portion(s) of the noted recited steps) and/or that recite generic computer and/or field of use functions that are recited at a high-level of generality that include only steps narrowing the abstract idea [Step 2A Prong I] (e.g. all or portion(s) of the noted recited steps) and/or because the additional method steps comprise or include: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, [Step 2A Prong II] adding the words "apply it" (or an equivalent) 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) (all or portions of the "applying optical character recognition and, … a digital image size", "initiating a bill validation module, … executes the following steps", "acquiring claims data originating from … or a text file", "converting, by a claims conversion … into a standardized format", "wherein converting comprises using optical … within the non-standardized format", "storing the standardized claims data … charge, and discount amount", "automatically accessing, via a computer network, the EOB database", "retrieving the standardized claims data … to the patient's identity", "automatically matching in real time … to the patient's identity", "automatically determining if the amount … in the matched claim", "responsive to determining that the … has been validated; and", "responsive to a user initiation … a secure communication channel" step(s)), and adding insignificant extra-solution activity to the judicial exception -- see MPEP 2106.05(g) (all or portions of the "applying optical character recognition and, … a digital image size", "acquiring claims data originating from … or a text file", "converting, by a claims conversion … into a standardized format", "wherein converting comprises using optical … within the non-standardized format", "storing the standardized claims data … charge, and discount amount", "automatically accessing, via a computer network, the EOB database", "retrieving the standardized claims data … to the patient's identity", "automatically matching in real time … to the patient's identity", "automatically determining if the amount … in the matched claim", "responsive to determining that the … has been validated; and", "responsive to a user initiation … a secure communication channel" step(s)), and generally linking the use of the judicial exception to a particular technological environment or field of use -- see MPEP 2106.05(h) (all or portions of the noted step(s)). Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the additional elements do not amount to more than a recitation of the words "apply it" (or an equivalent) or are not more than mere instructions to implement an abstract idea or other exception on a computer, and the additional elements do not add more than insignificant extra-solution activity to the judicial exception, and the additional elements do not amount to more than generally linking the use of a judicial exception to a particular technological environment or field of use. Additionally, the additional method step comprises or includes: reciting additional elements in implementing the abstract idea that do not constitute significantly more than the abstract idea because they comprise or include well-understood, routine, and conventional activities previously known to the industry (e.g. all or portion(s) of the "applying optical character recognition and, … a digital image size", "acquiring claims data originating from … or a text file", "converting, by a claims conversion … into a standardized format", "wherein converting comprises using optical … within the non-standardized format", "storing the standardized claims data … charge, and discount amount", "automatically accessing, via a computer network, the EOB database", "retrieving the standardized claims data … to the patient's identity", "automatically matching in real time … to the patient's identity", "automatically determining if the amount … in the matched claim", "responsive to determining that the … has been validated; and", "responsive to a user initiation … a secure communication channel", (insignificant extra-solution activity) steps), see Alice Corp., 134 S. Ct. at 2360, and/or that are otherwise not significant toward constituting any inventive concept beyond the abstract idea. (E.g. The above-italicized grounds of rejection apply at least to all or portion(s) of the noted recited steps.) For example regarding well-understood, routine, and conventional activities, the cited rationale have recognized the following computer function as well-understood, routine, and conventional functions when it is claimed or as insignificant extra-solution activity: receiving or transmitting data over a network, Intellectual Ventures I v. Symantec Corp., (2016); TLI Communications LLC v. AV Auto. LLC, (Fed. Cir. 2016); OIP Techs., Inc., v. Amazon.com, Inc., (Fed. Cir. 2015); buySAFE, Inc. v. Google, Inc., (Fed. Cir. 2014), see previous legal citations herein Re: Claim 1, performing repetitive calculations, Parker v. Flook, (1978); Bancorp Services v. Sun Life, (Fed. Cir. 2012), see previous legal citations herein Re: Claim 1, electronic recordkeeping, Alice Corp. Pty. Ltd. v. CLS Bank Int'l, (2014); Ultramercial, Inc. v. Hulu, LLC, (Fed. Cir. 2014), see previous legal citations herein Re: Claim 1, storing and retrieving information in memory, Versata Dev. Group, Inc. v. SAP Am., Inc., (Fed. Cir. 2015); OIP Techs., Inc. v. Amazon.com, Inc., (Fed. Cir. 2015), see previous legal citations herein Re: Claim 1, electronically scanning or extracting data from a physical document, Content Extraction and Transmission, LLC v. Wells Fargo Bank, (Fed. Cir. 2014), see previous legal citation herein Re: Claim 1, and a web browser's back and forward button functionality, Internet Patent Corp. v. Active Network, Inc., 790 F.3d 1343, 1348, 115 USPQ2d 1414, 1418 (Fed. Cir. 2015); and the cited rationale have found the following type of activity to be well-understood, routine, and conventional activity when it is claimed or as insignificant extra-solution activity: recording a customer's order, Apple, Inc. v. Ameranth, Inc., (Fed. Cir. 2016), see previous legal citation herein Re: Claim 1, restricting public access to media by requiring a consumer to view an advertisement, Ultramercial, Inc. v. Hulu, LLC (Fed. Cir. 2014), see previous legal citation herein Re: Claim 1, identifying undeliverable mail items, decoding data on those mail items, and creating output data, Return Mail, Inc. v. U.S. Postal Service, (Fed. Cir. 2017), see previous legal citation herein Re: Claim 1, presenting offers and gathering statistics, OIP Techs., Inc. v. Amazon.com, Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1, determining an estimated outcome and setting a price, OIP Techs., Inc. v. Amazon.com, Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1, and arranging a hierarchy of groups, sorting information, eliminating less restrictive pricing information and determining the price, Versata Dev. Group, Inc. v. SAP Am., Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1. None of the additional elements taken individually or when taken as an ordered combination amount to significantly more than the abstract idea. Accordingly, independent claim 7 is ineligible.
Claim 13: Particularly pertaining to the analysis under Step 2A of the Office's § 101 Subject Matter Eligibility Test for Products and Processes, independent claim 13 further to the abstract idea includes additional elements of "PDF", "file", "binary", "server", "optical character recognition", "predetermined extraction program", "relational spacing", "machine-readable relational data format that is not human readable", "digital", "relative spatial analysis", "pixels", "module", "automatically", "computing", "device", and "secure communication channel". However, independent claim 13 does not include additional elements that are sufficient to integrate the exception into a practical application because "PDF", "file", "binary", "server", "optical character recognition", "predetermined extraction program", "relational spacing", "machine-readable relational data format that is not human readable", "digital", "relative spatial analysis", "pixels", "module", "automatically", "computing", "device", and "secure communication channel" of independent claim 13 recite generic computer and/or field of use components pertaining to the particular technological environment that are recited a high-level of generality that perform functions ("converting, by a claims conversion … into a standardized format", "wherein converting comprises using optical … the non-standardized format, and" and "wherein the standardized format comprises … charge, and discount amount" "applying optical character recognition and, … digital image size and" "initiating a bill validation module, … executes the following steps", "automatically identifying standardized claims data … to the patient's identity", "automatically determining if the digital … to the patient's identity", "automatically determining if the amount … in the matched claim", "responsive to matching the amount … has been validated; and" and "responsive to patient authorization on … a secure communication channel") that merely perform, conduct, carry out, implement, and/or narrow the abstract idea itself (e.g. all or portion(s) of the noted recited steps) and/or that recite generic computer and/or field of use functions that are recited at a high-level of generality that include only steps narrowing the abstract idea [Step 2A Prong I] (e.g. all or portion(s) of the noted recited steps) and/or because the additional method steps comprise or include: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, [Step 2A Prong II] adding the words "apply it" (or an equivalent) 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) (all or portions of the "converting, by a claims conversion … into a standardized format", "wherein converting comprises using optical … the non-standardized format, and", "wherein the standardized format comprises … charge, and discount amount", "applying optical character recognition and, … digital image size and", "initiating a bill validation module, … executes the following steps", "automatically identifying standardized claims data … to the patient's identity", "automatically determining if the digital … to the patient's identity", "automatically determining if the amount … in the matched claim", "responsive to matching the amount … has been validated; and", "responsive to patient authorization on … a secure communication channel" step(s)), and adding insignificant extra-solution activity to the judicial exception -- see MPEP 2106.05(g) (all or portions of the "wherein converting comprises using optical … the non-standardized format, and", "applying optical character recognition and, … digital image size and", "automatically determining if the digital … to the patient's identity", "automatically determining if the amount … in the matched claim", "responsive to matching the amount … has been validated; and", "responsive to patient authorization on … a secure communication channel" step(s)), and generally linking the use of the judicial exception to a particular technological environment or field of use -- see MPEP 2106.05(h) (all or portions of the "wherein converting comprises using optical … the non-standardized format, and", "wherein the standardized format comprises … charge, and discount amount", "applying optical character recognition and, … digital image size and", "initiating a bill validation module, … executes the following steps", "automatically identifying standardized claims data … to the patient's identity", "automatically determining if the digital … to the patient's identity", "automatically determining if the amount … in the matched claim", "responsive to matching the amount … has been validated; and", "responsive to patient authorization on … a secure communication channel" step(s)). Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the additional elements do not amount to more than a recitation of the words "apply it" (or an equivalent) or are not more than mere instructions to implement an abstract idea or other exception on a computer, and the additional elements do not add more than insignificant extra-solution activity to the judicial exception, and the additional elements do not amount to more than generally linking the use of a judicial exception to a particular technological environment or field of use. Furthermore, the additional method steps comprise or include: reciting additional elements in implementing the abstract idea that do not constitute significantly more than the abstract idea because they comprise or include well-understood, routine, and conventional activities previously known to the industry (e.g. all or portion(s) of the "wherein converting comprises using optical … the non-standardized format, and", "applying optical character recognition and, … digital image size and", "automatically determining if the digital … to the patient's identity", "automatically determining if the amount … in the matched claim", "responsive to matching the amount … has been validated; and", "responsive to patient authorization on … a secure communication channel", (insignificant extra-solution activity) steps), see Alice Corp., 134 S. Ct. at 2360, and/or that are otherwise not significant toward constituting any inventive concept beyond the abstract idea. (E.g. The above-italicized grounds of rejection apply at least to all or portion(s) of the noted recited steps.) For example regarding well-understood, routine, and conventional activities, the cited rationale have recognized the following computer function as well-understood, routine, and conventional functions when it is claimed or as insignificant extra-solution activity: receiving or transmitting data over a network, Intellectual Ventures I v. Symantec Corp., (2016); TLI Communications LLC v. AV Auto. LLC, (Fed. Cir. 2016); OIP Techs., Inc., v. Amazon.com, Inc., (Fed. Cir. 2015); buySAFE, Inc. v. Google, Inc., (Fed. Cir. 2014), see previous legal citations herein Re: Claim 1, performing repetitive calculations, Parker v. Flook, (1978); Bancorp Services v. Sun Life, (Fed. Cir. 2012), see previous legal citations herein Re: Claim 1, electronic recordkeeping, Alice Corp. Pty. Ltd. v. CLS Bank Int'l, (2014); Ultramercial, Inc. v. Hulu, LLC, (Fed. Cir. 2014), see previous legal citations herein Re: Claim 1, electronically scanning or extracting data from a physical document, Content Extraction and Transmission, LLC v. Wells Fargo Bank, (Fed. Cir. 2014), see previous legal citation herein Re: Claim 1, and a web browser's back and forward button functionality, Internet Patent Corp. v. Active Network, Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 7; and the cited rationale have found the following type of activity to be well-understood, routine, and conventional activity when it is claimed or as insignificant extra-solution activity: recording a customer's order, Apple, Inc. v. Ameranth, Inc., (Fed. Cir. 2016), see previous legal citation herein Re: Claim 1, restricting public access to media by requiring a consumer to view an advertisement, Ultramercial, Inc. v. Hulu, LLC (Fed. Cir. 2014), see previous legal citation herein Re: Claim 1, identifying undeliverable mail items, decoding data on those mail items, and creating output data, Return Mail, Inc. v. U.S. Postal Service, (Fed. Cir. 2017), see previous legal citation herein Re: Claim 1, presenting offers and gathering statistics, OIP Techs., Inc. v. Amazon.com, Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1, determining an estimated outcome and setting a price, OIP Techs., Inc. v. Amazon.com, Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1, and arranging a hierarchy of groups, sorting information, eliminating less restrictive pricing information and determining the price, Versata Dev. Group, Inc. v. SAP Am., Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1. None of the additional elements taken individually or when taken as an ordered combination amount to significantly more than the abstract idea. Accordingly, independent claim 13 is ineligible.
Independent Claims: Nothing in independent claims 1, 7, and 13 improves another technology or technical field, improves the functioning of any claimed computer device itself, applies the abstract idea with any particular machine, solves any computer problem with a computer solution, or includes any element that may otherwise be considered to amount to significantly more than the abstract idea.
None of the dependent claims 2-6, 8-12, and 14-20 when separately considered with each dependent claim's corresponding parent claim overcomes the above analysis because none presents any method step not directed to the abstract idea that amounts to significantly more than the judicial exception or any physical structure that amounts to significantly more than the judicial exception.
Claim 3: Dependent claim 3 does not include additional elements that are sufficient to amount to significantly more than the judicial exception because, "camera" of dependent claim 3 recite generic computer and/or field of use components pertaining to the particular technological environment that are recited a high-level of generality. No additional element introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea.
Claim 4: Dependent claim 4 does not include additional elements that are sufficient to amount to significantly more than the judicial exception because, "device" of dependent claim 4 recite generic computer and/or field of use components pertaining to the particular technological environment that are recited a high-level of generality. No additional element introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea.
Claims 5, 11, and 19: Dependent claims 5, 11, and 19 do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, "control" of dependent claims 5, 11, and 19 recite generic computer and/or field of use components pertaining to the particular technological environment that are recited a high-level of generality. No additional element introduced in these claims taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea.
Claim 8: Dependent claim 8 does not include additional elements that are sufficient to amount to significantly more than the judicial exception because, "algorithm" of dependent claim 8 recite generic computer and/or field of use components pertaining to the particular technological environment that are recited a high-level of generality. No additional element introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea.
Claim 14: Dependent claim 14 does not include additional elements that are sufficient to amount to significantly more than the judicial exception because, "user interface" of dependent claim 14 recite generic computer and/or field of use components pertaining to the particular technological environment that are recited a high-level of generality. No additional element introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea.
Claim 15: Dependent claim 15 does not include additional elements that are sufficient to amount to significantly more than the judicial exception because, "storing", and "EOB database" of dependent claim 15 recite generic computer and/or field of use components pertaining to the particular technological environment that are recited a high-level of generality. No additional element introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea.
Claim 16: Dependent claim 16 does not include additional elements that are sufficient to amount to significantly more than the judicial exception because, "algorithm", and "EOB database" of dependent claim 16 recite generic computer and/or field of use components pertaining to the particular technological environment that are recited a high-level of generality. No additional element introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea.
Claim 2: Dependent claim 2 adds an additional method step of "wherein the patient's identity is identified by one or more of a name, a user login, a social security number, a date of birth, or a zip code". However, the additional method step of dependent claims 2 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. the noted recited steps). Dependent claim 2 further does not specify any particular machine element(s) for the "wherein the patient's identity is identified by one or more of a name, user login information, a social security number, a date of birth, or a zip code" step and under the broadest reasonable interpretation, this step may be manually performed by a human only which also does not add significantly more than the abstract idea. No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 2 is ineligible.
Claim 3: Dependent claim 3 adds additional method steps of "receiving the healthcare provider's unpaid bill as a first digital image taken with a digital … digital dataset includes the healthcare provider's identity, the amount due, and the service date". However, the additional method steps of dependent claims 3 are directed to the abstract idea noted above and do not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method steps merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrow the abstract idea (e.g. all or portion(s) of the noted recited steps) and/or because the additional method steps comprise or include: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, Regarding Step 2B, the additional elements do not add more than insignificant extra-solution activity to the judicial exception, and the additional elements do not amount to more than generally linking the use of a judicial exception to a particular technological environment or field of use. (E.g. The above-italicized grounds of rejection apply at least to all or portion(s) of the noted recited steps.) For example regarding well-understood, routine, and conventional activities, the cited rationale have recognized the following computer function as well-understood, routine, and conventional functions when it is claimed or as insignificant extra-solution activity: receiving or transmitting data over a network, Intellectual Ventures I v. Symantec Corp., (2016); TLI Communications LLC v. AV Auto. LLC, (Fed. Cir. 2016); OIP Techs., Inc., v. Amazon.com, Inc., (Fed. Cir. 2015); buySAFE, Inc. v. Google, Inc., (Fed. Cir. 2014), see previous legal citations herein Re: Claim 1, electronic recordkeeping, Alice Corp. Pty. Ltd. v. CLS Bank Int'l, (2014); Ultramercial, Inc. v. Hulu, LLC, (Fed. Cir. 2014), see previous legal citations herein Re: Claim 1, and electronically scanning or extracting data from a physical document, Content Extraction and Transmission, LLC v. Wells Fargo Bank, (Fed. Cir. 2014), see previous legal citation herein Re: Claim 1; and the cited rationale have found the following type of activity to be well-understood, routine, and conventional activity when it is claimed or as insignificant extra-solution activity: recording a customer's order, Apple, Inc. v. Ameranth, Inc., (Fed. Cir. 2016), see previous legal citation herein Re: Claim 1, and identifying undeliverable mail items, decoding data on those mail items, and creating output data, Return Mail, Inc. v. U.S. Postal Service, (Fed. Cir. 2017), see previous legal citation herein Re: Claim 1, pertaining to all or portion(s) of the noted recited steps. No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 3 is ineligible.
Claim 4: Dependent claim 4 adds an additional method step of "displaying on a patient's mobile device a comparison of the amount of the healthcare provider's … bill that the patient is required to pay as reported by patient-specific claims data". However, the additional method step of dependent claims 4 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited step) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claim 1 above. Regarding Step 2B, the additional elements do not amount to more than a recitation of the words "apply it" (or an equivalent) or are not more than mere instructions to implement an abstract idea or other exception on a computer, and the additional elements do not add more than insignificant extra-solution activity to the judicial exception, and the additional elements do not amount to more than generally linking the use of a judicial exception to a particular technological environment or field of use. (E.g. The above-italicized grounds of rejection apply at least to all or portion(s) of the noted recited step.) For example regarding well-understood, routine, and conventional activities, the cited rationale have recognized the following computer function as well-understood, routine, and conventional functions when it is claimed or as insignificant extra-solution activity: a web browser's back and forward button functionality, Internet Patent Corp. v. Active Network, Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 7; and the cited rationale have found the following type of activity to be well-understood, routine, and conventional activity when it is claimed or as insignificant extra-solution activity: recording a customer's order, Apple, Inc. v. Ameranth, Inc., (Fed. Cir. 2016), see previous legal citation herein Re: Claim 1, restricting public access to media by requiring a consumer to view an advertisement, Ultramercial, Inc. v. Hulu, LLC (Fed. Cir. 2014), see previous legal citation herein Re: Claim 1, presenting offers and gathering statistics, OIP Techs., Inc. v. Amazon.com, Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1, determining an estimated outcome and setting a price, OIP Techs., Inc. v. Amazon.com, Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1, and arranging a hierarchy of groups, sorting information, eliminating less restrictive pricing information and determining the price, Versata Dev. Group, Inc. v. SAP Am., Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1, pertaining to all or portion(s) of the noted recited step. No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 4 is ineligible.
Claim 5: Dependent claim 5 adds an additional method step of "displaying a selectable control to pick whether to pay the amount of the healthcare provider's … bill that the patient is required to pay as reported by patient-specific claims data". However, the additional method step of dependent claims 5 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited step) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claim 1 above. Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claim 4 also applies hereto. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited step.) See discussion above regarding Claim 4 for pertinent previously cited rationale finding well-understood, routine, and conventional activities, pertaining to all or portion(s) of the noted recited step. No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 5 is ineligible.
Claim 6: Dependent claim 6 adds an additional method step of "responsive to none of the patient-specific claims data corresponding to the healthcare provider's identity, the … healthcare provider's unpaid bill has not been validated by the patient-specific claims data; and", "transmitting the message to the one user over the communication network, so that the patient has immediate access to up-to-date payment information". However, the additional method step of dependent claims 6 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited steps) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claim 3 above. Regarding Step 2B, the additional elements do not add more than insignificant extra-solution activity to the judicial exception, and the additional elements do not amount to more than generally linking the use of a judicial exception to a particular technological environment or field of use. (E.g. The above-italicized grounds of rejection apply at least to all or portion(s) of the noted recited steps.) For example regarding well-understood, routine, and conventional activities, the cited rationale have recognized the following computer function as well-understood, routine, and conventional functions when it is claimed or as insignificant extra-solution activity: receiving or transmitting data over a network, Intellectual Ventures I v. Symantec Corp., (2016); TLI Communications LLC v. AV Auto. LLC, (Fed. Cir. 2016); OIP Techs., Inc., v. Amazon.com, Inc., (Fed. Cir. 2015); buySAFE, Inc. v. Google, Inc., (Fed. Cir. 2014), see previous legal citations herein Re: Claim 1, performing repetitive calculations, Parker v. Flook, (1978); Bancorp Services v. Sun Life, (Fed. Cir. 2012), see previous legal citations herein Re: Claim 1, electronic recordkeeping, Alice Corp. Pty. Ltd. v. CLS Bank Int'l, (2014); Ultramercial, Inc. v. Hulu, LLC, (Fed. Cir. 2014), see previous legal citations herein Re: Claim 1, and a web browser's back and forward button functionality, Internet Patent Corp. v. Active Network, Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 7; and the cited rationale have found the following type of activity to be well-understood, routine, and conventional activity when it is claimed or as insignificant extra-solution activity: recording a customer's order, Apple, Inc. v. Ameranth, Inc., (Fed. Cir. 2016), see previous legal citation herein Re: Claim 1, presenting offers and gathering statistics, OIP Techs., Inc. v. Amazon.com, Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1, determining an estimated outcome and setting a price, OIP Techs., Inc. v. Amazon.com, Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1, and arranging a hierarchy of groups, sorting information, eliminating less restrictive pricing information and determining the price, Versata Dev. Group, Inc. v. SAP Am., Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1, pertaining to all or portion(s) of the noted recited steps. No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 6 is ineligible.
Claim 8: Dependent claim 8 adds an additional method step of "performing a scoring algorithm when validating the amount due listed on the healthcare provider's unpaid … scoring threshold to validate the amount due listed on the healthcare provider's unpaid bill", "wherein the step of automatically notifying that the healthcare provider's bill has been validated occurs when one of the standardized claims data exceeds the predetermined scoring threshold". However, the additional method step of dependent claims 8 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited steps) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claim 1 above. Regarding Step 2B, the additional elements do not amount to more than a recitation of the words "apply it" (or an equivalent) or are not more than mere instructions to implement an abstract idea or other exception on a computer, and the additional elements do not add more than insignificant extra-solution activity to the judicial exception, and the additional elements do not amount to more than generally linking the use of a judicial exception to a particular technological environment or field of use. (E.g. The above-italicized grounds of rejection apply at least to all or portion(s) of the noted recited steps.) For example regarding well-understood, routine, and conventional activities, the cited rationale have recognized the following computer function as well-understood, routine, and conventional functions when it is claimed or as insignificant extra-solution activity: performing repetitive calculations, Parker v. Flook, (1978); Bancorp Services v. Sun Life, (Fed. Cir. 2012), see previous legal citations herein Re: Claim 1, electronic recordkeeping, Alice Corp. Pty. Ltd. v. CLS Bank Int'l, (2014); Ultramercial, Inc. v. Hulu, LLC, (Fed. Cir. 2014), see previous legal citations herein Re: Claim 1, and storing and retrieving information in memory, Versata Dev. Group, Inc. v. SAP Am., Inc., (Fed. Cir. 2015); OIP Techs., Inc. v. Amazon.com, Inc., (Fed. Cir. 2015), see previous legal citations herein Re: Claim 1; and the cited rationale have found the following type of activity to be well-understood, routine, and conventional activity when it is claimed or as insignificant extra-solution activity: recording a customer's order, Apple, Inc. v. Ameranth, Inc., (Fed. Cir. 2016), see previous legal citation herein Re: Claim 1, identifying undeliverable mail items, decoding data on those mail items, and creating output data, Return Mail, Inc. v. U.S. Postal Service, (Fed. Cir. 2017), see previous legal citation herein Re: Claim 1, presenting offers and gathering statistics, OIP Techs., Inc. v. Amazon.com, Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1, determining an estimated outcome and setting a price, OIP Techs., Inc. v. Amazon.com, Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1, and arranging a hierarchy of groups, sorting information, eliminating less restrictive pricing information and determining the price, Versata Dev. Group, Inc. v. SAP Am., Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1, pertaining to all or portion(s) of the noted recited steps. No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 8 is ineligible.
Claim 9: Dependent claim 9 adds an additional method step of "wherein the patient's identity is identified by one or more of a name, user login information, a social security number, a date of birth, or a zip code". However, the additional method step of dependent claims 9 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. the noted recited steps). Dependent claim 9 further does not specify any particular machine element(s) for the "wherein the patient's identity is identified by one or more of a name, user login information, a social security number, a date of birth, or a zip code" step and under the broadest reasonable interpretation, this step may be manually performed by a human only which also does not add significantly more than the abstract idea. No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 9 is ineligible.
Claims 10 and 18: Dependent claims 10 and 18 add an additional method step of "displaying on a patient's mobile device a comparison of the amount of the healthcare provider's … that the patient is required to pay as reported by the standardized claims data". However, the additional method step of dependent claim 10 and 18 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited step) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claim 1 above. Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claim 4 also applies hereto. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited step.) See discussion above regarding Claim 4 for pertinent previously cited rationale finding well-understood, routine, and conventional activities, pertaining to all or portion(s) of the noted recited step. No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claims 10 and 18 are ineligible.
Claim 11: Dependent claim 11 adds an additional method step of "displaying a selectable control to pick whether to pay the amount of the healthcare provider's … bill that the patient is required to pay as reported by standardized claims data". However, the additional method step of dependent claims 11 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited step) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claim 1 above. Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claim 4 also applies hereto. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited step.) See discussion above regarding Claim 4 for pertinent previously cited rationale finding well-understood, routine, and conventional activities, pertaining to all or portion(s) of the noted recited step. No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 11 is ineligible.
Claims 12 and 20: Dependent claims 12 and 20 add an additional method step of "responsive to none of the standardized claims data matching the digital dataset, automatically generating a … healthcare provider's unpaid bill has not been validated by the standardized claims data; and", "transmitting the message to the patient, so that the patient has immediate access to up-to-date payment information". However, the additional method step of dependent claim 12 and 20 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited steps) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claim 3 above. Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claim 6 also applies hereto. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited steps.) See discussion above regarding Claim 6 for pertinent previously cited rationale finding well-understood, routine, and conventional activities, pertaining to all or portion(s) of the noted recited steps. No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claims 12 and 20 are ineligible.
Claim 14: Dependent claim 14 adds an additional method step of "providing, on a graphic user interface, the patient with an option to initiate a digital payment to the healthcare provider". However, the additional method step of dependent claims 14 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited steps) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claim 1 above. Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claim 4 also applies hereto. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited steps.) See discussion above regarding Claim 4 for pertinent previously cited rationale finding well-understood, routine, and conventional activities, pertaining to all or portion(s) of the noted recited steps. No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 14 is ineligible.
Claim 15: Dependent claim 15 adds an additional method step of "storing the standardized claims data in an EOB database in the standardized format". However, the additional method step of dependent claims 15 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited step) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claim 1 above. Regarding Step 2B, the additional elements do not amount to more than a recitation of the words "apply it" (or an equivalent) or are not more than mere instructions to implement an abstract idea or other exception on a computer, and the additional elements do not add more than insignificant extra-solution activity to the judicial exception, and the additional elements do not amount to more than generally linking the use of a judicial exception to a particular technological environment or field of use. (E.g. The above-italicized grounds of rejection apply at least to all or portion(s) of the noted recited step.) For example regarding well-understood, routine, and conventional activities, the cited rationale have recognized the following computer function as well-understood, routine, and conventional functions when it is claimed or as insignificant extra-solution activity: electronic recordkeeping, Alice Corp. Pty. Ltd. v. CLS Bank Int'l, (2014); Ultramercial, Inc. v. Hulu, LLC, (Fed. Cir. 2014), see previous legal citations herein Re: Claim 1, and storing and retrieving information in memory, Versata Dev. Group, Inc. v. SAP Am., Inc., (Fed. Cir. 2015); OIP Techs., Inc. v. Amazon.com, Inc., (Fed. Cir. 2015), see previous legal citations herein Re: Claim 1; and the cited rationale have found the following type of activity to be well-understood, routine, and conventional activity when it is claimed or as insignificant extra-solution activity: recording a customer's order, Apple, Inc. v. Ameranth, Inc., (Fed. Cir. 2016), see previous legal citation herein Re: Claim 1, identifying undeliverable mail items, decoding data on those mail items, and creating output data, Return Mail, Inc. v. U.S. Postal Service, (Fed. Cir. 2017), see previous legal citation herein Re: Claim 1, determining an estimated outcome and setting a price, OIP Techs., Inc. v. Amazon.com, Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1, and arranging a hierarchy of groups, sorting information, eliminating less restrictive pricing information and determining the price, Versata Dev. Group, Inc. v. SAP Am., Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1, pertaining to all or portion(s) of the noted recited step. No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 15 is ineligible.
Claim 16: Dependent claim 16 adds an additional method step of "performing a scoring algorithm when validating the amount due listed on the healthcare provider's unpaid … scoring threshold to validate the amount due listed on the healthcare provider's unpaid bill", "wherein the step of automatically generating a message containing a confirmation that the healthcare provider's … validated occurs when one of the standardized claims data exceeds the predetermined scoring threshold". However, the additional method step of dependent claims 16 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited steps) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claim 1 above. Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claim 8 also applies hereto. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited steps.) See discussion above regarding Claim 8 for pertinent previously cited rationale finding well-understood, routine, and conventional activities, pertaining to all or portion(s) of the noted recited steps. No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 16 is ineligible.
Claim 17: Dependent claim 17 adds an additional method step of "wherein the patient's identity is identified by one or more of a name, a social security number, a date of birth, or a zip code". However, the additional method step of dependent claims 17 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. the noted recited steps). Dependent claim 17 further does not specify any particular machine element(s) for the "wherein the patient's identity is identified by one or more of a name, a social security number, a date of birth, or a zip code" step and under the broadest reasonable interpretation, this step may be manually performed by a human only which also does not add significantly more than the abstract idea. No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 17 is ineligible.
Claim 19: Dependent claim 19 adds an additional method step of "displaying a selectable control on the patient's mobile device to pick whether to pay the … bill that the patient is required to pay as reported by standardized claims data". However, the additional method step of dependent claims 19 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited step) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claim 1 above. Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claim 4 also applies hereto. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited step.) See discussion above regarding Claim 4 for pertinent previously cited rationale finding well-understood, routine, and conventional activities, pertaining to all or portion(s) of the noted recited step. No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 19 is ineligible.
PNG
media_image1.png
930
645
media_image1.png
Greyscale
PNG
media_image2.png
200
400
media_image2.png
Greyscale
§101 Subject Matter Eligibility Test for Products and Processes
Response to Arguments
• The Applicant argued:
"The amendments introduce no new matter. []"
(REMARKS [as abridged], p. 11).
Respectively nonetheless, the above-quoted arguments are not persuasive.
Regarding eligibility rejections under 35 U.S.C. § 101, the Applicant's arguments submitted January 22, 2026 (hereinafter "REMARKS") in response to the Official Correspondence mailed December 12, 2025 (hereinafter "Final Correspondence") have been fully considered but are not persuasive and/or are moot in view of the new grounds of rejection which are responsive to Applicant's RCE submission. Further to the December 12, 2025 Final Correspondence, the new grounds of rejection are fully set forth above under the 35 U.S.C. § 101 heading as applied to the herein examined current claims.
• The Applicant argued:
'[] Applicant respectfully submits that the Prong One characterization overgeneralizes the claims by treating the entire claimed workflow as the "abstract idea[.]" []
"[T]he independent claims recite concrete, computer-implemented operations that cannot practically be performed in the human mind, including:
"[amended claim language].
"These limitations are expressly technical data-processing steps tied to machine interpretation of electronic documents and images (OCR, spatial extraction, relational-data structuring). [] OCR, pixel- based spatial extraction, and machine-readable relational storage are not mental acts.
"To the extent the Office associates 'mathematical concepts' with the amended spatial- extraction language, [t]he amended claims do not claim a mathematical formula in the abstract. Instead, the claims recite a specific image-to-text extraction technique using OCR and spatial constraints (pixels or percent of image size) as part of a defined technical pipeline.
'[] Applicant submits the record does not establish, by a proper Prong One analysis, that the amended independent claims "recite" a judicial exception.
'Even assuming arguendo that some aspect of "validating" a bill could be characterized at a high level as an abstract concept, the claims as amended integrate any such concept into a practical application by reciting a particular technical solution implemented through specific computerized document-processing operations.
"[] The amended claims recite a particular end-to-end technical pipeline[].
"Independent claim 1 now requires that claims data be acquired in specific non- standardized electronic file types (PDF, binary, text), converted via OCR or insurer- specific extraction programs that use relational spacing to extract information from specific locations within those files, then stored as standardized EOB data in a machine- readable relational format that is not human readable and includes specified EOB fields. Claim 1 further requires converting the provider's unpaid bill into a machine-readable dataset by applying OCR and relative spatial analysis tied to predetermined query terms and measured spatial relationships (pixels or percentage of image size), and then executing the comparison in real time. Claims 7 and 13 include the same technical extraction and standardization limitations, plus the secure-channel payment action conditioned on the validated amount.
'[] The present amendments materially change [] analysis. The amended claims no longer rely on generic "conversion" or "machine-readable dataset" language alone; instead, they specify how conversion and extraction occur (OCR plus relational spacing extraction and OCR plus relative spatial analysis keyed to query terms and pixel/percentage distances), and specify the resulting structured relational EOB data and its field content. Those added limitations meaningfully constrain any alleged abstract concept to a particular technical implementation.
"[] The present amendments expressly add OCR-based extraction, insurer-specific extraction programs using relational spacing, specified heterogeneous file types (PDF, binary, text), and machine-readable relational standardized EOB data. Accordingly, the record now includes claim language [] based on those concrete technical limitations[.]
"[T]he independent claims integrate any alleged judicial exception into a practical application at Step 2A, Prong Two.
'[] Applicant submits the claims are eligible at Step 2A, Prong Two, Step 2B need not be reached. [T]he Office's reliance on cases discussing generic network transmission, generic recordkeeping, and generic "receiving/scanning" activities does not address the amended, specific extraction mechanics now recited (OCR plus relational spacing for insurer-specific extraction from fixed locations within non-standardized formats, and OCR plus relative spatial analysis tied to query terms with pixel/percentage distance constraints). The amended limitations are the claim's "how," and they materially constrain the claim scope beyond a generic instruction to computerize billing.
"In view of the amendments and the specification-supported technical detail now present in the claims, Applicant respectfully submits the present record does not establish ineligibility by a preponderance.
"[T]he independent claims have been amended to recite the concrete technical conversion, extraction, relational structuring, and real-time matching limitations discussed above, the dependent claims ([] further narrow scope) [] in view of the amended independent claims. "
(REMARKS [as abridged], pp. 12-16).
However, the above-quoted arguments submitted January 22, 2026 at REMARKS pp. 12-16 regarding rejections under 35 U.S.C. § 101 have been fully considered, but are not persuasive. Furthermore, the Office respectfully submits that above-quoted arguments are moot in view of the new grounds of rejection which are responsive to Applicant's RCE submission filed January 22, 2026. Substantially, the Office respectfully disagrees with the Applicant's above-quoted factual allegations and legal conclusion. '[T]he "invention" is what is claimed'. Zoltek Corp. v. United States, 672 F.3d 1309, 1318, 102 USPQ2d 1001, 1008 (Fed. Cir. 2012). The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. Contrary to Applicants assertions, all elements within the Applicant's claims were duly considered given their proper weight and attributed with their proper interpretation and applied within the proper tests of the proper factual and legal analyses. Contrary to the Applicant's above-quoted assertions, the Applicant's alleged invention as delineated by the currently pending claims appears to be deeply rooted in the abstract idea. The Applicant's claims do not purport to improve the functioning of the computer itself, or to improve any other technology or technical field, rather "the focus of the claims is not on [] an improvement in computers as tools, but on certain independently abstract ideas that use computers as tools." Electric Power Group, LLC, v. Alstom, 830 F.3d 1350, 1354, 119 U.S.P.Q.2d 1739, 1742 (Fed. Cir. 2016). The Federal Circuit has held that "communicating requests to a remote server and receiving communications from that server, i.e., communication over a network" is itself an abstract idea. See ChargePoint, Inc. v. SemaConnect, Inc., 2019 U.S.P.Q.2d at 108516: "It is clear from the language of claim 1 that the claim involves an abstract idea--namely, the abstract idea of communicating requests to a remote server and receiving communications from that server, i.e., communication over a network. [] We therefore continue our analysis to determine whether the focus of claim 1, as a whole, is the abstract idea. As explained below, we conclude that it is." ChargePoint, Inc. v. SemaConnect, Inc., 2019 U.S.P.Q.2d 108512 (Fed. Cir. 2019).
In response to Applicant's argument that the claimed subject matter provides any improvement to any technology or technical field, the alleged improvement(s) in the abstract idea itself (e.g. a recited fundamental economic concept) is not an improvement in technology. Example(s) that the courts have indicated may not be sufficient to show an improvement in computer-functionality: i. Generating restaurant menus with functionally claimed features, Ameranth, 842 F.3d at 1245, 120 USPQ2d at 1857; ii. Accelerating a process of analyzing audit log data when the increased speed comes solely from the capabilities of a general-purpose computer, FairWarning IP, LLC v. Iatric Sys., 839 F.3d 1089, 1095, 120 USPQ2d 1293, 1296 (Fed. Cir. 2016); iii. Mere automation of manual processes, such as using a generic computer to process an application for financing a purchase, Credit Acceptance Corp. v. Westlake Services, 859 F.3d 1044, 1055, 123 USPQ2d 1100, 1108-09 (Fed. Cir. 2017) or speeding up a loan-application process by enabling borrowers to avoid physically going to or calling each lender and filling out a loan application, LendingTree, LLC v. Zillow, Inc., 656 Fed. App'x 991, 996-97 (Fed. Cir. 2016) (non-precedential); iv. Recording, transmitting, and archiving digital images by use of conventional or generic technology in a nascent but well-known environment, without any assertion that the invention reflects an inventive solution to any problem presented by combining a camera and a cellular telephone, TLI Communications, 823 F.3d at 611-12, 118 USPQ2d at 1747; v. Affixing a barcode to a mail object in order to more reliably identify the sender and speed up mail processing, without any limitations specifying the technical details of the barcode or how it is generated or processed, Secured Mail Solutions, LLC v. Universal Wilde, Inc., 873 F.3d 905, 910-11, 124 USPQ2d 1502, 1505-06 (Fed. Cir. 2017); vi. Instructions to display two sets of information on a computer display in a non-interfering manner, without any limitations specifying how to achieve the desired result, Interval Licensing LLC v. AOL, Inc., 896 F.3d 1335, 1344-45, 127 USPQ2d 1553, 1559-60 (Fed. Cir. 2018); vii. Providing historical usage information to users while they are inputting data, in order to improve the quality and organization of information added to a database, because "an improvement to the information stored by a database is not equivalent to an improvement in the database's functionality," BSG Tech LLC v. Buyseasons, Inc., 899 F.3d 1281, 1287-88, 127 USPQ2d 1688, 1693-94 (Fed. Cir. 2018); viii. Arranging transactional information on a graphical user interface in a manner that assists traders in processing information more quickly, Trading Technologies v. IBG LLC, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019);
Examples that the courts have indicated may not be sufficient to show an improvement to technology include: i. A commonplace business method being applied on a general purpose computer, Alice Corp., 573 U.S. at 223, 110 USPQ2d at 1976; Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015); iii. Gathering and analyzing information using conventional techniques and displaying the result, TLI Communications, 823 F.3d at 612-13, 118 USPQ2d at 1747-48; iv. Delivering broadcast content to a portable electronic device such as a cellular telephone, when claimed at a high level of generality, Affinity Labs of Tex. v. Amazon.com, 838 F.3d 1266, 1270, 120 USPQ2d 1210, 1213 (Fed. Cir. 2016); Affinity Labs of Tex. v. DirecTV, LLC, 838 F.3d 1253, 1262, 120 USPQ2d 1201, 1207 (Fed. Cir. 2016);
In response to applicant's argument that the claim requires an additional element or a combination of additional elements to apply, rely on, or use the judicial exception in a manner that imposes a meaningful limit on the judicial exception, it is noted that the features upon which applicant relies are not recited in the rejected claim(s) (i.e., are not required to present by the broadest reasonable interpretation of the rejected claim(s)). Although the claims are interpreted in light of the specification, limitations from the specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993). For example, the claims do not recite or require "heterogeneous insurer file formats " or "provider-specific extraction" or "heterogeneous, non-standardized healthcare claims and bills".
See Alice Corp., 134 S. Ct. at 2358: 'Stating an abstract idea "while adding the words 'apply it'" is not enough for patent eligibility. Mayo, supra, at ___, 132 S. Ct. 1289, 182 L. Ed. 2d 321, 325. Nor is limiting the use of an abstract idea "'to a particular technological environment.'" Bilski, supra, at 610-611, 130 S. Ct. 3218, 177 L. Ed. 2d 792.' Limitations that the courts have found not to be enough to qualify as "significantly more" when recited in a claim with a judicial exception include adding insignificant extra-solution activity to the judicial exception, e.g., mere data gathering in conjunction with a law of nature or abstract idea such as a step of obtaining information about credit card transactions so that the information can be analyzed by an abstract mental process, as discussed in CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375, 99 USPQ2d 1690, 1694 (Fed. Cir. 2011). For Step 2B, relying on what the courts have recognized, or those in the art would recognize, as elements that are well-understood, routine and conventional, the claims in the present application are ineligible under Step 2B. For example, the courts have recognized the following computer functions to be well-understood, routine, and conventional functions when they are claimed in a merely generic manner: performing repetitive calculations, receiving, processing, and storing data, electronically scanning or extracting data from a physical document, electronic recordkeeping, automating mental tasks, and receiving or transmitting data over a network, e.g., using the Internet to gather data. Courts have held computer-implemented processes not to be significantly more than an abstract idea (and thus ineligible) where the claim as a whole amounts to nothing more than generic computer functions merely used to implement an abstract idea, such as an idea that could be done by a human analog (i.e., by hand or by merely thinking). The Applicant may please refer to and see the current rejection based upon the currently pending claims under the 35 U.S.C. § 101 heading above.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
USPGPub No. US 20190019574 A1 by Byrnes; Michael discloses SYSTEM AND METHOD FOR CREATING AN ELECTRONIC CONSENT-BASED MEDICAL RECORD.
USPGPub No. US 20120022887 A1 by Chiappe; Andrea discloses System and Method for Optimizing Healthcare Remittance Processing.
USPAT No. US 8065162 B1 to Curry; Bry discloses Provider data management and claims editing and settlement system.
USPGPub No. US 20110258004 A1 by DEAN; Tom et al. discloses Reconciliation , Automation and Tagging of Healthcare Information.
USPGPub No. US 20110010189 A1 by Dean; Tom et al. discloses Healthcare Accounts Receiveable Data Valuator.
USPGPub No. US 20170351824 A1 by DeGasperis; William J. discloses Advance payment processing system computer for medical service provider bills.
USPGPub No. US 20100241595 A1 by Felsher; David Paul discloses INFORMATION RECORD INFRASTRUCTURE, SYSTEM AND METHOD.
USPGPub No. US 20030195771 A1 by Fitzgerald, David et al. discloses Healthcare financial data and clinical information processing system.
USPGPub No. US 20030191665 A1 by Fitzgerald, David et al. discloses System for processing healthcare claim data.
USPAT No. US 11461816 B1 to Frens; Jeremy L. et al. discloses Healthcare provider bill validation.
USPAT No. US 10664921 B1 to Frens; Jeremy L. et al. discloses Healthcare Provider Bill Validation And Payment.
USPGPub No. US 20150006198 A1 by Furr; Thomas et al. discloses MANAGING INSTALLMENT PAYMENTS IN A HEALTHCARE SYSTEM.
USPGPub No. US 20020007290 A1 by Gottlieb, Joshua L. discloses On-line system for service provisioning and reimbursement in health systems.
USPGPub No. US 20110258001 A1 by Green, III; W. T. et al. discloses INTEGRATED MEDICAL SOFTWARE SYSTEM WITH LOCATION-DRIVEN BILL CODING.
USPGPub No. US 20070194109 A1 by Harrison; Sarah E. et al. discloses Payment Programs For Healthcare Plans.
USPGPub No. US 20050033604 A1 by Hogan, Brian F. discloses Method and apparatus for settling claims between health care providers and third party payers.
USPGPub No. US 20060047539 A1 by Huang; Paul discloses Healthcare administration transaction method and system for the same.
USPGPub No. US 20070194108 A1 by Kalappa; Ahana M. et al. discloses Assured Payments For Health Care Plans.
USPGPub No. US 20070005402 A1 by Kennedy; Beverly et al. discloses HEALTHCARE SYSTEM AND METHOD FOR REAL-TIME CLAIMS ADJUDICATION AND PAYMENT.
USPGPub No. US 20070005403 A1 by Kennedy; Beverly et al. discloses HEALTHCARE SYSTEM AND METHOD FOR RIGHT-TIME CLAIMS ADJUDICATION AND PAYMENT.
USPGPub No. US 20010034621 A1 by Kirsh, William D. et al. discloses System and method for standardized and automated appeals process.
USPAT No. US 8060382 B1 to Lee; Adam Cheung et al. discloses Method and system for providing a healthcare bill settlement system.
USPGPub No. US 20140379361 A1 by Mahadkar; Shilpak et al. discloses Healthcare Prepaid Payment Platform Apparatuses, Methods And Systems.
USPAT No. US 7979286 B2 to Manning; Michael G. et al. discloses Patient-interactive healthcare management.
USPGPub No. US 20110225006 A1 by Manning; Michael G. et al. discloses PATIENT-INTERACTIVE HEALTHCARE MANAGEMENT.
USPGPub No. US 20090080408 A1 by Natoli; Joseph D. et al. discloses HEALTHCARE SEMANTIC INTEROPERABILITY PLATFORM.
USPGPub No. US 20110166883 A1 by Palmer; Robert D. et al. discloses Systems and Methods for Modeling Healthcare Costs, Predicting Same, and Targeting Improved Healthcare Quality and Profitability.
USPGPub No. US 20060265251 A1 by Patterson; Neal L. discloses Computerized system and methods for adjudicating and reimbursing for healthcare services based on quality.
USPAT No. US 7996239 B1 to Pellican; Suzanne et al. discloses System and method for generating a display to graphically indicate state for a series of events.
USPGPub No. US 20070299699 A1 by Policelli; Thomas et al. discloses System and Method for Initiation of Payment of a Member Cost Portion of Insurance Claim Expenses.
USPGPub No. US 20060161463 A1 by Poonnen; John et al. discloses Method and system for in-process tracking of an operation.
USPGPub No. US 20120239560 A1 by Pourfallah; Stacy S. et al. discloses HEALTHCARE PAYMENT COLLECTION PORTAL APPARATUSES, METHODS AND SYSTEMS.
USPGPub No. US 20110099087 A1 by REINHARDT, JR.; WILLIAM R. discloses HOSGATE.
USPGPub No. US 20140343973 A1 by Ruszala; Anthony C. et al. discloses Computer System for Processing Data From a Plurality of Remote Input Devices for Transmission to a Third-Party Computer.
USPGPub No. US 20070050219 A1 by Sohr; James M. et al. discloses Healthcare claim and remittance processing system and associated method.
USPGPub No. US 20090326974 A1 by Tolan; Mary A. et al. discloses Best possible payment expected for healthcare services.
USPGPub No. US 20150120561 A1 by Ver Hulst; Jay et al. discloses Healthcare Transaction Facilitation Platform Apparatuses, Methods and Systems.
USPGPub No. US 20090138277 A1 by Warren; Catherine et al. discloses Healthcare Transactions Management Solution.
USPGPub No. US 20040204960 A1 by Wood, Richard Glee et al. discloses Method for reducing fraud in healthcare programs using a smart card.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to SLADE E. SMITH whose telephone number is 571- 272-8645. The examiner can normally be reached Monday from 7:30 AM to 5:00 PM.
Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Matthew S. Gart can be reached on 571-272-3955. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000.
Sincerely,
/SLADE E SMITH/Primary Examiner, Art Unit 3696 03/19/2026