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 .
DETAILED ACTION
Status of Claims
This action is in reply to the RCE filed on 5th of January 2026.
Claims 1, 11, and 16 were amended.
Claims 1-20 are currently pending and have been examined.
Response to Arguments
Applicant's arguments filed 5th of January 2026 have been fully considered but they are not persuasive.
With regard to the limitations of claims 1-20, Applicant added by amendment “…determining a second base limit value for the user account indicating an additional excess utilization buffer for the user account by utilizing a second activity machine learning model from the plurality of activity machine learning models selected based on an updated user account activity duration corresponding to the user account; determining, for the user account, a second available base limit value based on the second base limit value; and providing the second available base limit value for display within the graphical user interface.” This is merely a further elaboration of the abstract idea “utilizing” machine learning model and user interface as tools. Therefore, it is not sufficient enough to overcome the pending 101 rejection.
With regard to the limitations of claims 1-20, Applicant argues “…The Claims are not directed to an abstract idea.” The Examiner respectfully disagrees. As amended, the claims are still directed to an abstract idea. Applicant merely elaborated on the abstract idea itself.
With regard to the limitations of claims 1-20, Applicant argues “…The Currently Amended Claims Recite a Practical Application of Any purported Abstract Idea.” The Examiner respectfully disagrees. Again, merely using the computer technology as tool to implement the abstract idea itself is not sufficient enough to overcome the rejection.
With regard to the limitations of claims 1-20, Applicant argues “…The Currently Amended Claims Amount to Significantly More Than Any Purported Abstract Idea.” The Examiner respectfully disagrees. Again, merely using the computer technology such as “machine learning models” or user interface for displaying as tools to implement the abstract idea itself is not sufficient enough to overcome the rejection.
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 abstract idea without significantly more. The claims recite abstract idea of organizing human activities. This judicial exception is not integrated into a practical application and the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Analysis
First of all, claims are directed to one or more of the following statutory categories: a process, a machine, a manufacture, and a composition of matter. For claim 1, the claim recites an abstract idea of
“…determining…a base limit value or a user account indicating an excess utilization buffer for the user account by: selecting, utilizing a user activity duration corresponding to the user account, an activity machine learning model from a plurality of activity machine learning models, wherein each of the plurality of activity machine learning models comprise learned parameters specific to different sets of user activity training data from different groupings of user accounts; generating an activity score utilizing the activity machine learning model from user activity data of the user account; and utilizing the activity score with a base limit value model to determine the base limit value; determining, for the user account, an available base limit value based on the base limit value; receiving, for the user account, a credit transaction corresponding to a secured credit account with a transaction value limit based on a deposited value within the secured credit account; upon detecting that a transaction value of the credit transaction is greater than the transaction value limit, utilizing the available base limit value corresponding to the user account to fulfill a remainder between the transaction value and the transaction value limit; generating a modified transaction value limit and a modified available base limit value for the user account based on the utilization of the available base limit value; and providing…the modified transaction value limit and the modified available base limit value…determining a second base limit value for the user account indicating an additional excess utilization buffer for the user account by utilizing a second activity machine learning model from the plurality of activity machine learning models selected based on an updated user account activity duration corresponding to the user account; determining, for the user account, a second available base limit value based on the second base limit value; and providing the second available base limit value for display within the graphical user interface.” This is an abstract idea of a certain method of organizing human activity, since it recites managing personal behavior including following rules and a commercial or legal interactions, namely purchasing transaction related limits management. Besides reciting the abstract idea, the remaining claim limitations recite generic computer components/processes (e.g., display/graphical user interface, machine learning model). “We conclude that claim 1 is “directed to a result or effect that itself is the abstract idea and merely invoke[s] generic processes and machinery” rather than “a specific means or method that improves the relevant technology.” Smart Sys. Innovations, LLC v. Chi. Transit Authority, 873 F.3d 1364, 1371.
This recited abstract idea is not integrated into a practical application. In particular, the claim only recites generic computer components/processes (e.g., display/graphical user interface, machine learning model) to receive/transmit/display data (extra-solution activities) and perform the abstract idea mentioned above. (See at least MPEP 2016.05(g): CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375 (Fed. Cir. 2011); buySafe, Inc. v. Google, Inc., 765 F.3d 1350, 1355 (Fed. Cir. 2014); OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015); Ultramercial, Inc. v. Hulu, LLC, 772 F.3D 709, 715 (Fed. Cir. 2014); Electric Power Group, LLC v. Alstom S.A., 830 F.3d 1350, 1354-55 (Fed. Cir. 2016); Intellectual Ventures I LLC v. Erie Indem. Co., 850 F.3d 1315, 1328-29 (Fed. Cir. 2017); Ameranth, 842 F.3d at 1245, 120 USPQ2d at 1857; Trading Technologies v. IBG LLC, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019)). The additional elements (e.g., display/graphical user interface, machine learning model) are recited at a high-level of generality such that they amount to no more than mere instructions to apply the exception using generic computer components or merely uses a computer as a tool to perform an abstract idea. Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Therefore, the claim is directed to an abstract idea.
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements - (e.g., display/graphical user interface, machine learning model) amount to no more than mere instructions to apply the abstract idea using generic computer components or merely uses a computer as a tool to perform an abstract idea. In conclusion, merely “applying” the exception using generic computer components cannot provide an inventive concept. Therefore, the claim is not patent eligible under 35 USC 101.
Again, the insignificant extra-solution activities mentioned above were re-evaluated in step 2B. The limitations do not amount to significantly more than the abstract idea because the courts found sending/receiving/displaying of data to be well understood, routine, and conventional activities. (See at least MPEP 2016.05(g): CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375 (Fed. Cir. 2011); buySafe, Inc. v. Google, Inc., 765 F.3d 1350, 1355 (Fed. Cir. 2014); OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015); Ultramercial, Inc. v. Hulu, LLC, 772 F.3D 709, 715 (Fed. Cir. 2014); Electric Power Group, LLC v. Alstom S.A., 830 F.3d 1350, 1354-55 (Fed. Cir. 2016); Intellectual Ventures I LLC v. Erie Indem. Co., 850 F.3d 1315, 1328-29 (Fed. Cir. 2017); Ameranth, 842 F.3d at 1245, 120 USPQ2d at 1857; Trading Technologies v. IBG LLC, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019)). Thus again, claims were not patent eligible under 35 USC 101.
Similar arguments can be extended to independent claims 11 and 16.
Dependent claims 2-10, 12-15, and 17-20 have been given the full two-part analysis, analyzing the additional limitations both individually and in combination. The dependent claims when analyzed individually and in combination, are also held be patent ineligible under 35 U.S.C. 101.
For claims 2 and 17, the recited limitations of these claims merely further narrow the abstract idea discussed above. These claims further added, “…receiving an additional credit transaction corresponding to the secured credit account; and authorizing the additional credit transaction for the user account by comparing an additional transaction value of the additional credit transaction to the modified transaction value limit and the modified available base limit value.” The limitations of these claims fail to integrate the abstract idea into a practical application because these claims do not introduce additional elements other than the generic components discussed above. These dependent claims, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitations of these dependent claims fail to establish that the claims provide an inventive concept because claims that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 3, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…authorizing the additional credit transaction by: accepting the additional credit transaction upon detecting that the additional transaction value does not exceed a combination of the modified transaction value limit and the modified available base limit value; or rejecting the additional credit transaction upon detecting that the additional transaction value exceeds the combination of the modified transaction value limit and the modified available base limit value.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 4, the recited limitations of this claim merely further defined the generic computing step of “training” the first and the second activity machine learning models. The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic computing step discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitations of this dependent claim fail to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claims 13 and 18, the recited limitations of these claims merely further narrow the abstract idea discussed above. These claims further added, “…determining, for the user account, the available base limit value based on the base limit value, one or more credit transactions corresponding to the secured credit account, and one or more transactions corresponding to an additional transaction account of the user account.” The limitations of these claims fail to integrate the abstract idea into a practical application because these claims do not introduce additional elements other than the generic components discussed above. These dependent claims, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitations of these dependent claims fail to establish that the claims provide an inventive concept because claims that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claims 5 and 14, the recited limitations of these claims merely further narrow the abstract idea discussed above. These claims further added, “…generating the modified available base limit value based on the remainder between the transaction value and the transaction value limit from the available base limit value.” The limitations of these claims fail to integrate the abstract idea into a practical application because these claims do not introduce additional elements other than the generic components discussed above. These dependent claims, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitations of these dependent claims fail to establish that the claims provide an inventive concept because claims that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claims 6 and 19, the recited limitations of these claims merely further narrow the abstract idea discussed above. These claims further added, “…detecting a transaction corresponding to an additional transaction account of the user account, wherein the additional transaction account is different from the secured credit account; generating an updated modified available base limit value based on the transaction; and providing, for display within the graphical user interface, the modified transaction value limit and the updated modified available base limit value.” The limitations of these claims fail to integrate the abstract idea into a practical application because these claims do not introduce additional elements other than the generic components discussed above. These dependent claims, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitations of these dependent claims fail to establish that the claims provide an inventive concept because claims that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 7, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…detecting a deposit transaction within one or more transaction accounts corresponding to the user account; generating, utilizing the deposit transaction, an updated modified available base limit value for the user account; and providing, for display within the graphical user interface, the modified transaction value limit and the updated modified available base limit value.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claims 8, 15, and 20, the recited limitations of these claims merely further narrow the abstract idea discussed above. These claims further added, “…detecting an additional deposited value within the secured credit account; and generating, utilizing the additional deposited value, an updated modified transaction value limit by combining the additional deposited value and the modified transaction value limit.” The limitations of these claims fail to integrate the abstract idea into a practical application because these claims do not introduce additional elements other than the generic components discussed above. These dependent claims, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitations of these dependent claims fail to establish that the claims provide an inventive concept because claims that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 9, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…providing, for display within an additional graphical user interface, one or more selectable user interface elements to select, for access to the available base limit value, the secured credit account or one or more additional transaction accounts; and upon receiving a user selection of a selectable user interface element corresponding to the secured credit account and an additional transaction account from the one or more additional transaction accounts, enabling the available base limit value for the secured credit account and the additional transaction account.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 10, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…providing, for display within an additional graphical user interface, a user interface element indicating utilization of the available base limit value for the credit transaction and an additional user interface element indicating an amount of the available base limit value utilized based on the remainder between the transaction value and the transaction value limit.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 12, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the operations further comprise: receiving an additional credit transaction corresponding to the secured credit account; and authorizing the additional credit transaction based on an additional transaction value of the additional credit transaction by: accepting the additional credit transaction upon detecting that the additional transaction value does not exceed a combination of the modified transaction value limit and the modified available base limit value; or rejecting the additional credit transaction upon detecting that the additional transaction value exceeds the combination of the modified transaction value limit and the modified available base limit value.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to EDWARD CHANG whose telephone number is (571)270-3092. The examiner can normally be reached M - F, 9-5.
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/EDWARD CHANG/Primary Examiner, Art Unit 3696 03/16/2026