Detailed Action
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Acknowledgments
The submission filed on 12/19/25 is acknowledged.
Status of Claims
Claims 1-5, 7-11, 13-18 and 20-23 are pending.
In the Response filed on 12/19/25, claims 1-4, 13-16 and 18 were amended, claims 21-23 were added, and no claims were cancelled (claims 6, 12 and 19 were cancelled in previous papers).
Claims 1-5, 7-11, 13-18 and 20-23 are rejected.
Response to Arguments
Regarding the claim objections
In view of the claim amendments, most of the previous objections are withdrawn. However, Applicant’s attention is directed to the instant objections.
Regarding the rejections under 35 U.S.C. 112
In view of the claim amendments, the rejections are withdrawn.
Regarding the rejections under 35 U.S.C. 101
Applicant's arguments have been fully considered but are not persuasive.
The Office responds to Applicant's arguments below. In the discussion below, page numbers refer to Applicant's response unless otherwise indicated.
Step 2A, prong 1
Initially, it is noted that a significant part of Applicant's remarks constitute discussion of the law and guidance, which is not substantive argument. Specifically, pages 14, 15 (except last paragraph), 16 (first two paragraphs), 18 (penultimate paragraph), and 19 (first full paragraph) constitute such discussion of the law and guidance.
Further, pages 15 (last paragraph), 16 (third paragraph), and 19 (second full paragraph) constitute merely conclusory statements, not substantive argument.
Further, page 16 (4th paragraph) through page 18 (up to the first full paragraph) constitutes merely a recitation of claim 1.
Accordingly, the only substantive argument presented by Applicant is the paragraph bridging pages 18 and 19. Here, Applicant offers the training limitations and the dynamically generating and updating of a display order of messages on a GUI of claim 1 as "not directed to mathematical concepts or certain methods of organizing human activity, as these limitations are rooted in computer software and/or hardware" and as "not a generic computer implementation, but a specific technical solution to the problem of prioritizing and presenting transfer-related messages in a way that adapts to user behavior and transaction history." Pages 18-19.
In response, first the Office notes that, even assuming arguendo that the limitations here cited by Applicant do not constitute (part of) an abstract idea, that would not demonstrate that the claim does not recite (or is not directed to) an abstract idea, since other portions of the claim could recite an abstract idea.
Second, as shown in the rejection, where abstract idea content is indicated by bolding, such limitations as receiving transfer data, analyzing transfer data, and generating, dynamically updating, and displaying product utilization messages comprising value data, as recited in claim 1, constitute an abstract idea of monitoring and managing transactions and presenting messages to a user about the transactions, which falls under the category of certain methods of organizing human activity, specifically, fundamental economic practices or principles and/or commercial or legal interactions. (The GUI, on which the messages are displayed, is a generic computer element.)
Third, the training limitations do indeed constitute an abstract idea of mathematical concepts, which covers mathematical relationships, mathematical formulas or equations, and mathematical calculations. For example, the training limitations include:
(b) … (iii) repeatedly determining, during each iteration of the training and testing loop, the target variable, wherein each iteration of the training and testing loop has differing weights assigned to one or more nodes of the neural network, each of the differing weights being updated with each iteration of the training and testing loop to reduce error in predicting the target variable and improve predictability of the neural network thereby creating a trained neural network, …
This subject matter is comparable to that found ineligible in Recentive1, which was indicated as "mathematical techniques"/"mathematical algorithm,"2 and which was found to be "directed to the abstract idea of using a generic machine learning technique in a particular environment, with no inventive concept."3
Again, this subject matter is comparable to that indicated as mathematical concepts and as ineligible in USPTO Example 47 (claim 2), as also discussed in the USPTO Subject Matter Eligibility Memo issued on 08/04/2025.4
In view of Recentive, Example 47 and the 08/04/2025 memo, the training limitations of claim 1 are abstract idea limitations implemented using generic computer elements (e.g., "processor").
Step 2A, prong 2
Initially, it is noted that a significant part of Applicant's remarks constitute discussion of the law and guidance, which is not substantive argument. Specifically, pages 19 and 20 (except last paragraph) constitute such discussion of the law and guidance.
Further, page 21 (first full paragraph) and 23 (first and second full paragraphs) constitute merely conclusory statements, not substantive argument.
Further, page 21 (last paragraph) through page 23 (up to the first full paragraph) constitutes a recitation of most of claim 1. The conclusory statements before and after this recitation (namely, page 23, first full paragraph, and page 21, first sentence of last paragraph) do not indicate what part of the recitation constitutes the alleged "meaningful limit on the judicial exception," nor how the recitation constitutes the alleged "meaningful limit on the judicial exception." Pages 22-23. Further, regarding page 21, first sentence of last paragraph, this sentence references consideration of claim 1 "as a whole." Page 21. However, Applicant has not indicated what the "as a whole" consideration of claim 1 is supposed to provide, beyond the sum of the individual elements of claim 1, and furthermore, analysis of claim 1 finds no synergy or the like beyond the sum of the individual elements of claim 1.
Further regarding this recitation of most of claim 1, the instant and previous rejections indicate (as shown in bold) what part of claim 1 constitutes the abstract idea, and (as shown in plain font) what part of claim 1 constitutes generic computer elements or mathematical concepts. This analysis of claim 1 provided by the rejections covers the entirety of claim 1, and no "meaningful limit on the judicial exception" is found in claim 1.
Accordingly, the only remaining substantive argument presented by Applicant is (i) the paragraph bridging pages 20 and 21, and (ii) the second full paragraph on page 21.
Let us address each of (i) and (ii) in turn.
(i) As for the paragraph bridging pages 20 and 21, here Applicant cites the same subject matter as was cited in respect of Step 2A, prong 1, as discussed above, specifically, training limitations and the dynamically generating and updating of a display order of messages on a GUI. As per the discussion above in respect of Step 2A, prong 1, the dynamically generating and updating of a display order of messages on a GUI amounts to an abstract idea (monitoring and managing transactions and presenting messages to a user about the transactions, which falls under the category of certain methods of organizing human activity, specifically, fundamental economic practices or principles and/or commercial or legal interactions), applied using a generic computer element (GUI); and, as per Recentive, Example 47 and the Memo issued on 08/04/25, the training limitations amount to an abstract idea (e.g., mathematical concept) implemented using generic computer elements (e.g., "processor").
(ii) As for the second full paragraph on page 21, Applicant writes:
Specifically, the claims provide a technical solution by leveraging a neural [sic] trained on training data including historical transfer data and user activity data, to automatically filter and rank messages, and dynamically [sic] graphical user interfaces based on the filtered and ranked messages. Therefore, the claims recite a technical improvement over conventional systems that merely display or filter messages. The claimed invention uses machine learning to adaptively prioritize and present information, improving the efficiency and relevance of the user interface. Page 21.
The alleged improvement presented here lies in the filtering/ranking/prioritizing of information presented, and as such, is an alleged improvement in the abstract idea, not in the functioning of a computer or in any other technology/technical field. As described above and as recited in claim 1, the additional elements (non-abstract idea content) are merely generic computer elements/technology (e.g., GUI, machine learning) recited at a high level of generality and used off the shelf without any change whatsoever in them or in how they operate, and consequently, without any improvement to them or their functioning.
Step 2B
Initially, pages 23 through 24 (up until the first full paragraph) constitute a conclusory statement (namely, at page 23, first sentence in Step 2B section) and discussion of the law and guidance.
Further, page 24, first full paragraph, is merely conclusory assertion.
At page 24, second full paragraph, Applicant writes:
Applicant respectfully submits that the claimed computer-implemented method is therefore unconventional and advantageously addresses "the drawbacks of traditional techniques for managing resource utilization," by providing "systems and methods that automate the analysis of resource transfer activity and that generate notifications concerning relevant current resource transfer activity, expected future resource transfers, and modifications to optimize ongoing resource utilization and transfer activity. The systems further allow resource utilization to be managed effectively, efficiently, and in a secure fashion using encryption and individual computing device authentication techniques" as explained, in part, in paragraph [0003] of the Specification. Therefore, Applicant respectfully submits that the claims presented herewith are believed patentable under 35 U.S.C. §101. Page 24.
As described above, the claimed invention merely automates analysis of commercial activity and generates notifications, while allegedly also using encryption and authentication of an individual computing device. As such, Applicant and Applicant's specification5 have squarely characterized the claimed invention as applying an abstract idea using generic computer elements. Specifically, the said analysis and notification generation are merely abstract ideas falling under the rubric of commercial/economic practices or the like, while the said automation is a paradigmatic example of 'apply it' using generic computer elements. In addition, the said encryption and authentication of an individual computing device are not seen as recited in claim 1, but if they were recited they would likewise amount to abstract idea content (encryption and authentication) applied using generic computer elements (individual computing device).
Finally, at page 24, penultimate paragraph, through page 25, Applicant argues that the claims are not well-understood, routine and conventional. The Office responds that the claims were not found ineligible on the basis of being well-understood, routine and conventional. Accordingly, Applicant's argument is not germane. Rather, the claims were found ineligible in step 2B based on the fact that they amount to an abstract idea applied using generic computer elements, which precludes eligibility under step 2B: "adding the words 'apply it' (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer" is a "[limitation] that the courts have found not to be enough to qualify as 'significantly more' when recited in a claim with a judicial exception." MPEP 2106.05. (Eligibility Step 2B: Whether a Claim Amounts to Significantly More), I. (THE SEARCH FOR AN INVENTIVE CONCEPT), A.(Relevant Considerations For Evaluating Whether Additional Elements Amount To An Inventive Concept).
Claim Objections
Claim 1 is objected to because of the following informalities:
A) Claim 1 recites:
(b) … (iii) … and output priority data used to control the order and positions of messages in graphical user interfaces, and
…
(c) … (viii) … the order and positions of the product utilization messages in the resource management graphical user interfaces; …
…
(d) … (ix) … (A) … corresponding to the positions and the order defined by the priority data,
The underlined language lacks antecedent basis, as the "order" and "positions" were not previously recited. This is understood to be a clerical oversight. Note the recitations in (c) and (d) are understood to refer back to the recitation in (b) and accordingly would not require change once the recitation in (b) is corrected.
B) Claim 1 recites:
(c) … (ii) detect a specified conditions for the transfer data,
The underlined language is not grammatically correct; "conditions" should be changed to "condition" (see (c) (iii) where the singular is recited). This is understood to be a clerical oversight.
C) Claim 1 recites:
(d) … (v) transmit … (vii) receive, …
As shown above the substeps under step (d) proceed from substep (v) to substep (vii). There is no substep (vi). The substeps should be renumbered in proper numerical order. This is understood to be a clerical oversight.
D) Claim 1 recites:
(d) … (ix) … (B) the plurality of resource management graphical user interfaces comprise a main frame and a graphical widget displayed in a secondary frame adjacent to the centralized main frame, and
The underlined language lacks antecedent basis, as the word "centralized" was deleted in the amendments presented in Applicant's previous response. This is understood to be a clerical oversight. The word "centralized" should be deleted.
Claim 14 is objected to because of the following informalities:
A) Claim 14 recites:
(a) … (ii) detecting a specified conditions for the transfer data,
The underlined language is not grammatically correct; "conditions" should be changed to "condition" (see (a) (iii) where the singular is recited). This is understood to be a clerical oversight.
B) Claim 14 recites:
(a) … (vi) generating … one or more of the product utilization message,
The underlined language is not grammatically correct; "message" should be changed to "messages." This is understood to be a clerical oversight.
C) Claim 14 recites:
(a) … (viii) … wherein the priority data is used to control the order and positions of product utilization messages in graphical user interfaces, …
…
(b) … (vii) … (A) … and priority data,
…
(b) … (vii) … (D) … corresponding to the positions and the order defined by the priority data,
In (a), the underlined language lacks antecedent basis, as the "order" and "positions" were not previously recited. This is understood to be a clerical oversight.
In (b)(vii)(A), it is not clear whether "priority data" refers back to the priority data recited in (a) or not. As best understood, "priority data" recited in (b)(vii)(A) does indeed refer back to the priority data recited in (a). If this understanding is correct, then "priority data" recited in (b)(vii)(A) should be changed to "the priority data."
Note "the positions and the order defined by the priority data" recited in (b)(vii)(D) is understood to refer back to "the order and positions of product utilization messages in graphical user interfaces" recited in (a), and accordingly the recitation in (b)(vii)(D) is not objected to.
Claim 18 is objected to because of the following informalities:
A) Claim 18 recites:
(b) … (iii) … and output priority data used to control the order and positions of product utilization messages in graphical user interfaces, and
…
(c) … (v) … the order and positions of the product utilization messages in the resource management graphical user interfaces; …
…
(d) … (iii) … (B) … corresponding to the positions and the order defined by the priority data, and
The underlined language lacks antecedent basis, as the "order" and "positions" were not previously recited. This is understood to be a clerical oversight. Note the recitations in (c) and (d) are understood to refer back to the recitation in (b) and accordingly would not require change once the recitation in (b) is corrected.
Appropriate correction is required.
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1-5, 7-11, 13-18 and 20-23 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 1-5, 7-11, 13-18 and 20-23 are directed to a system, which are/is one of the statutory categories of invention. (Step 1: YES)
Claims 1, 14 and 18 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. The claims recite a system for training a model to monitor and manage transactions and expenditures including presenting messages to a user.
For claim 1, the limitations (indicated below in bold) of:
(a) a network computing device having a first processor;
(b) a machine-learning software module and training data, wherein the training data comprises historical transfer data and historical user activity data, wherein the machine-learning software module causes the first processor to perform operations comprising:
(i) iteratively training, using the training data, a neural network to generate simulated priority data,
(ii) inserting the training data into an iterative training and testing loop to predict a target variable,
(iii) repeatedly determining, during each iteration of the training and testing loop, the target variable, wherein each iteration of the training and testing loop has differing weights assigned to one or more nodes of the neural network, each of the differing weights being updated with each iteration of the training and testing loop to reduce error in predicting the target variable and improve predictability of the neural network thereby creating a trained neural network, trained to process transfer data and generate priority data for message display, wherein the trained neural network is configured to receive the transfer data and user activity data as input and output priority data used to control the order and positions of messages in graphical user interfaces, and
(iv) deploying the trained neural network;
(c) a first memory device storing data and one or more integrated software applications that, when executed, cause the first processor to:
(i) pass product identification data to a Transfer Activity Database and in return receive the transfer data for a plurality of transfers associated with the product identification data,
(ii) detect a specified conditions for the transfer data,
(iii) when the specified condition is detected, execute a transfer analysis utilizing the transfer data to generate product utilization message data,
(iv) generate a plurality of product utilization messages using the product utilization message data, wherein each product utilization message comprises utilization value data and message sequencing data,
(v) generate transfer instruction parameters display data comprising instructions for generating a Transfer Instruction Parameters graphical user interface, wherein the Transfer Instruction Parameters graphical user interface comprises transfer instruction parameters input fields that include a specified conditions field,
(vi) generate interface display data comprising machine readable instructions for generating a plurality of resource management graphical user interfaces that displays one or more of the product utilization messages, and
(vii) filter the product utilization messages using interface identification data, and
(viii) execute a priority analysis using the trained neural network, wherein the priority analysis processes the product utilization messages, the transfer data, and the user activity data to generate priority data, wherein the priority data is used to dynamically update the order and positions of the product utilization messages in the resource management graphical user interfaces; and
(d) a user computing device comprising a second processor, an integrated display device, and a second memory device storing software code that, when executed by the second processor, cause the second processor to:
(i) receive the transfer instruction parameters display data
(ii) render the Transfer Instruction Parameters graphical user interface on the integrated display device,
(iii) receive a first input from an end user to the specified conditions field, wherein the first input specifies the specified condition, and wherein the first input specifies one or more categories of product utilization messages to be generated and displayed to the end user or a threshold transfer value to trigger the display of one or more of the product utilization messages,
(iv) transmit the specified condition to the network computing device,
(v) transmit an interface display command to the network computing device,
(vii) receive from the network computing device in response to the interface display command, the interface display data, the product utilization messages formatted as JavaScriptObject Notation messages, and the priority data,
(viii) process the interface display data to generate the plurality of resource management graphical user interfaces, and
(ix) render the plurality of resource management graphical user interfaces on the integrated display device, wherein
(A) the second processor causes the resource management graphical user interfaces to simultaneously display the product utilization messages in a position and an order relative to other product utilization messages on the resource management graphical user interfaces corresponding to the positions and the order defined by the priority data,
(B) the plurality of resource management graphical user interfaces comprise a main frame and a graphical widget displayed in a secondary frame adjacent to the centralized main frame, and
(C) the end user can navigate through the plurality of resource management graphical user interfaces using the main frame while the secondary frame continues to display the selected product utilization messages.
as drafted, constitute a process that, under the broadest reasonable interpretation, covers “mathematical concepts” (specifically, the portion of step (b) that is shown in bold above) and "certain methods of organizing human activity," specifically, "fundamental economic practices or principles" and/or "commercial or legal interactions" (specifically, the other content shown in bold above), but for recitation of generic computer components. The Examiner notes that “mathematical concepts” includes mathematical relationships, mathematical formulas or equations, mathematical calculations. MPEP 2106.04(a)(2)I.A.,B.,C. The Examiner notes that "fundamental economic practices" or "fundamental economic principles" describe concepts relating to the economy and commerce, including hedging, insurance, and mitigating risks, and "commercial interactions" or "legal interactions" include agreements in the form of contracts, legal obligations, advertising, marketing or sales activities or behaviors, and business relations. MPEP 2106.04(a)(2)II.A.,B. If a claim limitation, under its broadest reasonable interpretation, covers “mathematical relationships, mathematical formulas or equations, mathematical calculations” or "fundamental economic practices or principles" and/or "commercial or legal interactions," but for recitation of generic computer components, then it falls within the "certain methods of organizing human activity" grouping of abstract ideas. Accordingly, claim 1 recites an abstract idea. (Step 2A - Prong 1: YES. Claim 1 recites an abstract idea.)
For claim 14, the limitations (indicated below in bold) of:
(a) a network computing device, wherein the network computing device comprises one or more integrated software applications that perform operations comprising:
(i) passing product identification data to a Transfer Activity Database and in return receiving transfer data for a plurality of transfers associated with the product identification data,
(ii) detecting a specified conditions for the transfer data,
(iii) executing, when the specified condition is detected, a transfer analysis utilizing the transfer data, wherein the transfer analysis generates product utilization message data,
(iv) generating a plurality of product utilization messages using the product utilization message data, wherein each product utilization message comprises utilization value data and message sequencing data,
(v) generating transfer instruction parameters display data comprising instructions for generating a Transfer Instruction Parameters graphical user interface, wherein the Transfer Instruction Parameters graphical user interface comprises transfer instruction parameters input fields that include a specified conditions field that specifies one or more categories of product utilization messages to display,
(vi) generating interface display data comprising machine readable instructions for generating a plurality of resource management graphical user interfaces that displays one or more of the product utilization message,
(vii) filtering the product utilization messages using interface identification data, wherein one or more product utilization messages are selected for transmission to a user computing device based on the interface identification data, and
(viii) executing, by a neural network, a priority analysis that processes the product utilization messages, the transfer data, and user activity data to generate priority data, wherein the neural network is trained to process the transfer data and generate the priority data for message display, wherein the priority data is used to control the order and positions of product utilization messages in graphical user interfaces, wherein the neural network is trained based on training data comprising historical transfer data and historical user activity data, and
(b) the user computing device comprising an integrated display device, wherein the user computing device performs operations comprising:
(i) receiving transfer instruction parameters display data,
(ii) rendering the Transfer Instruction Parameters graphical user interface on the integrated display device,
(iii) receiving a first input from an end user to the specified conditions field, wherein the first input specifies the specified condition,
(iv) transmitting the specified condition to the network computing device,
(v) receiving from the network computing device, the interface display data, the priority data, and the selected product utilization messages, wherein the one or more product utilization messages selected for transmission are formatted as JavaScript Object Notation messages,
(vi) generating, using the interface display data, a plurality of resource management graphical user interfaces, and
(vii) rendering the plurality of resource management graphical user interfaces on the integrated display device, wherein
(A) the plurality of resource management graphical user interfaces comprises the selected product utilization messages and priority data,
(B) the user computing device displays the selected product utilization messages as graphical widgets integrated with the plurality of resource management graphical user interfaces,
(C) the selected product utilization messages comprise both the utilization value data and the message sequencing data,
(D) the user computing device displays the selected product utilization messages on the plurality of resource management graphical user interfaces in a position and an order relative to other product utilization messages corresponding to the positions and the order defined by the priority data,
(E) the user computing device displays the plurality of resource management graphical user interfaces on the user integrated display device in a main frame, and
(F) the user computing device displays the graphical widgets in a secondary frame adjacent to the main frame such that the end user can navigate through the plurality of resource management graphical user interfaces using the main frame while the secondary frame continues to display the selected product utilization messages.
as drafted, constitute a process that, under the broadest reasonable interpretation, covers "certain methods of organizing human activity," specifically, "fundamental economic practices or principles" and/or "commercial or legal interactions," but for recitation of generic computer components. The Examiner notes that "fundamental economic practices" or "fundamental economic principles" describe concepts relating to the economy and commerce, including hedging, insurance, and mitigating risks, and "commercial interactions" or "legal interactions" include agreements in the form of contracts, legal obligations, advertising, marketing or sales activities or behaviors, and business relations. MPEP 2106.04(a)(2)II.A.,B. If a claim limitation, under its broadest reasonable interpretation, covers "fundamental economic practices or principles" and/or "commercial or legal interactions," but for recitation of generic computer components, then it falls within the "certain methods of organizing human activity" grouping of abstract ideas. Accordingly, claim 14 recites an abstract idea. (Step 2A - Prong 1: YES. Claim 14 recites an abstract idea.)
For claim 18, the limitations (indicated below in bold) of:
(a) a network computing device having a processor;
(b) a machine-learning software module and training data, wherein the training data comprises historical transfer data and historical user activity data, wherein the machine-learning software module causes the first processor to perform operations comprising:
(i) iteratively training, using the training data, a neural network to generate simulated priority data,
(ii) inserting the training data into an iterative training and testing loop to predict a target variable,
(iii) repeatedly determining, during each iteration of the training and testing loop, the target variable, wherein each iteration of the training and testing loop has differing weights assigned to one or more nodes of the neural network, each of the differing weights being updated with each iteration of the training and testing loop to reduce error in predicting the target variable and improve predictability of the neural network thereby creating a trained neural network trained to process transfer data and generate priority data for message display, wherein the trained neural network is configured to receive transfer data and user activity data as input and output priority data used to control the order and positions of product utilization messages in graphical user interfaces, and
(iv) deploying the trained neural network;
(c) a first memory storage device, wherein the memory storage device comprises one or more integrated software applications that, when executed, cause the first processor to perform operations comprising:
(i) passing the product identification data to a Transfer Activity Database and in return receiving transfer data for a plurality of transfers associated with the product identification data,
(ii) executing, by the trained neural network, a transfer predictive analysis utilizing transfer data retrieved from the Transfer Activity Database, wherein:
(A) the transfer predictive analysis generates predictive transfer data associated with one or more expected transfers, and
(B) for each expected transfer, the predictive transfer data comprises (I) expected transfer value data, (II) expected sequencing data, and (III) an expected terminal source identification,
(iii) generating a product utilization messages using the predictive transfer data,
(iv) generating interface display data comprising machine readable instructions for generating a plurality of resource management graphical user interfaces,
(v) executing a priority analysis that processes the product utilization messages, the transfer data, and the user activity data to generate priority data, wherein the priority data is used to dynamically update the order and positions of the product utilization messages in the resource management graphical user interfaces; and
(d) a user computing device comprising a second processor, an integrated display device, and a second memory device storing software code that, when executed by the second processor, cause the second processor to:
(i) transmit an interface display command to the network computing device,
(ii) receive from the network computing device in response to the interface display command, the interface display data, the product utilization message, and the priority data, and
(iii) render the interface display data as a plurality of resource management graphical user interfaces each comprising a main frame and a graphical widget displayed in a secondary frame adjacent to the main frame, wherein:
(A) the second processor displays the product utilization message as a graphical widget in the secondary frame,
(B) the second processor displays a plurality of product utilization message within the secondary frame in a position and an order relative to other product utilization messages corresponding to the positions and the order defined by the priority data, and
(C) an end user can navigate through the plurality of resource management graphical user interfaces using the main frame while the secondary frame continues to display the product utilization messages.
as drafted, constitute a process that, under the broadest reasonable interpretation, covers “mathematical concepts” (specifically, the portion of step (b) that is shown in bold above) and "certain methods of organizing human activity," specifically, "fundamental economic practices or principles" and/or "commercial or legal interactions" (specifically, the other content shown in bold above), but for recitation of generic computer components. The Examiner notes that “mathematical concepts” includes mathematical relationships, mathematical formulas or equations, mathematical calculations. MPEP 2106.04(a)(2)I.A.,B.,C. The Examiner notes that "fundamental economic practices" or "fundamental economic principles" describe concepts relating to the economy and commerce, including hedging, insurance, and mitigating risks, and "commercial interactions" or "legal interactions" include agreements in the form of contracts, legal obligations, advertising, marketing or sales activities or behaviors, and business relations. MPEP 2106.04(a)(2)II.A.,B. If a claim limitation, under its broadest reasonable interpretation, covers “mathematical relationships, mathematical formulas or equations, mathematical calculations” or "fundamental economic practices or principles" and/or "commercial or legal interactions," but for recitation of generic computer components, then it falls within the "certain methods of organizing human activity" grouping of abstract ideas. Accordingly, claim 18 recites an abstract idea. (Step 2A - Prong 1: YES. Claim 18 recites an abstract idea.)
This judicial exception is not integrated into a practical application. Claims 1, 14 and 18 recite the additional elements of (a) a network computing device having a first processor; (b) a machine-learning software module …, wherein the machine-learning software module causes the first processor to perform operations comprising; (iii) … in graphical user interfaces; (iv) deploying the trained neural network; (c) a first memory device storing data and one or more integrated software applications; (i) a Database; (v) [data for generating a] "graphical user interface" [comprising] "input fields"; "machine readable" [instructions for generating] "a plurality of resource management graphical user interfaces"; (viii) in the resource management graphical user interfaces; (d) a user computing device comprising a second processor, an integrated display device, and a second memory device storing software code; (ii) render the Transfer Instruction Parameters graphical user interface on the integrated display device; (iii) … field ...; (iv) … to the network computing device; (v) … to the network computing device; (vii) … from the network computing device …; (viii) [generate] "the plurality of resource management graphical user interfaces"; (ix) render the plurality of resource management graphical user interfaces on the integrated display device; (A) the second processor causes the resource management graphical user interfaces [to display messages] on the resource management graphical user interfaces …; (B) the plurality of resource management graphical user interfaces comprise a main frame and a graphical widget displayed in a secondary frame adjacent to the centralized main frame, and [(C) the end user can navigate through] "the plurality of resource management graphical user interfaces using the main frame" [while] "the secondary frame" [displays messages] (the foregoing recited in claim 1); (a) a network computing device, wherein the network computing device comprises one or more integrated software applications that perform operations; (i) a Database; (v) … [data for generating a] "graphical user interface" [comprising] "input fields" …; (vi) … "machine readable" [instructions for generating] "a plurality of resource management graphical user interfaces" …; (vii) … a user computing device …; (viii) … in graphical user interfaces …; (b) a user computing device comprising an integrated display device, wherein the user computing device performs operations; (ii) rendering the Transfer Instruction Parameters graphical user interface on the integrated display device; (iii) … field …; (iv) … to the network computing device; (v) … from the network computing device …; (vi) generating, using the interface display data, a plurality of resource management graphical user interfaces; (vii) rendering the plurality of resource management graphical user interfaces on the integrated display device; (A) the plurality of resource management graphical user interfaces" …; (B) "the user computing device" [displays messages] "as graphical widgets integrated with the plurality of resource management graphical user interfaces"; "the user computing device" [displays messages] "on the plurality of resource management graphical user interfaces"; "(E) the user computing device displays the plurality of resource management graphical user interfaces on the user integrated display device in a main frame"; "(F) the second processor displays the graphical widgets in a secondary frame adjacent to the main frame" [such that an end user can navigate through] "the plurality of resource management graphical user interfaces using the main frame while the secondary frame" [continues to display messages] (the foregoing recited in claim 14); (a) a network computing device having a processor; (b) a machine-learning software module …, wherein the machine-learning software module causes the first processor to perform operations; (iii) … in graphical user interfaces; (iv) deploying the trained neural network; (c) a first memory storage device, wherein the memory storage device comprises one or more integrated software applications that, when executed, cause the first processor to perform operations; (i) a Database; (ii) a Database; (iv) "machine readable" [instructions for generating] "a plurality of resource management graphical user interfaces"; (v) … in the resource management graphical user interfaces; (d) a user computing device comprising a second processor, an integrated display device, and a second memory device storing software code; (i) … to the network computing device; (ii) … from the network computing device …; (iii) render the interface display data as a plurality of resource management graphical user interfaces each comprising a main frame and a graphical widget displayed in a secondary frame adjacent to the main frame; "(A) the second processor" [displays message] "as a graphical widget in the secondary frame"; "(B) the second processor" [displays message] "within the secondary frame"; (C) [a user can navigate through] "the plurality of resource management graphical user interfaces using the main frame while the secondary frame" [continues to display messages] (the foregoing recited in claim 18), that implement the abstract idea. These additional elements are not described by the applicant and they are recited at a high level of generality (i.e., one or more generic computer elements performing generic computer functions), such that they amount to no more than mere instructions to apply the exception using generic computer elements. Accordingly, even in combination these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. (Step 2A - prong 2: NO. The additional elements do not integrate the abstract idea into a practical application.)
The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception itself. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements of (a) a network computing device having a first processor; (b) a machine-learning software module …, wherein the machine-learning software module causes the first processor to perform operations comprising; (iii) … in graphical user interfaces; (iv) deploying the trained neural network; (c) a first memory device storing data and one or more integrated software applications; (i) a Database; (v) [data for generating a] "graphical user interface" [comprising] "input fields"; "machine readable" [instructions for generating] "a plurality of resource management graphical user interfaces"; (viii) in the resource management graphical user interfaces; (d) a user computing device comprising a second processor, an integrated display device, and a second memory device storing software code; (ii) render the Transfer Instruction Parameters graphical user interface on the integrated display device; (iii) … field ...; (iv) … to the network computing device; (v) … to the network computing device; (vii) … from the network computing device …; (viii) [generate] "the plurality of resource management graphical user interfaces"; (ix) render the plurality of resource management graphical user interfaces on the integrated display device; (A) the second processor causes the resource management graphical user interfaces [to display messages] on the resource management graphical user interfaces …; (B) the plurality of resource management graphical user interfaces comprise a main frame and a graphical widget displayed in a secondary frame adjacent to the centralized main frame, and [(C) the end user can navigate through] "the plurality of resource management graphical user interfaces using the main frame" [while] "the secondary frame" [displays messages] (the foregoing recited in claim 1); (a) a network computing device, wherein the network computing device comprises one or more integrated software applications that perform operations; (i) a Database; (v) … [data for generating a] "graphical user interface" [comprising] "input fields" …; (vi) … "machine readable" [instructions for generating] "a plurality of resource management graphical user interfaces" …; (vii) … a user computing device …; (viii) … in graphical user interfaces …; (b) a user computing device comprising an integrated display device, wherein the user computing device performs operations; (ii) rendering the Transfer Instruction Parameters graphical user interface on the integrated display device; (iii) … field …; (iv) … to the network computing device; (v) … from the network computing device …; (vi) generating, using the interface display data, a plurality of resource management graphical user interfaces; (vii) rendering the plurality of resource management graphical user interfaces on the integrated display device; (A) the plurality of resource management graphical user interfaces" …; (B) "the user computing device" [displays messages] "as graphical widgets integrated with the plurality of resource management graphical user interfaces"; "the user computing device" [displays messages] "on the plurality of resource management graphical user interfaces"; "(E) the user computing device displays the plurality of resource management graphical user interfaces on the user integrated display device in a main frame"; "(F) the second processor displays the graphical widgets in a secondary frame adjacent to the main frame" [such that an end user can navigate through] "the plurality of resource management graphical user interfaces using the main frame while the secondary frame" [continues to display messages] (the foregoing recited in claim 14); (a) a network computing device having a processor; (b) a machine-learning software module …, wherein the machine-learning software module causes the first processor to perform operations; (iii) … in graphical user interfaces; (iv) deploying the trained neural network; (c) a first memory storage device, wherein the memory storage device comprises one or more integrated software applications that, when executed, cause the first processor to perform operations; (i) a Database; (ii) a Database; (iv) "machine readable" [instructions for generating] "a plurality of resource management graphical user interfaces"; (v) … in the resource management graphical user interfaces; (d) a user computing device comprising a second processor, an integrated display device, and a second memory device storing software code; (i) … to the network computing device; (ii) … from the network computing device …; (iii) render the interface display data as a plurality of resource management graphical user interfaces each comprising a main frame and a graphical widget displayed in a secondary frame adjacent to the main frame; "(A) the second processor" [displays message] "as a graphical widget in the secondary frame"; "(B) the second processor" [displays message] "within the secondary frame"; (C) [a user can navigate through] "the plurality of resource management graphical user interfaces using the main frame while the secondary frame" [continues to display messages] (the foregoing recited in claim 18), to perform the noted steps amount to no more than mere instructions to apply the exception using generic computer elements. Mere instructions to apply an exception using generic computer elements cannot provide an inventive concept ("significantly more"). Accordingly, even in combination, these additional elements do not provide significantly more. As such, claims 1, 14 and 18 are not patent eligible. (Step 2B: NO. The claims do not provide significantly more.)
Dependent claims 2-5, 7-11, 13, 15-17 and 20-23 are similarly rejected because they further define/narrow the abstract idea of independent claims 1, 14 and 18 as discussed above, and/or do not integrate the abstract idea into a practical application or provide an inventive concept such as would render the claims eligible, whether each is considered individually or as an ordered combination.
As for further defining/narrowing the abstract idea:
Claim 2 merely describes wherein: (a) the product utilization message data further comprises product identification data; (b) the interface identification data designates an Account Interface GUI for display that is associated with a given product identification; (c) filter the product utilization messages by performing the operations of (i) determining for each product utilization message, whether the product utilization message comprises product identification data that matches the given product identification, and (ii) when the product identification data matches the given product identification, transmitting the product utilization message having matching data ….
Claim 3 merely describes wherein: (a) the interface identification data designates a Homepage GUI for display; (b) the one or more product utilization messages … as utilization message previews comprising category descriptor data and utilization value data.
Claim 4 merely describes wherein: (a) the priority data further comprises expected sequencing data that represents a time that is later than priority data for previous active product utilization messages currently …; (b) the product utilization message … according to the priority data by selecting the position on … the product utilization message, wherein the selected position is closer to the top of … relative to previous active product utilization messages.
Claim 5 merely describes wherein: (a) the priority data for the product utilization message has a higher value than priority data for previous product utilization messages current …; and (b) the product utilization message … according to the priority data by selecting the position on … the product utilization message, wherein the selected position is closer to the top of … relative to previous active product utilization messages.
Claim 10 merely describes wherein the product utilization messages ….
Claims 11 and 17 merely describe a full product utilization message view and a utilization message preview.
Claim 13 merely describes wherein: (a) … executes a transfer predictive analysis utilizing transfer data retrieved from the Transfer Activity …, wherein (i) the transfer predictive analysis generates predictive transfer data associated with one or more expected transfers, and wherein (ii) for each expected transfer, the predictive transfer data comprises (A) expected transfer value data, (B) expected sequencing data, and (C) an expected terminal source identification; and (b) the predictive transfer data is transmitted … with the product utilization message.
Claim 15 merely describes wherein: (a) the priority data comprises expected sequencing data that represents a time that is later than priority data for previous active product utilization messages currently …; and (b) … the selected product utilization messages according to the priority data by selecting a position on … that is closer to a top of … than the previous active product utilization messages.
Claim 16 merely describes wherein: (a) … determines a probability for each product utilization message that the end user will take action in response to viewing the selected product utilization message; (b) … the priority data further based on the probabilities, wherein a higher probability results in a higher priority data value; and (c) the selected product utilization messages having higher priority data values … closer to a top of … relative to selected product utilization messages having a lower probability that the end user will take action in response to viewing the selected product utilization message.
Claim 21 merely describes wherein the historical transfer activity data comprises: (i) one of a plurality of unique user identifiers, (ii) historical resource availability data for each account or product associated with the unique identifier, (iii) a historical value of transferred resources, (iv) a historical timestamp, (v) one of a plurality of unique transaction identifiers, (vi) a historical terminal source identifier, (vii) historical transaction location data, (viii) historical transfer classification data, (ix) a historical average value of products or account balances maintained over a time period, and (x) a historical average number of transactions conducted over the time period.
Claim 22 merely describes wherein the historical user activity data comprises: (i) a historical log of attempts to access provider systems, (ii) a historical browsing history of accessed resources of the provider systems, (iii) historical user input modifying settings, (iv) historical user input comprising selections, (v) a historical log of written communications, (vi) a historical log of support communications, and (vii) historical resource transfer logs.
Claim 23 merely describes wherein the transfer activity data comprises: (i) one of the unique user identifiers, (ii) resource availability data associated with the unique identifier, (iii) a value of transferred resources, (iv) a timestamp, (v) one of the plurality of unique transaction identifiers, (vi) a terminal source identifier, (vii) transaction location data, (viii) transfer classification data, (ix) an average value of products or account balances maintained over a time period, and (x) an average number of transactions conducted over the time period, wherein the user activity data comprises: (i) a log of attempts to access provider systems, (ii) a browsing history of accessed resources of the provider systems, (iii) user input modifying settings, (iv) user input comprising selections, (v) a log of written communications, (vi) a log of support communications, and (vii) resource transfer logs.
As for additional elements:
Claim 2 recites "the executable code further causes the first processor to" perform operations, including transmitting data “to the user computing device for display.” This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claim 3 recites that messages “are displayed by the user computing device.” This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claim 4 recites messages “displayed by the user computing device” and a message “displayed … on a user computing device display screen to display” the message, and indicates a position where message is displayed on the display screen. This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claim 5 recites messages “displayed by the user computing device” and a message “displayed … on a user computing device display screen to display” the message, and indicates a position where message is displayed on the display screen. This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claim 7 recites “wherein the neural network is a recurrent neural network having a long short-term memory neural network architecture.” This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claim 8 recites “wherein the neural network comprises a convolutional neural network having least three intermediate layers.” This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claim 9 recites “wherein the neural network performs operations that implement a Latent Dirichlet Allocation model.” This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claim 10 recites that messages are “displayed as graphical widgets on the user computing device.” This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claims 11 and 17 recite “wherein the graphical widgets include an expansion input function that toggles display of the graphical widget between” two views. This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claim 13 recites “wherein: (a) the network computing device" executes an analysis, data retrieved from a "Database," and data transmitted “to the user computing device for display.” This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claim 15 recites messages “displayed by the user computing device” and “the user computing device displays" messages on "graphical user interfaces" at a certain position on "the integrated display device." This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claim 16 recites "the trained neural network" determines a probability, "the first processor" generates data, and messages “are displayed" at a certain position on "the integrated display device." This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claim 20 recites “wherein the neural network comprises a network architecture selected from one of a (i) LSTM network architecture, (ii) deep-learning, cyclic recurrent neural networks, (iii) Elman recurrent neural network, (iv) convolutional neural network, (v) multilayer perceptron network, (vi) TensorFlow network, (vii) MxNet network, (viii) PyTorch network, (ix) Keras network, or (x) Gluon network.” This recitation is at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer element. Even in combination these additional elements do not integrate the abstract idea into a practical application and do not amount to significantly more than the abstract idea itself.
Claims 21-23 do not recite any additional elements, and accordingly, for the reasons provided above with respect to the independent claims, are not patent eligible.
Therefore, dependent claims 2-5, 7-11, 13, 15-17 and 20-23 are not patent eligible.
Conclusion
The prior art made of record and not relied upon, as set forth in the accompanying Notice of References Cited (PTO-892), is considered pertinent to applicant's disclosure. Among the cited references:
Sayed and Rephlo teach determining forecasted transactions and predicting cash flow;
Ross teaches monitoring balances against thresholds, including notifying users when a balance is to fall below a threshold and recommending corrective action, based on user-defined triggering criteria (parameters);
Fiala teaches tracking cash flows/balances, monitoring the sustainability of income streams and expense needs, projecting future balances, and issuing alerts when account parameters fail to meet criteria, and automatically taking corrective action or making recommendations;
Hart teaches predicting resource events and their timing and notifying a user of an imminent resource event at an optimal time;
Wadley teaches determining optimal resource reallocation based on historical and predicted future resource utilization;
Song teaches preemptively storing past data in a cache for use in subsequent transactions to reduce latency, specifically, capturing identifiers associated with historical data that is likely to be used again, and when a subsequent authorization request message includes an identifier, using the identifier to retrieve historical transaction data to perform the current operation;
Dubey teaches forecasting liquidity and transactions;
Walters teaches preventing missed transactions, specifically, monitoring transaction logs and identifying patterns in historical transaction data, noticing the omission of an upcoming transaction and automatically executing the transaction before an expiration period;
Badger teaches predicting future spending behavior based on historical purchase patterns;
Robinson, Sergay and Shen teach neural networks and various aspects thereof, including for classification and prediction applicable to transactions/financial context.
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any extension fee pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to DOUGLAS W PINSKY whose telephone number is (571)272-4131. The examiner can normally be reached on 8:30 am - 5:30 pm ET.
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/DWP/ /JESSICA LEMIEUX/Examiner, Art Unit 3626 Supervisory Patent Examiner, Art Unit 3626
1 Recentive Analytics, Inc. v. Fox Corp., 134 F.4th 1205 (Fed. Cir. 2025)
2 Recentive Analytics, Inc. v. Fox Corp., Case: 23-2437, pp. 9, 12.
3 Recentive Analytics, Inc. v. Fox Corp., Case: 23-2437, p. 2. See also p. 10: "This case presents a question of first impression: whether claims that do no more than apply established methods of machine learning to a new data environment are patent eligible. We hold that they are not." See also representative claim 1 at issue in Recentive, at p. 3, footnote 2.
4 USPTO Subject Matter Eligibility Example 47, claim 2; USPTO Subject Matter Eligibility Memo issued on 08/04/2025, II. A. "Distinguishing claims that recite a judicial exception from claims that merely involve a judicial exception," p. 3.
5 Note the description Applicant provides in the paragraph quoted here constitutes quotation of the entire substance of paragraph [0003] of the specification.
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