DETAILED ACTION
1. The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . This Office action is in response to Applicant’s communication filed on November 28, 2025. Amendments to claims 1, 3-5, 9, 12-14, 16, 17, and 19 have been entered. Claims 1-20 are pending and have been examined. The statement of reasons for the indication of allowable subject matter over prior art was already discussed in the Office action mailed on July 28, 2025 and hence not repeated here. The rejections and the response to arguments are stated below.
Claim Rejections - 35 USC § 101
2. 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.
3. Claims 1-20 are rejected under 35 U.S.C. § 101 because the claimed invention is directed to an abstract idea without significantly more.
The claim(s) recite(s) communicating the contextual underwriting analytics recommendation comprising a human-readable contextual insight, which is considered a judicial exception because it falls under the category of “Certain Methods of organizing human activity” such as fundamental economic practice as well as commercial or legal interactions including agreements as discussed below. This judicial exception is not integrated into a practical application as discussed below. The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception as discussed below.
Analysis
Step 1: In the instant case, exemplary claim 1 is directed to a system (apparatus).
Step 2A – Prong One: The limitations of “A computerized system comprising:
one or more computer processors; and
computer memory storing computer-useable instructions that, when used by the one or more computer processors, cause the one or more computer processors to perform operations, the operations comprising:
accessing, via a contextual underwriting analytics engine implemented in a distributed computing environment, input data associated with a client identified for an underwriting assessment, the input data comprising qualitative client profile data including a client financial profile description and quantitative client financial data including raw financial documents,
wherein the contextual underwriting analytics engine automatically ingests multimodal data from heterogenous sources and automatically normalizes, parses, and extracts fields from the raw financial documents based in part on performing cross-document field correlation;
analyzing the input data using a contextual underwriting analytics model and a plurality of predefined augmented analytics rules, wherein the contextual underwriting analytics model comprises machine-learning components that support mapping qualitative features to quantitative financial fields, wherein the plurality of predefined augmented analytics rules comprises one or more of: forward-looking rules, annotating rules, ranking rules, and presentation and packaging rules,
wherein the plurality of predefined augmented analytics rules support performing automated rule-based transformations;
based on analyzing the input data using the contextual underwriting analytics engine, generating a contextual underwriting analytics recommendation associated with information from the client financial profile description, one or more fields associated with a raw financial document, and a predefined augmented analytics rule, the contextual underwriting analytics recommendation comprising a machine-created insight narrative; and
communicating, for presentation on a contextual underwriting analytics interface, the contextual underwriting analytics recommendation comprising a human-readable contextual insight, wherein the contextual underwriting analytics recommendation is formatted using a presentation-packaging rule” as drafted, when considered collectively as an ordered combination without the italicized portions, is a process that, under the broadest reasonable interpretation, covers the category of “Certain Methods of organizing human activity” such as fundamental economic practice as well as commercial or legal interactions including agreements.
The steps of “communicating, for presentation on a contextual underwriting analytics interface, the contextual underwriting analytics recommendation comprising a human-readable contextual insight” is a fundamental economic practice such as communicating a product or service. The steps of “accessing, via a contextual underwriting analytics engine implemented in a distributed computing environment, input data associated with a client identified for an underwriting assessment, the input data comprising qualitative client profile data including a client financial profile description and quantitative client financial data including raw financial documents, …… and communicating, for presentation on a contextual underwriting analytics interface, the contextual underwriting analytics recommendation comprising a human-readable contextual insight, wherein the contextual underwriting analytics recommendation is formatted using a presentation-packaging rule” considered collectively as an ordered combination without the italicized portions, is a form of fulfilling agreements between the parties concerned. Hence, the steps of the claim considered collectively as an ordered combination without the italicized portions, covers the abstract category of “Certain Methods of organizing human activity”.
That is, other than, one or more computer processors, a computer memory storing computer-useable instructions, a contextual underwriting analytics engine, a distributed computing environment, a contextual underwriting analytics model, a plurality of predefined augmented analytics rules including, forward-looking rules, annotating rules, ranking rules, and presentation and packaging rules, machine-learning components, and a contextual underwriting analytics interface, nothing in the claim precludes the steps from being performed as a method of organizing human activity. If the claim limitations, under the broadest reasonable interpretation, covers methods of organizing human activity but for the recitation of generic computer components, then it falls within the “Certain methods of organizing human activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
Step 2A – Prong Two: The judicial exception is not integrated into a practical application. In particular, the claim only recites the additional elements of one or more computer processors, a computer memory storing computer-useable instructions, a contextual underwriting analytics engine, a distributed computing environment, a contextual underwriting analytics model, a plurality of predefined augmented analytics rules including, forward-looking rules, annotating rules, ranking rules, and presentation and packaging rules, machine-learning components, and a contextual underwriting analytics interface to perform all the steps. A plain reading of Figures 1-2 and 6-8 and associated descriptions in at least paragraphs [0057] , [0081] – [0083] reveals that one or more computer processors may be generic processors suitably programmed to execute the claimed steps. The distributed computing environment is broadly interpreted to include a generic distributed computing environment suitably programmed to perform the associated functions. The computer memory may be a generic memory suitably programmed to store the computer-useable instructions, the contextual underwriting analytics model, the plurality of predefined augmented analytics rules including, forward-looking rules, annotating rules, ranking rules, and presentation and packaging rules, machine-learning components, and the contextual underwriting analytics interface are broadly interpreted to include generic computer components suitably programmed to perform the associated functions. Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. The additional elements in all the steps are recited at a high-level of generality (i.e., as generic computer components performing generic computer functions) such that it amounts no more than mere instructions to apply the exception using generic computer components. 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. Hence, claim 1 is directed to an abstract idea.
Step 2B: 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, using the additional elements (identified above) to perform the claimed steps amounts to no more than mere instructions to apply the exception using a generic computer component. The additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Hence, independent claim 1 is not patent eligible. Independent claims 9 and 14 are also not patent eligible based on similar reasoning and rationale.
Dependent claims 2-8, 10-13 and 15-20, when analyzed as a whole are held to be patent ineligible under 35 U.S.C. 101 because the additional recited limitations only refine the abstract idea further.
For instance, in claims 2-3, 12-13, and 16-17, the steps
“wherein the client financial profile description includes information about a client including a business objective and a long-term financial goal, and wherein the quantitative financial data comprises two or more different types of raw financial documents, wherein a first document type is a tax return and a second document type of a schedule K-1 document”, “wherein the human-readable contextual insight is generated based on the business objective, the long-term financial goal, the tax return, and the schedule K-1 document” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the data/information used in the intermediate steps of the underlying process.
In claims 4, 10, and 18, the steps “wherein the contextual underwriting analytics model is a machine learning model that employs the plurality of predefined augmented analytics rules to map the qualitative client profile data to the quantitative client financial data, while simultaneously generating the human-readable contextual insight” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the intermediate steps of the underlying process. The additional element of a machine learning model is broadly interpreted to correspond to generic software suitably programmed to perform the associated function. The additional element of the machine learning model, performs a traditional function recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using generic computer components.
In claims 5, and 19, the steps “wherein the predefined augmented analytics rules include the forward-looking rules, the annotating rules, the ranking rules, and the presentation and packaging rules” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe rules used in the intermediate steps of the underlying process.
In claims 6, and 20, the steps “wherein a plurality contextual underwriting analytics recommendations are ranked and provided for presentation based on a ranking score of each contextual underwriting analytics recommendation” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe criteria used in the intermediate steps of the underlying process.
In claim 7, the steps “wherein a plurality of contextual underwriting analytics recommendations are packaged and provided for exportation to an external system” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the intermediate steps of the underlying process.
In claim 8, the steps “the operations further comprising:
communicating a request for the contextual underwriting analytics recommendation;
based on communicating the request for the contextual underwriting analytics recommendation, receive the contextual underwriting analytics recommendation; and
causing display of the contextual underwriting analytics recommendation comprising the human-readable contextual insight” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the intermediate steps of the underlying process.
In claims 11, and 15, the steps “wherein the contextual underwriting analytics recommendations are associated with input data comprising qualitative client profile data including a client financial profile description and quantitative client financial data including raw financial documents” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the intermediate steps of the underlying process.
In all the dependent claims, the judicial exception is not integrated into a practical application because the limitations are recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using generic computer components. Also, the claims do not affect an improvement to another technology or technical field; the claims do not amount to an improvement to the functioning of a computer system itself; the claims do not affect a transformation or reduction of a particular article to a different state or thing; and the claims do not move beyond a general link of the use of an abstract idea to a particular technological environment. In addition, the dependent claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. The additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. The claims as a whole, do not amount to significantly more than the abstract idea itself. For these reasons, the dependent claims also are not patent eligible.
Response to Arguments
4. In response to Applicants arguments on pages 1-13 of the Applicant’s remarks that the claims are patent-eligible under 35 USC 101 when considered under MPEP 2106, the Examiner respectfully disagrees.
The fact that the claims are Patent-Ineligible when considered under the MPEP 2106 has already been addressed in the rejection and hence not all the details of the rejection are repeated here.
Response to Applicants’ arguments regarding Step 2A – Prong one:
The claim(s) recite(s) communicating the contextual underwriting analytics recommendation comprising a human-readable contextual insight, which is considered a judicial exception because it falls under the category of “Certain Methods of organizing human activity” such as fundamental economic practice as well as commercial or legal interactions including agreements as discussed in the rejection.
The steps of “communicating, for presentation on a contextual underwriting analytics interface, the contextual underwriting analytics recommendation comprising a human-readable contextual insight” is a fundamental economic practice such as communicating a product or service.
The steps of “accessing, via a contextual underwriting analytics engine implemented in a distributed computing environment, input data associated with a client identified for an underwriting assessment, the input data comprising qualitative client profile data including a client financial profile description and quantitative client financial data including raw financial documents, …… and communicating, for presentation on a contextual underwriting analytics interface, the contextual underwriting analytics recommendation comprising a human-readable contextual insight, wherein the contextual underwriting analytics recommendation is formatted using a presentation-packaging rule” considered collectively as an ordered combination without the italicized portions, is a form of fulfilling agreements between the parties concerned. Hence, the steps of the claim considered collectively as an ordered combination without the italicized portions, recite an abstract idea”. The additional elements, including the engine, model, machine-learning components, rules, and the distributed computing environment in the claims are used as tools in their ordinary capacity to apply the abstract idea. Hence, the claims recite an abstract idea.
Response to Applicants’ arguments regarding Step 2A – Prong two:
According to MPEP 2106, limitations that are indicative of integration into a practical application include:
Improvements to the functioning of a computer, or to any other technology or technical field - see MPEP 2106.05(a)
Applying or using a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition
Applying the judicial exception with, or by use of, a particular machine - see MPEP 2106.05(b)
Effecting a transformation or reduction of a particular article to a different state or thing - see MPEP 2106.05(c)
Applying or using the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception - see MPEP 2106.05(e).
In the instant case, the judicial exception is not integrated into a practical application, because none of the above criteria is met. The claim (exemplary claim 1) only recites the additional elements of one or more computer processors, a computer memory storing computer-useable instructions, a contextual underwriting analytics engine, a distributed computing environment, a contextual underwriting analytics model, a plurality of predefined augmented analytics rules including, forward-looking rules, annotating rules, ranking rules, and presentation and packaging rules, machine-learning components, and a contextual underwriting analytics interface to perform all the steps. A plain reading of Figures 1-2 and 6-8 and associated descriptions in at least paragraphs [0057] , [0081] – [0092] reveals that one or more computer processors may be generic processors suitably programmed to execute the claimed steps. The distributed computing environment is broadly interpreted to include a generic distributed computing environment suitably programmed to perform the associated functions. The computer memory may be a generic memory suitably programmed to store the computer-useable instructions, the contextual underwriting analytics model, the plurality of predefined augmented analytics rules including, forward-looking rules, annotating rules, ranking rules, and presentation and packaging rules, machine-learning components, and the contextual underwriting analytics interface are broadly interpreted to include generic computer components suitably programmed to perform the associated functions. Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. The additional elements in all the steps are recited at a high-level of generality (i.e., as generic computer components performing generic computer functions) such that it amounts no more than mere instructions to apply the exception using generic computer components. 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. Hence, the claims are directed to an abstract idea.
The claimed features recited on page 4 of the remarks such as “
° automatic ingestion of multimodal data from heterogeneous sources;
° automated normalization, parsing, and field extraction from raw financial documents;
° cross-document field correlation across tax returns, K-1 forms, and other financial records;
° machine-learning components configured to map qualitative features to quantitative financial fields; and
° predefined augmented analytics rules that perform forward-looking analysis, annotating logic, ranking, presentation-packaging, and automated rule-based transformations” are all abstract features performed by the additional elements using the additional elements as tools in their ordinary capacity. Hence, these features may be characterized as an improvement in the abstract idea of communicating the contextual underwriting analytics recommendation comprising a human-readable contextual insight, using the additional elements as tools in their ordinary capacity. It does not involve any improvements to another technology, technical field, or improvements to the functioning of the computer itself.
Similarly, the claimed features recited on page 5 of the remarks such as “enabling automated ingestion and normalization of multi-format financial inputs, ….. applying augmented analytics rules that perform automated transformation” may be characterized as an improvement in the abstract idea of communicating the contextual underwriting analytics recommendation comprising a human-readable contextual insight, using the additional elements as tools in their ordinary capacity. It does not involve any improvements to another technology, technical field, or improvements to the functioning of the computer itself. By relying on a computer to perform routine tasks more quickly or more accurately is insufficient to render a claim patent eligible (See Alice, 134 S. Ct. at 2359 (use of a computer to create electronic records, track multiple transactions, and issue simultaneous instructions” is not an inventive concept). The Examiner does not see the parallel between the Applicant’s claims and those in Enfish and/or McRO. Therefore the Applicant’s arguments are not persuasive.
Similarly, the claimed features recited on page 5 of the remarks such as “a distributed analytics engine optimized for processing multimodal, heterogeneous financial data; ….. generation of a machine-created insight narrative” may be characterized as an improvement in the abstract idea of communicating the contextual underwriting analytics recommendation comprising a human-readable contextual insight, using the additional elements as tools in their ordinary capacity. The alleged advantages such as improving the efficiency, accuracy, and scalability of computer systems tasked with financial interpretation…… transforming the computer from a passive storage/retrieval device into an active analytics platform capable of performing multi-stage, algorithmic financial reasoning are due to improvements in the abstract idea of communicating the contextual underwriting analytics recommendation comprising a human-readable contextual insight. The Examiner does not see the parallel between the Applicant’s claims and those in Enfish and/or McRO. Therefore the Applicant’s arguments are not persuasive.
The limitations listed on pages 6-7 of the remarks such as “a contextual underwriting analytics engine deployed in a distributed computing environment …… generation of a machine-created insight narrative, formatted using presentation-packaging rules ….. multimodal ingestion, cross-document correlation, ML-driven mapping, rule-based transformations, automated insight generation, and structured presentation formatting” may be characterized as an improvement in the abstract idea of communicating the contextual underwriting analytics recommendation comprising a human-readable contextual insight, using the additional elements as tools in their ordinary capacity. It does not involve any improvements to another technology, technical field, or improvements to the functioning of the computer itself.
The Applicant’s arguments regarding response to rejections under Step 2A -Prongs one and two have already been addressed in the rejection and hence not repeated here. The claimed features such as “performing intelligent normalization and cross-document correlation, …. reconciling qualitative and quantitative information, and using rule-based transformations (e.g., add-backs, distribution vs. contribution identification, one-time expense normalization) to generate a contextual underwriting narrative” can all be performed by a human mind, but a little slower than a computer. By relying on a computer to perform routine tasks more quickly or more accurately is insufficient to render a claim patent eligible (See Alice, 134 S. Ct. at 2359 (use of a computer to create electronic records, track multiple transactions, and issue simultaneous instructions” is not an inventive concept).
The Applicant’s arguments regarding response to rejections under Step 2B have already been addressed in the rejection and hence not repeated here. By relying on a computer to perform routine tasks more quickly or more accurately is insufficient to render a claim patent eligible (See Alice, 134 S. Ct. at 2359 (use of a computer to create electronic records, track multiple transactions, and issue simultaneous instructions” is not an inventive concept). The Examiner does not see the parallel between the Applicant’s claims and those in BASCOM. Therefore the Applicant’s arguments are not persuasive.
In summary, the Applicant’s computerized system is a platform on which the abstract idea is implemented. The additional elements, identified in the rejection, are used as tools in their ordinary capacity to improve the underlying abstract idea of communicating the contextual underwriting analytics recommendation comprising a human-readable contextual insight. It does not involve any improvements to another technology, technical field, or improvements to the functioning of the computer itself. Therefore the Applicant’s arguments are not persuasive.
For these reasons and those discussed in the rejection, the rejections under 35 USC § 101 are maintained.
Conclusion
5. The prior art made of record and not relied upon is considered pertinent to applicant's disclosure:
(a) Feehan; Stephen P. (US Pub. 2016/0140662 A1) discloses an interactive graphical system is disclosed for ascertaining a person's or business owner's financial status to aid in financial planning. A display graphically and interactively displays the size of a person's or business owner's assets and locations thereof in real time, the assets comprise at least one of the group: investments, Roth funds, 401k/IRA funds, deferred annuities, non-cash assets, life insurance, disability insurance, and cash reserves. Current strategies in place to meet future goals are evaluated and a processor is provided for calculating surplus or deficit cash flow position due to living expenses, current strategies, and taxes in order to formulate strategies for future goals. Tax implications of current asset locations are also considered as part of the planning process. The result of using this inventive tool is to provide clarity of a person's assets and plans.
(b) Robb; Paul H. (US Pub. 2013/0085967 A1) discloses a method to maximize a post-mortem asset disbursement, the method receives information about one or more assets owned by an asset holder, selects a life expectancy from the group consisting of a single life, a joint life, and both a single life and a joint life, and sets an expected aggregate expenditure of the asset holder over the life expectancy period. The method further calculates a first investment corpus, a first investment corpus life expectancy value, and calculates a first estimated post-mortem tax liability. The method further sets a value for carve out funds deducted from the first investment corpus, wherein said carve out funds take into account both gift tax and estate tax exclusions, calculates a second investment corpus, a second investment corpus life expectancy value, and a second estimated post-mortem tax liability. The method then determines a value for life insurance proceeds paid at end of life expectancy.
6. 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 Narayanswamy Subramanian whose telephone number is (571) 272-6751. The examiner can normally be reached Monday-Friday from 9:00 AM to 5:00 PM. If attempts to reach the examiner by telephone are unsuccessful, the examiner's supervisor, Abhishek Vyas can be reached at (571) 270-1836. The fax number for Formal or Official faxes and Draft to the Patent Office is (571) 273-8300.
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/Narayanswamy Subramanian/
Primary Examiner
Art Unit 3691
May 12, 2026
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