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 .
Claim Status
The claims filed on 8/4/2025 have been entered.
Claims 1-20 are pending.
Claims 1, 10, and 20 are independent.
Claims 1, 10, and 20 are currently amended.
Claims 2-5 and 11-14 are previously presented.
Claims 6-9 and 15-19 are original.
Response to Arguments
Applicant's arguments filed 8/4/2025 have been fully considered but they are not persuasive.
Claim Objections
The prior objections to claims 1 and 10 are withdrawn in view of the current amendments.
35 U.S.C. 101
Applicant’s arguments regarding the rejection of claims 1-20 under 35 U.S.C. 101 as directed to an abstract idea without significantly more have been considered but are not persuasive.
Applicant argues that the claims should be found eligible in view of Example 47 claim 3 of the USPTO Subject Matter Eligibility examples. The argument is not persuasive. Claims 1-20 are not similar to Example 47 eligible claim 3 because they do not recite additional elements which, when considered in combination, integrate the abstract idea into a practical application by providing an improvement in the technical field of network intrusion detection. The present claims are directed to managing shared expenses. They are not analogous to the eligible example claim because they do not recite a comparable technical solution or improvement to the functioning of a computer or other technology such as network intrusion detection. The present claims are more similar to Example 47 ineligible claim 2 because the additional elements are at best (1) mere instructions to “apply” the abstract idea; or (2) merely indicating a field of use or technological environment in which the abstract idea is performed. Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. As such, the claims are ineligible because the additional elements do not integrate the abstract idea into a practical application under Step 2 Prong 2, nor do they provide an inventive concept under Step 2B.
As such, the rejection of claims 1-20 is maintained.
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 an abstract idea without significantly more.
Step 1
Claims 1-20 are each directed to a system (machine), method (process), or non-transitory computer-readable medium (manufacture), and fall within one of the statutory categories of invention. (Step 1: YES).
Step 2A Prong 1
The Examiner has identified independent system claim 1 as the claim that represents the claimed invention for analysis and is similar to independent method claim 10 and independent product claim 20. Claim 1 recites the limitations of:
1. [A system for] updating a learning engine to improve detection accuracy, comprising:
[a storage device storing instructions and a learning engine configured to (i) electronically] collect and store transaction data from a plurality of users and (ii) determine and update patterns and thresholds used to automatically detect recurring shared expenses, wherein the transaction data comprises a plurality of transactions associated with the plurality of users, and wherein each transaction of the plurality of transactions is categorized into one or more of a plurality of transaction categories; and
[at least one processor configured to execute the instructions to] perform operations comprising:
detecting a first transaction associated with a first user of the plurality of users that has been categorized into a first transaction category of the plurality of transaction categories,
determining, [using the learning engine], that the first transaction comprises a potential recurring shared expense based on the first transaction exceeding a transaction category threshold for the first transaction category and previous transactions associated with the first user that were categorized into the first transaction category, the thresholds comprising the transaction category threshold;
identifying a set of potential users associated with the potential recurring shared expense;
receiving, from a user [device associated with the first user], a confirmation indicating that (i) the potential recurring shared expense corresponds to a recurring shared expense and (ii) one or more users are to be removed from the set of potential users;
updating, based on the confirmation, the patterns and thresholds [of the learning engine] including updating the transaction category threshold to an updated transaction category threshold and removing the one or more users from the set of potential users to obtain a set of request recipients associated with the recurring shared expense;
for each request recipient of the set of request recipients;
determining, [using the learning engine], an advance time for sending a request for payment to the request recipient to provide a requested share amount, the advance time being determined based on information associated with the request recipient, a number of reminders transmitted to the request recipient in association with a previous transaction of the previous transactions corresponding to the recurring shared expense, and a penalty shared by each of a plurality of individuals for a late payment of the recurring shared expense; and
transmitting the request for the payment to [a device associated] with the request recipient indicating the requested share amount, at a time prior to a due date of the recurring shared expense based on the advance time, wherein an additional instance of the request for payment is transmitted to the device responsive to detecting a second transaction comprising the potential recurring shared expense based on the second transaction exceeding the updated transaction category threshold.
These limitations, under their broadest reasonable interpretation, cover performance of the limitation as “Certain Methods of Organizing Human Activity”. The claim limitations delineated in bold above recite a fundamental economic practice because they pertain to shared expense management. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation as a fundamental economic practice, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea. The storage device, learning engine, processor, user device, and device associated with the request recipient in Claim 1 is just applying generic computer components to the recited abstract limitations. The recitation of generic computer components in a claim does not necessarily preclude that claim from reciting an abstract idea. Claims 10 and 20 are also abstract for similar reasons. (Step 2A-Prong 1: YES. The claims recite an abstract idea)
Step 2A Prong 2
This judicial exception is not integrated into a practical application. In particular, the claims recite the additional elements of:
Claim 1: storage device, learning engine, processor, user device, device associated with the request recipient
Claim 10: learning engine, user device, device associated with the request recipient
Claim 20: computer-readable storage medium, one or more processors, learning engine, user device, device associated with the request recipient
The computer hardware/software is/are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function) such that it amounts no more than mere instructions to apply the exception using a generic computer component. MPEP 2106.05(f).
With regards to updating and using the learning engine, the claim only recites the idea of a solution or outcome and fails to recite how the solution to the problem is accomplished. Furthermore, these elements are described at a high level of generality in Applicant’s specification without any meaningful detail about its structure or configuration (see e.g., para. 0041). These limitations merely invoke the additional element as a tool to perform the abstract idea. As demonstrated by the specification, the claimed invention does not improve machine learning itself, but merely describes the features at a high level of generality as an implementation tool for performing the abstract idea. Here, the disclosure does not provide sufficient detail such that one of ordinary skill in the art would recognize the claimed invention as providing an improvement to the functioning of the computer or to any other technology or technical field. MPEP 2106.04(d)(1). Thus, even considering this limitation, the use of the processor still merely amounts to adding the words “apply it” (or an equivalent) with the judicial exception. MPEP 2106.05(f).
Furthermore, the recitation of “using the learning engine” merely indicates a field of use or technological environment in which the judicial exception is performed. This type of limitation merely confines the use of the abstract idea to a particular technological environment (machine learning models) and thus fails to provide a practical application. MPEP 2106.05(h).
Accordingly, these additional elements, when considered separately and as an ordered combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea and are at a high level of generality. Therefore, claims 1, 10, and 20 are directed to an abstract idea without a practical application. (Step 2A-Prong 2: NO. The additional claimed elements are not integrated into a practical application)
Step 2B
The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when considered separately and as an ordered combination, they do not add significantly more (also known as an “inventive concept”) to the exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional element of using a computer hardware amounts to no more than mere instructions to apply the exception using a generic computer component. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. See Applicant’s specification para. [0029-0031], [0037-0038] about implementation using general purpose or special purpose computing devices and MPEP 2106.05(f) where applying a computer as a tool is not indicative of significantly more. Additionally, as discussed above, the recitation of “using the learning engine” merely indicates a field of use or technological environment in which the judicial exception is performed. This type of limitation merely confines the use of the abstract idea to a particular technological environment (machine learning models) and thus fails to provide an inventive concept. MPEP 2106.05(h).
Furthermore, no additional element or combination of elements are other than what is well-understood, routine, conventional activity in the field. The additional elements simply append well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception, per MPEP § 2106.05(d). Specifically, it is well-understood, routine, and conventional, to use a learning engine to produce outputs given a set of input data. Evidence of this includes:
Applicant’s Specification [0041] … Server 111 may employ one or more regression algorithms, clustering algorithms, or other known data analysis techniques to analyze collected data. Learning engine 254 may employ such data analysis and crowd-sourcing techniques to learn new patterns and thresholds in transaction data indicative of shared expenses versus individual, non-shared expenses.
Anand (US 2005/0225552 A1) [0154] The techniques for specifying and training a neural net is well known in the art of artificial intelligence (AI)….Typically, a neural net is specified by defining input and output parameters, number of layers, and number of neurons in each layer. A neural net can be thought of as a trainable nonlinear mapping between input parameters and output variables.
Accordingly, these additional elements, do not change the outcome of the analysis, when considered separately and as an ordered combination. Thus, claims 1, 10, and 20 are not patent eligible. (Step 2B: NO. The claims do not provide significantly more)
Dependent Claims
Dependent claims 2-9 and 11-19 further define the abstract idea that is present in their respective independent claims 1 and 10 and thus correspond to “Certain Methods of Organizing Human Activity” and hence are abstract for the reasons presented above. The dependent claims do not include any additional elements that integrate the abstract idea into a practical application or are sufficient to amount to significantly more than the judicial exception when considered both individually and as an ordered combination. Therefore, the dependent claims are directed to an abstract idea without significantly more. Thus, claims 1-20 are not patent-eligible.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Teckchandani (US 2010/0121745 A1) discloses systems and methods for facilitating sharing of expenses over a network utilize a first component adapted to communicate with members of a user group via a client device over the network and a merchant via a merchant device over the network. The systems and methods for facilitating sharing of expenses over a network further utilize a second component adapted to receive a group transaction request from the user group, divide a payment for the group transaction request into a plurality of portions according to a number of members in the user group, separately debit the portions of the payment from one or more accounts related to each member of the user group, and provide payment to the merchant via the merchant device based on information passed with the group transaction request.
THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ERIC T WONG whose telephone number is (571)270-3405. The examiner can normally be reached 9am-5pm M-F.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Michael W Anderson can be reached at 571-270-0508. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/ERIC T WONG/Primary Examiner, Art Unit 3693
ERIC WONG
Primary Examiner
Art Unit 3693