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 . In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. The applicant's submission, the “AMENDMENT AND RESPONSE TO FINAL OFFICE ACTION” of 09 March 2026 (hereinafter referred to as the “Amendment/Response”), has been entered.
Status of the Claims
The pending claims in the present application are claims 1-4, 6, 9-14, 16, 19, and 20 of the Amendment/Response.
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 1-4, 6, 9-14, 16, 19, and 20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. The paragraphs below provide rationales for the rejection. The rationales are based on the multi-step subject matter eligibility test outlined in MPEP 2106.
Step 1 of the eligibility analysis involves determining whether a claim falls within one of the four enumerated categories of patentable subject matter recited in 35 USC 101. (See MPEP 2106.03(I).) That is, Step 1 asks whether a claim is to a process, machine, manufacture, or composition of matter. (See MPEP 2106.03(II).) Referring to the pending claims, the “device” of claims 1-4, 6, 9, and 10 constitutes a machine under 35 USC 101, and the “method” of claims 11-14, 16, 19, and 20 constitutes a process under the statute. Accordingly, claims 1-4, 6, 9-14, 16, 19, and 20 meet the criteria of Step 1 of the eligibility analysis. The claims, however, fail to meet the criteria of subsequent steps of the eligibility analysis, as explained in the paragraphs below.
The next step of the eligibility analysis, Step 2A, involves determining whether a claim is directed to a judicial exception. (See MPEP 2106.04(II).) This step asks whether a claim is directed to a law of nature, a natural phenomenon (product of nature) or an abstract idea. (See id.) Step 2A is a two-prong inquiry. (See MPEP 2106.04(II)(A).) Prong One and Prong Two are addressed below.
In the context of Step 2A of the eligibility analysis, Prong One asks whether a claim recites an abstract idea, law of nature, or natural phenomenon. (See MPEP 2106.04(II)(A)(1).) Using claim 1 as an example, the claim recites the following abstract idea limitations:
“... store a plurality of contacts; and ...” - See below regarding MPEP 2106.04(a), certain methods of organizing human activity, and mental processes
“... display the plurality of contacts ...” - See below regarding MPEP 2106.04(a), certain methods of organizing human activity, and mental processes
“... receive a first user input for selecting one contact from among the plurality of contacts; and ...” - See below regarding MPEP 2106.04(a), certain methods of organizing human activity, and mental processes
“... display at least one piece of activity information related to the selected contact and contact history information related to the selected contact ..., based on the first user input, ...” - See below regarding MPEP 2106.04(a), certain methods of organizing human activity, and mental processes
“... wherein each of the at least one piece of activity information includes an activity name, schedule information, place information, asset information, and grade information related to the selected contact, ...” - See below regarding MPEP 2106.04(a), certain methods of organizing human activity, and mental processes
“... wherein the asset information includes information on income and expenditure breakdowns related to the at least one piece of activity information, ...” - See below regarding MPEP 2106.04(a), certain methods of organizing human activity, and mental processes
“... display one or more other contacts connected to the selected contact who have performed one or more activities with the selected contact in a conduct area ... where the at least one piece of activity information is displayed; ...” - See below regarding MPEP 2106.04(a), certain methods of organizing human activity, and mental processes
“... identify, based on a financial transfer being identified ..., a counterpart of the financial transfer; ...” - See below regarding MPEP 2106.04(a), certain methods of organizing human activity, and mental processes
“... identify, based on the identified counterpart corresponding to the selected contact, activity information related to the selected contact based on the financial transfer; and ...” - See below regarding MPEP 2106.04(a), certain methods of organizing human activity, and mental processes
“... register the financial transfer in information on income and expenditure breakdowns of the identified activity information, ...” - See below regarding MPEP 2106.04(a), certain methods of organizing human activity, and mental processes
“... wherein the identifying of the counterpart of the financial transfer includes: ... when the financial transfer is identified from the financial application and the counterpart of the identified financial transfer is not identified among the plurality of contacts, ... inputting information on the financial transfer; and ...” - See below regarding MPEP 2106.04(a), certain methods of organizing human activity, and mental processes
“... identifying information on the counterpart of the financial transfer based on the information input ...” - See below regarding MPEP 2106.04(a), certain methods of organizing human activity, and mental processes
“... wherein the one or more other contacts are displayed in descending order based on the number of times each of the one or more other contacts has performed the one or more activities with the selected contact.” - See below regarding MPEP 2106.04(a), certain methods of organizing human activity, and mental processes
The above-listed limitations of claim 1, when applying their broadest reasonable interpretations in light of their context in the claim as a whole, fall under enumerated groupings of abstract ideas outlined in MPEP 2106.04(a). For example, limitations of the claim can be characterized as: fundamental economic principles or practices, including managing financial information about various entities, or bookkeeping; commercial interactions, including banking activities or behaviors, involving monitoring financial transactions and maintaining associated records; and managing personal behavior or relationships or interactions between people, including social activities among users and their contacts, which fall under the certain methods of organizing human activity grouping of abstract ideas (see MPEP 2106.04(a)). Limitations of the claim also can be characterized as: concepts performed in the human mind, including observation (e.g., the recited “store” and “receive” steps), and evaluation, judgment, and/or opinion (e.g., the recited “display,” “identify,” “register,” “displaying,” “identifying,” and “displayed” steps), which fall under the mental processes grouping of abstract ideas (see MPEP 2106.04(a)). Accordingly, for at least these reasons, claim 1 fails to meet the criteria of Step 2A, Prong One of the eligibility analysis.
In the context of Step 2A of the eligibility analysis, Prong Two asks if the claim recites additional elements that integrate the judicial exception into a practical application. (See MPEP 2106.04(II)(A)(2).) Continuing to use claim 1 as an example, the claim recites the following additional element limitations:
“An electronic device comprising: a display; a storage configured to ...; and a processor, wherein the processor is configured to: ...” - See below regarding MPEP 2106.05(a)-(c) and (f)-(h)
The claimed “contacts” are “on the display” - See below regarding MPEP 2106.05(a)-(c) and (f)-(h)
The claimed “selected contact” is “on the display” - See below regarding MPEP 2106.05(a)-(c) and (f)-(h)
“... wherein the processor is further configured to: ...” - See below regarding MPEP 2106.05(a)-(c) and (f)-(h)
The claimed “conduct area” is “of the display” - See below regarding MPEP 2106.05(a)-(c) and (f)-(h)
The claimed “identified” is “from a financial application” - See below regarding MPEP 2106.05(a)-(c) and (f)-(h)
“... displaying ... a popup window” - See below regarding MPEP 2106.05(a)-(c) and (f)-(h)
The claimed “input” is “through the popup window” - See below regarding MPEP 2106.05(a)-(c) and (f)-(h)
The above-listed additional element limitations of claim 1, when applying their broadest reasonable interpretations in light of their context in the claim as a whole, are analogous to: mere automation of manual processes, 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, and arranging transactional information on a graphical user interface in a manner that assists traders in processing information more quickly, which courts have indicated may not be sufficient to show an improvement in computer-functionality (see MPEP 2106.05(a)(I)); a commonplace business method being applied on a general purpose computer, gathering and analyzing information using conventional techniques and displaying the result, and selecting a particular generic function for computer hardware to perform from within a range of fundamental or commonplace functions performed by the hardware, which courts have indicated may not be sufficient to show an improvement to technology (see MPEP 2106.05(a)(II)); a general purpose computer that applies a judicial exception, such as an abstract idea, by use of conventional computer functions, and merely adding a generic computer, generic computer components, or a programmed computer to perform generic computer functions, which do not qualify as a particular machine or use thereof (see MPEP 2106.05(b)(I)); a machine that is merely an object on which the method operates, which does not integrate the exception into a practical application (see MPEP 2106.05(b)(II)); use of a machine that contributes only nominally or insignificantly to the execution of the claimed method, which does not integrate a judicial exception (see MPEP 2106.05(b)(III)); transformation of an intangible concept such as a contractual obligation or mental judgment, which is not likely to provide significantly more (see MPEP 2106.05(c)); remotely accessing user-specific information through a mobile interface and pointers to retrieve the information without any description of how the mobile interface and pointers accomplish the result of retrieving previously inaccessible information, which courts have found to be mere instructions to apply an exception, because they recite no more than an idea of a solution or outcome (see MPEP 2106.05(f)); use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) or simply adding a general purpose computer or computer components after the fact to an abstract idea, a commonplace business method or mathematical algorithm being applied on a general purpose computer, generating a second menu from a first menu and sending the second menu to another location as performed by generic computer components, and requiring the use of software to tailor information and provide it to the user on a generic computer, which courts have found to be mere instructions to apply an exception, because they do no more than merely invoke computers or machinery as a tool to perform an existing process (see MPEP 2106.05(f)); mere data gathering in the form of obtaining information about transactions using the Internet to verify transactions and consulting and updating an activity log, and selecting a particular data source or type of data to be manipulated in the form of selecting information, based on types of information and availability of information in an environment, for collection, analysis, and display, which courts have found to be insignificant extra-solution activity (see MPEP 2106.05(g)); and specifying that the abstract idea of monitoring audit log data relates to transactions or activities that are executed in a computer environment, because this requirement merely limits the claims to the computer field, i.e., to execution on a generic computer, which courts have described as merely indicating a field of use or technological environment in which to apply a judicial exception (see MPEP 2106.05(h)). For at least these reasons, claim 1 fails to meet the criteria of Step 2A, Prong Two of the eligibility analysis.
The next step of the eligibility analysis, Step 2B, asks whether a claim recites additional elements that amount to significantly more than the judicial exception. (See MPEP 2106.05(II).) The step involves identifying whether there are any additional elements in the claim beyond the judicial exceptions, and evaluating those additional elements individually and in combination to determine whether they contribute an inventive concept. (See id.) The ineligibility rationales applied at Step 2A, Prong Two, also apply to Step 2B. (See id.) For all of the reasons covered in the analysis performed at Step 2A, Prong Two, claim 1 fails to meet the criteria of Step 2B. Further, claim 1 also fails to meet the criteria of Step 2B because at least some of the additional elements are analogous to: electronic recordkeeping, and storing and retrieving information in memory, which courts have recognized as well-understood, routine, conventional activity, and as insignificant extra-solution activity (see MPEP 2106.05(d)(II)). As a result, claim 1 is rejected under 35 USC 101 as ineligible for patenting.
Regarding pending claims 2-4, 6, 9, and 10, the claims depend from claim 1, and expand upon limitations introduced by claim 1. The dependent claims are rejected at least for the same reasons as claim 1. For example, the dependent claims recite abstract idea elements similar to the abstract idea elements of claim 1, that fall under the same abstract idea groupings as the abstract idea elements of claim 1 (e.g., the “wherein each of the at least one piece of activity information is a planned activity or a performed activity, and wherein if the piece of activity information is the performed activity, the piece of activity information includes edges having a specific color” of claim 2, the “wherein if the piece of activity information is the planned activity, the piece of activity information does not include edges” of claim 3, the “wherein if activity information related to the selected contact includes a plurality of pieces of activity information, ... further display an average value of grade information of the plurality of pieces of activity information” of claim 4, the “a second user input for generating new activity information related to the selected contact” of claim 6, the “further display personal information of the selected contact based on the first user input, and wherein the personal information includes a name, a phone number, a photo, and propensity information of the selected contact” of claim 9, and the “further display latest news information related to the selected contact based on the first user input” of claim 10). The dependent claims recite further additional elements that are similar to the additional elements of claim 1, that fail to warrant eligibility for the same reasons as the additional elements of claim 1 (e.g., the “electronic device” of claims 2-4, 6, 9, and 10, the “processor is configured to further” of claims 4, 6, 9, and 10, and the “display a activity generation screen on the display” of claim 6). Accordingly, claims 2-4, 6, 9, and 10 also are rejected as ineligible under 35 USC 101.
Regarding pending claims 11-14, 16, 19, and 20, while the claims are of different scope relative to claims 1-4, 6, 9, and 10, the claims recite limitations similar to the limitations of claims 1-4, 6, 9, and 10. As such, the rejection rationales applied to reject claims 1-4, 6, 9, and 10 also apply for purposes of rejecting claims 11-14, 16, 19, and 20. Claims 11-14, 16, 19, and 20 are, therefore, also rejected as ineligible under 35 USC 101.
Claim Rejections - 35 USC § 103
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
1. Determining the scope and contents of the prior art.
2. Ascertaining the differences between the prior art and the claims at issue.
3. Resolving the level of ordinary skill in the pertinent art.
4. Considering objective evidence present in the application indicating obviousness or nonobviousness.
Claims 1, 6, 9, 10, 11, 16, 19, and 20 are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Pat. App. Pub. No. 2016/0350868 A1 to Votaw et al. (hereinafter referred to as “Votaw”), in view of U.S. Pat. App. Pub. No. 2014/0006275 A1 to Hanson et al. (hereinafter referred to as “Hanson”), in view of U.S. Pat. App. Pub. No. 2014/0108562 A1 to Panzer (hereinafter referred to as “Panzer”).
Regarding claim 1, the combination of Votaw, Hanson, and Panzer (hereinafter referred to as “Votaw/Hanson/Panzer”) teaches the following limitations:
“An electronic device comprising: a display; ...” - Votaw discloses, “display the integrated financial and social networking activity interface to the user on a display of a user computer system” (para. [0008]), and “The first user computer system 20 may be a desktop, laptop, tablet, mobile device (e.g., smartphone device, PDA, phone, or other like mobile device), or any other type of computer” (para. [0181]). The user computer system having the display, in Votaw, reads on the recited limitation.
“... a storage configured to store a plurality of contacts; and ...” - Votaw discloses, “determining that the primary user has a relationship with the user, based on analyzing social networking contacts of the primary user” (para. [0011]), and “the memory device 36 includes a datastore 39 for storing data related to the social networking systems 30, including but not limited to data created and/or used by the social networking application 37” (para. [0184]). The memory device for storing data used by the social networking application, including social network contacts of users, in Votaw, reads on the recited limitation.
“... a processor, wherein the processor is configured to: ...” - Votaw discloses, “computer program instructions may be provided to a processor of a general purpose computer, special purpose computer, or other programmable data processing apparatus to produce a particular machine, such that the instructions, which execute via the processor of the computer or other programmable data processing apparatus, create mechanisms for implementing the functions/acts specified in the flowchart and/or block diagram block or blocks” (para. [0213]).
“... display the plurality of contacts on the display; ...” - Votaw discloses, “As such, the financial and social management system 1 may access the first user's social networking account to determine if the other users are listed as contacts (e.g., friends, followers, family, co-workers, or the like) within the social networking accounts, in order to determine the other users (e.g., the second user 6, the third user, or the like) that may be associated with the activity at the entity. In other embodiments, the financial and social management system 1 may identify users that were tagged at the same or similar locations, or in images taken or uploaded at the same time as the activity in order to determine other users to associate with the activity” (para. [0068]), “contacts may also be identified through the user's contact lists in the user's e-mail accounts, contacts lists in the user's mobile devices, or other contact lists. In addition to capturing images associated with the contacts in the contact lists, other activity information about the contacts from the contact lists may also be utilized by the financial and social management system 1” (para. [0079]), “ENTITY 1,” “USER 2,” “ENTITY 2” (FIG. 7), and “USER 4,” “USER 5,” and “USER 6” (FIG. 13).
“... receive a first user input for selecting one contact from among the plurality of contacts; and ...” - Votaw discloses, “As illustrated by block 606 of FIG. 6A, the financial and social management system 1 receives an indication from a user (e.g., first user 4) to filter activities by one or more users and display the filtered activities in an activity social relationship interface 800 as illustrated in FIG. 8. The activity social relationship interface 800 may comprise a navigation bar, a social relationship image section 810, a relationship section 820 (e.g., word block, location map, or the like), and an activity list section 830. A social relationship header 802 may also be provided in the social relationship interface 800 illustrating the one or more users included in the social relationship interface 800. As illustrated in the social relationship header 802 of FIG. 8, only activities associated with a single user (e.g., USER 2) are displayed” (para. [0112]). Receiving the indication from the user to filter by users, in Votaw, reads on the recited limitation.
“... display at least one piece of activity information related to the selected contact and contact history information related to the selected contact on the display, based on the first user input, ...” - See the aspects of Votaw that have been cited above. Votaw also discloses, “With respect to the activity list section 830 the activity list is filtered to only display activities associated with one or more users” (para. [0115]). Displaying activities associated with the user after filtering, including the user’s interactions with the user of the system, in Votaw, reads on the recited limitation.
“... wherein each of the at least one piece of activity information includes an activity name, schedule information, place information, asset information, and grade information related to the selected contact, ...” - See the aspects of Votaw that have been cited above. The “MONEY SPENT,” “JUNE 10, XXXX,” “07:50 PM,” “CITY 1, STATE 1,” “$200.00,” and “INCOME” in Votaw (FIG. 8), reads on the recited limitation.
“... wherein the asset information includes information on income and expenditure breakdowns related to the at least one piece of activity information, ...” - See the aspects of Votaw that have been cited above. The “INCOME,” “$200.00,” “FAST FOOD,” and “-$8.68” in Votaw (FIG. 8), reads on the recited limitation.
“... wherein the processor is further configured to: display one or more other contacts connected to the selected contact who have performed one or more activities with the selected contact in a conduct area of the display where the at least one piece of activity information is displayed; ...” - See the aspects of Votaw that have been cited above. Votaw shows “YOUR HISTORY WITH USER 2” and activities involving “COFFEE SHOPS” that took place “WITH 2 FRIENDS” in FIG. 8. The displaying of information about friends connected to users who have visited coffee shops with the users in listings of activities where multiple activities are displayed, in Votaw, reads on the recited limitation. Additionally or alternatively, the displaying of interfaces for the platform, for accounts of users and their friends, wherein each of the users and friends can view their own data within the interfaces, and the data is related due to the users being friends and attending activities together, also reads on the recited limitation.
“... identify, based on a financial transfer being identified from a financial application, a counterpart of the financial transfer; ...” - See the aspects of Votaw that have been cited above. Identifying payments by multiple users that are friends (e.g., the main user, “User 2,” and the “2 FRIENDS”) and that attended the same activity together, wherein the payments appears on an interface like the one in FIG. 8 of Votaw, reads on the recited limitation. Payments from various parties for the same event are counterpart financial transfers.
“... identify, based on the identified counterpart corresponding to the selected contact, activity information related to the selected contact based on the financial transfer; and ...” - See the aspects of Votaw that have been cited above. The identification of payments by friends that occur around the time of, or in the same place as, activities and associated payments by suers, in Votaw, reads on the recited limitation.
“... register the financial transfer in information on income and expenditure breakdowns of the identified activity information, ...” - See the aspects of Votaw that have been cited above. The “INCOME,” “$200.00,” “FAST FOOD,” and “-$8.68” in Votaw (FIG. 8), reads on the recited limitation.
“... wherein the identifying of the counterpart of the financial transfer includes: displaying, when the financial transfer is identified from the financial application and the counterpart of the identified financial transfer is not identified among the plurality of contacts, a popup window for inputting information on the financial transfer; and ...” - Votaw does not appear to disclose identifying financial transactions and associated use of pop-up windows. Hanson discloses, “Since the third party that manages the user's mobile wallet aggregates all of the daily mobile wallet purchases and reports such purchases to the user's financial institution as one aggregate, daily transaction, at block 810 the transaction apparatus automatically determines that there is not a match between the daily number of transaction and the number of banking record entries. Accordingly, at block 812 the discrepancy apparatus 803 notifies the User that there is a discrepancy with the user's banking records. As indicated at block 814, the discrepancy apparatus notifies the User by displaying an indication on the display of mobile phone 801” (para. [0097]), “RECEIVE DAILY NUMBER OF TRANSACTIONS” and “AUTOMATICALLY COMPARE DAILY NUMBER OF TRANSACTIONS TO NUMBER OF BANKING RECORD ENTRIES” (FIG. 8), and “At block 814, the indication that is displayed on mobile phone 801 may be any type of indication. In the embodiment of the invention depicted at block 814, the indication appears as a pop up window on the display of mobile phone 801 notifies the User that there is a discrepancy with the user's banking records. The pop-up window indicates that the daily number of transactions differs from the number of banking record entries and also contains hyperlinks to allow the User to contact his financial institution, as well as submit additional information to help reconcile the discrepancy” (para. [0098]). Identifying related transactions and banking record entries, displaying, when there are discrepancies between the transactions and the record entries, the pop-up window to allow the user to submit additional information to help reconcile the discrepancies, in Hanson, reads on the recited limitation.
“... identifying information on the counterpart of the financial transfer based on the information input through the popup window, and ...” - See the aspects of Hanson that have been cited above. Identifying information on the transactions and/or the record entries based on the user submitted additional information, entered via the pop-up window, in Hanson, reads on the recited limitation.
“... wherein the one or more other contacts are displayed in descending order based on the number of times each of the one or more other contacts has performed the one or more activities with the selected contact.” - Votaw does not appear to disclose ordering of how contacts are displayed based on frequency. Panzer discloses, “The interaction levels describe a level of interaction between the first user and the related users of the cluster. The system ranks the cluster of related users based on the interaction levels” (para. [0003]), “The ranking module 208 can rank the users of a cluster identified by the cluster processor 204. The ranking module 208 is coupled to the cluster processor 204 to receive a ranking signal, and responsive thereto, to rank the users of a cluster identified by the ranking signal. In some implementations, information about the cluster is included with the ranking signal. In other implementations, the ranking module 208 retrieves information about the cluster from the data store 224, as stored by the cluster processor 204. The ranking module 208 can rank the users of a cluster based on their interaction level. Each user's interaction level reflects the level of his/her participation in the conversation or conversations reflected by the one or more electronic messages that the cluster of related users was identified from by the cluster processor 204. The more a user participated in the conversation or conversations, the higher that user is ranked relative to the other users of the cluster” (para. [0071]). The ranking of users of a cluster based on the levels of interaction between one user and the other users, in Panzer, reads on the recited limitation.
Hanson discloses electronic banking processes (Abstract), similar to the claimed invention and to Votaw. It would have been obvious to a person having ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the identifying of transactions, of Votaw, to include processes for identifying and remedying any discrepancies, as in Hanson, to help consumers keep better track of payments made and how they were made, per Hanson (para. [0004]).
Panzer discloses determining interaction levels for users (Abstract), similar to the claimed invention and to Votaw. It would have been obvious to a person having ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the listing of users, friends, activities, and the like, in Votaw, to include the ranking aspects in Panzer, so users benefit from group-related functionalities offered by social networking services, as taught by Panzer (see para. [0002]).
Regarding claim 6, Votaw/Hanson/Panzer teaches the following limitations:
“The electronic device of claim 1, wherein the processor is configured to display a activity generation screen on the display based on a second user input for generating new activity information related to the selected contact.” - See the aspects of Votaw that have been cited above. Votaw also discloses, “FILTER BY” and “CITY, STREET” (FIG. 5), and “the activity list 510 may also include an activity tag section 530, which may be expanded or hidden in the activity list. Within the activity tag section 530 the tags may be automatically or manually added to the activity as previously discussed with respect to FIG. 4 and elsewhere throughout this specification. As illustrated the tags may include user tags 532, location tags 534, entity tags 536, and category tags 538. In other embodiments of the invention, other tags may be included, such as but not limited to time of day tags (morning, afternoon, evening, late night, or the like). As illustrated in the activity tag section 530 the user may also have the ability to connect additional accounts 542, view packages 544 in which the activity is located, edit images 546 associated with the activity, and edit tags 548 in order to add, delete, or change tags” (para. [0105]). The system displaying the activity tag section for manually adding tags, to filter activities based on the tags, in Votaw, reads on the recited limitation.
Regarding claim 9, ---Votaw/Hanson/Panzer teaches the following limitations:
“The electronic device of claim 1, wherein the processor is configured to further display personal information of the selected contact based on the first user input, and ...” - See the aspects of Votaw that have been cited above. Votaw discloses, “ENTITY 1,” “SHOPPING,” and “LCD TV-XXXXX” (FIG. 5), and “In other embodiments of the invention electronic data captured from electronic receipts or actual receipts may be used as a source of activity information” and “The order confirmation also includes information about the merchant, such as name, address, phone number, web address, and the like” (para. [0060]). The system displaying activity information associated with entities based on filtering by users, in Votaw, reads on the recited limitation.
“... wherein the personal information includes a name, a phone number, a photo, and propensity information of the selected contact.” - See the aspects of Votaw that have been cited above. The entity information including the entity’s name, phone number, picture, and offerings, in Votaw, reads on the recited limitation.
Regarding claim 10, Votaw/Hanson/Panzer teaches the following limitations:
“The electronic device of claim 9, wherein the processor is configured to further display latest news information related to the selected contact based on the first user input.” - See the aspects of Votaw that have been cited above. Data feeds about most recent activities of users and entities, in Votaw, read on the recited limitation.
Regarding claims 11, 16, 19, and 20, while the claims are of different scope relative to claims 1, 6, 9, and 10, the claims recite limitations similar to those recited by claims 1, 6, 9, and 10. As such, the rationales applied to reject claims 1, 6, 9, and 10 also apply for purposes of rejecting claims 11, 16, 19, and 20. Claims 11, 16, 19, and 20 are, therefore, also rejected under 35 USC 103 as obvious in view of the combination of Votaw/Hanson/Panzer.
Claims 2-4 and 12-14 are rejected under 35 U.S.C. 103 as being unpatentable over Votaw, in view of Hanson, further in view of Panzer, and further in view of U.S. Pat. App. Pub. No. 2014/0149885 A1 to Wilder et al. (hereinafter referred to as “Wilder”).
Regarding claim 2, the combination of Votaw, Hanson, Panzer, and Wilder (hereinafter referred to as “Votaw/Hanson/Panzer/Wilder”) teaches the following limitations:
“The electronic device of claim 1, wherein each of the at least one piece of activity information is a planned activity or a performed activity, and ...” - Votaw discloses, “the social networking accounts of a user may be utilized to not only identify activities in the past (e.g., past locations of the user) or current activities (e.g., current locations of the user), but may also have the ability to identify future activities (e.g., locations at which the user will be in the future). To the extent that a social networking account includes information about the user in the future, the financial and social management system may be able to capture the future information and associate this type of activity information with an activity, as previously described herein with respect to past or current activities of the user” (para. [0157]).
“... wherein if the piece of activity information is the performed activity, the piece of activity information includes edges having a specific color.” - See the aspects of Votaw that have been cited above. Votaw does not appear, however, to disclose coloring of any edges. Wilder discloses, “According to another embodiment it may be advantageous to provide an indication of recent activity or relevance associated with a particular asset. Element 1215 provides a graphical treatment applied to the graphical display of an element which may be one or more of a border, color highlighting, flashing, 3D effect, etc. to signify recent relevance, such as trending or social media activity for the asset. Asset 1220 is shown with graphical elements 1225 a graphical representation signifying social media activity for the asset” (para. [0082]). Adding a border and color highlighting, as in Wilder, to the activities displayed, in Votaw, reads on the recited limitation.
Wilder discloses, “presenting a tapestry interface including graphical elements for a plurality of assets” (abstract), similar to the claimed invention and to Votaw. It would have been obvious to a person having ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the display, in Votaw, to include any one of, or combination of, graphical treatments, of Wilder, for purposes of visually signifying, indicating, differentiating, and the like, as taught by Wilder (see para. [0082]). Further, giving edges a specific color, as claimed, is nothing more than an aesthetic design change, and “matters relating to ornamentation only which have no mechanical function cannot be relied upon to patentably distinguish the claimed invention from the prior art” (MPEP 2144.04(I)).
Regarding claim 3, Votaw/Hanson/Panzer/Wilder teaches the following limitations:
“The electronic device of claim 2, wherein if the piece of activity information is the planned activity, the piece of activity information does not include edges.” - See the aspects of Votaw and Wilder that have been cited above. The future activity information, in Votaw, reads on the recited “planned activity” limitation. As shown in FIG. 12 of Votaw, text associated with the activities have no colored edges. Additionally or alternatively, using flashing, instead of colored bordering, of Wilder, reads on the recited limitation. The rationales for combining the teachings of the cited references, from the rejection of claim 2, also apply for purposes of rejecting claim 3.
Regarding claim 4, Votaw/Hanson/Panzer/Wilder teaches the following limitations:
“The electronic device of claim 3, wherein if activity information related to the selected contact includes a plurality of pieces of activity information, the processor is configured to further display an average value of grade information of the plurality of pieces of activity information.” - See the aspects of Votaw that have been cited above. Votaw also discloses, “as illustrated by the consumption interface 1900 in FIG. 19, the financial and social management system 1 may illustrate that based on the aggregated activity information a user drinks on average 3.2 cups of coffee a day” (para. [0170]). The activity information for filtered users including aggregated activity information, including displaying average values associated with activities, in Votaw, reads on the recited limitation.
Regarding claims 12-14, while the claims are of different scope relative to claims 2-4, the claims recite limitations similar to those recited by claims 2-4. As such, the rationales applied to reject claims 2-4 also apply for purposes of rejecting claims 12-14. Claims 12-14 are, therefore, also rejected under 35 USC 103 as obvious in view of Votaw/Hanson/Panzer/Wilder.
Response to Arguments
On pp. 7-10 of the Amendment/Response, the applicant requests reconsideration and withdrawal of the claim rejection under 35 USC 101. More specifically, with respect to Step 2A, Prong Two of the eligibility analysis, the applicant contends that the claims recite additional elements that integrate any judicial exception into a practical application. (Amendment/Response, p. 8.) The applicant emphasizes the claiming of contacts that are highly relevant to both the user and the specific contact based on relationship analysis, thereby enabling the user to manage and analyze their relationship with a specific contact by considering the associations with other contacts. (Amendment/Response, p. 8.) The applicant characterizes these aspects as representing a significant technical improvement over the prior art. (Amendment/Response, p. 8.) The applicant also emphasizes that within the claimed invention the information on third parties with high relevance to the user and the selected contact is prioritized and positioned at the top of the screen, which allegedly is a specific improvement in computer functionality by reducing required user interactions to provide the desired information, and not merely an abstract rule for organizing human social activities. (Amendment/Response, p. 8.) The applicant also points to the popup window aspects of the claims, and asserts that the claims go beyond importing transaction data from a financial application, by combining information with different data structures through a specific sequence, which is allegedly an improvement in computer functionality via ensuring interoperability between different software environments, and enhancing accuracy of data processing. (Amendment/Response, p. 9.) Also, the applicant argues that the popup window is a specific UI element that solves the technical problem of incomplete data, and is a non-conventional and technical means for doing so. (Amendment/Response, p. 9.)
The examiner finds the arguments above unpersuasive. Managing contacts, identifying highly relevant contacts, analyzing relationships with contacts, consideration associations between contacts, and the like, are abstract idea elements, none of which represents a technical improvement (i.e., an improvement to computers or technology in accordance with MPEP 2106.05(a)). This is because the claimed steps associated with the above elements are improvements to abstract idea elements (certain methods of organizing human activity, mental processes assisted by use of pen and paper, and the like), and “it is important to keep in mind that an improvement in the abstract idea itself (e.g. a recited fundamental economic concept) is not an improvement in technology” (MPEP 2106.05(a)(II).) Further, arranging data in different areas of a screen is not an improvement to technology, either, as it seems more like “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),” “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),” and/or “Gathering and analyzing information using conventional techniques and displaying the result, TLI Communications, 823 F.3d at 612-13, 118 USPQ2d at 1747-48,” none of which warrants eligibility per MPEP 2106.05(a). Finally, using popup windows to present data and receive data inputs is generic and conventional. The context of the popup windows in the applicant’s claims (i.e., their features and operation) fall squarely within generic, conventional operation. For all of these reasons, the claims remain rejected under 35 USC 101.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Such prior art includes the following:
U.S. Pat. App. Pub. No. 2014/0244498 A1 to Shishkov et al. discloses, “electronic systems and techniques for implementing a banking transaction and feed display system are provided that allow a user to visualize and interact with a financial transaction feed displayed on a mobile device. The feed displays a list of transactions made over a defined period of time, and the user selects different views, grouping the financial transactions by type, by recipient, by donor, by amount, and so on. The banking transaction and feed display system provides a rich set of tools to allow the user to customize the views and quickly display a desired format. The system also enables peer to peer payments to contacts stored in an address book on the mobile device.” (Abstract.)
U.S. Pat. App. Pub. No. 2015/0100478 A1 to Lee discloses, “systems and method for a communication device interface for monetary transfers through a displayable contact list. A user may import contacts from a contact list application, a social networking service, a user account with a payment provider, and/or another contact source into a communication device, such as a mobile phone. The mobile phone may then execute a monetary transfer module that allows the user to transmit requests for monetary transfers with the contacts. When the user selects a contact in a contact list, the module may retrieve payment account information and initiate a monetary transfer with the selected contact. The monetary transfer may correspond to receiving money or sending money to the contact. Additionally, the user may communicate messages with the request as well as a monetary amount. In order to facilitate completion of the monetary transfer, a payment provider may be utilized.” (Abstract.)
U.S. Pat. App. Pub. No. 2015/0142661 A1 to Jain et al. discloses, “Systems and methods are provided for managing shared expenses. The systems and methods may include a financial service provider identifying shared expenses in a customer's transaction history with software application executed on a server or personal computing device. The financial service provider may identify other individuals with whom the customer shares the expense, and send requests for reimbursement on the customer's behalf. The financial service provider may monitor the status of reimbursement payments, and send reminders as necessary until the shared expense has been reimbursed.” (Abstract.)
U.S. Pat. App. Pub. No. 2020/0387887 A1 to Rathod discloses, “systems, methods, graphical user interface and devices for identifying identity of merchant based on selected from maps, particular place associated website or webpage uniform resource locator (URL) or selected place on maps and enabling user to directly make payment from user payment account to said identified merchant's account including merchant bank account or debit card. In another embodiment enabling user or merchant to connect with each other via merchant client application and user client application and share or request payloads for the transaction and conduct payment transaction, communication, view orders, status, provide deals, offers, booking and one or more types of call-to-actions. The present disclosure relates to point of sale terminal systems and contactless mobile payment systems and relates to methods and systems for completing a transaction through internet or data network.” (Abstract.)
Any inquiry concerning this communication or earlier communications from the examiner should be directed to THOMAS Y. HO, whose telephone number is (571)270-7918. The examiner can normally be reached Monday through Friday, 9:30 AM to 5:30 PM Eastern.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Jerry O'Connor, can be reached on 571-272-6787. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/THOMAS YIH HO/Primary Examiner, Art Unit 3624
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