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 (RCE) filed on August 11, 2026. Amendments to claims 1, 4, 8, 10, 13, 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 September 24, 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) a method of displaying via a user interface and responsive to receiving the user input, a summary section of the selected first subcategory or second subcategory, the summary section including at least one of a subcategory name, an amount attributed to the subcategory, or a percentage of a total budgeted amount attributed to the subcategory, and an area-based graphical visualization of the plurality of merchants of the selected first subcategory or second subcategory, the area-based graphical visualization displaying each merchant as a graphical representation having a size that is based on the data associated with the plurality of transactions, 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 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 method (process).
Step 2A – Prong One: The limitations of “computer-implemented method comprising:
providing, by a computer system, first access rights to a bank account of a financial institution to a first user account of a first user and second access rights to the bank account to a second user account of a second user, the first access rights granting the first user account full access to the bank account, the second access rights granting the second user account restricted access to the bank account;
authorizing, by the computer system, the second user account to access the bank account based on receiving authentication information;
receiving, by the computer system, data of a plurality of transactions associated with the bank account;
displaying, by the computer system via a user interface, a graphical representation of a budget category including a plurality of subcategories, wherein each of the plurality of subcategories is grouped based on the data of the plurality of transactions and wherein the user interface comprises graphical representations of the first subcategory and the second subcategory having a characteristic based on the data of the plurality of transactions;
receiving, by the computer system from the second user account, a user input comprising a selection of at least one of the first subcategory or the second subcategory of the plurality of subcategories;
determining, by the computer system and based on the plurality of transactions, a
plurality of merchants associated with the selected first subcategory or second subcategory;
displaying, by the computer system via the user interface and responsive to receiving the user input, a summary section of the selected first subcategory or second subcategory, the summary section including at least one of a subcategory name, an amount attributed to the subcategory, or a percentage of a total budgeted amount attributed to the subcategory, and an area-based graphical visualization of the plurality of merchants of the selected first subcategory or second subcategory, the area-based graphical visualization displaying each merchant as a graphical representation having a size that is based on the data associated with the plurality of transactions;
receiving, by the computer system, updated data of the plurality of transactions; and
updating, by the computer system via the user interface, the characteristic of the graphical representations of each of the first subcategory and the second subcategory based on the updated data” 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.
Displaying categories of a transaction is a fundamental economic practice such as analyzing a transaction.
The steps of “receiving, by the computer system, data of a plurality of transactions associated with the bank account; displaying, by the computer system via a user interface, a graphical representation of a budget category including a plurality of subcategories, wherein each of the plurality of subcategories is grouped based on the data of the plurality of transactions and wherein the user interface comprises graphical representations of the first subcategory and the second subcategory having a characteristic based on the data of the plurality of transactions; receiving, by the computer system from the second user account, a user input comprising a selection of at least one of the first subcategory or the second subcategory of the plurality of subcategories; determining, by the computer system and based on the plurality of transactions, a plurality of merchants associated with the selected first subcategory or second subcategory; displaying, by the computer system via the user interface and responsive to receiving the user input, a summary section of the selected first subcategory or second subcategory, the summary section including at least one of a subcategory name, an amount attributed to the subcategory, or a percentage of a total budgeted amount attributed to the subcategory, and an area-based graphical visualization of the plurality of merchants of the selected first subcategory or second subcategory, the area-based graphical visualization displaying each merchant as a graphical representation having a size that is based on the data associated with the plurality of transactions; receiving, by the computer system, updated data of the plurality of transactions; and updating, by the computer system via the user interface, the characteristic of the graphical representations of each of the first subcategory and the second subcategory based on the updated data” considered collectively, is also a form of fulfilling agreements between the company (represented by the computer system) and the user. 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, a computer system comprising a data storage, a processor, program logic (including rights management logic and a personal financial management logic), a user interface including graphical representation of budget category and subcategories, and an area-based graphical visualization 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 a computer system comprising a data storage, a processor, program logic (recited in claim 10) including rights management logic and a personal financial management logic), a communication network (not explicitly claimed), a user interface including graphical representation of budget category and subcategories, and an area-based graphical visualization to perform all the steps. A plain reading of Figures 1 and 5A-18 and the associated descriptions in at least paragraphs [0017] – [0024], [0032] – [0045] reveals that the data storage is a generic data storage suitably programmed to store the associated data/information. The processor may be a generic processor, the program logic, the user interface including graphical representation of budget category and subcategories and an area-based graphical visualization may be generic software suitably programmed to perform the associated functions. The communication network (not explicitly claimed) may be a generic communication network such as the Internet. 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 10 and 19 are also not patent eligible based on similar reasoning and rationale.
Dependent claims 2-9, 11-18 and 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, 11 and 20, the steps “wherein the characteristic of the graphical representations of the first subcategory and the second subcategory comprises a size of the graphical representations” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the graphical representations used in the intermediate steps of the underlying process.
In claims 3 and 12, the steps “wherein:
the user interface further comprises a spending history section including shapes that are sized in proportion to spending in at least one of the first subcategory or the second subcategory over a predetermined period of time; and
one of the shapes of the spending history section is sized according to a predicted spending total for a subset of the predetermined period of time” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the user interface used in the intermediate steps of the underlying process.
In claims 4 and 13, the steps “wherein:
the characteristic of the graphical representations is based on an amount of transactions of the plurality of transactions” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the transactions used in the intermediate steps of the underlying process.
In claims 5 and 14, the steps “wherein:
the first access rights comprises displaying the budget category; and
the second access rights comprises hiding the budget category” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the access rights used in the intermediate steps of the underlying process.
In claims 6 and 15, the steps “wherein authorizing the second user account comprises:
comparing, by the computer system, the authentication information with information of the second user account maintained in a database communicably coupled to the computer system; and
determining, by the computer system, the authentication information matches the information of the second user account” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the authentication process used in the intermediate steps of the underlying process. The additional element of a database is broadly interpreted to correspond to generic database suitably programmed to perform the associated function. The additional element of the database, 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 7-9 and 16-18, the steps “wherein: wherein the graphical representations of the first subcategory differ from the graphical representations of the second subcategory in at least one of color or location on the user interface”,
“wherein the graphical representations of at least one of the first subcategory or the second subcategory comprise a name of a merchant associated with at least one transaction of the plurality of transactions” and
“wherein the graphical representations of the first subcategory and the second subcategory are displayed as a treemap” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the graphical representations of the categories used in 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 9-14 of the Applicant’s remarks that the claims re 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) a method of displaying via a user interface and responsive to receiving the user input, a summary section of the selected first subcategory or second subcategory, the summary section including at least one of a subcategory name, an amount attributed to the subcategory, or a percentage of a total budgeted amount attributed to the subcategory, and an area-based graphical visualization of the plurality of merchants of the selected first subcategory or second subcategory, the area-based graphical visualization displaying each merchant as a graphical representation having a size that is based on the data associated with the plurality of transactions, 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 as discussed in the rejection.
Displaying categories of a transaction is a fundamental economic practice such as analyzing a transaction.
The steps of The steps of “receiving, by the computer system, data of a plurality of transactions associated with the bank account; displaying, by the computer system via a user interface, a graphical representation of a budget category including a plurality of subcategories, wherein each of the plurality of subcategories is grouped based on the data of the plurality of transactions and wherein the user interface comprises graphical representations of the first subcategory and the second subcategory having a characteristic based on the data of the plurality of transactions; receiving, by the computer system from the second user account, a user input comprising a selection of at least one of the first subcategory or the second subcategory of the plurality of subcategories; determining, by the computer system and based on the plurality of transactions, a plurality of merchants associated with the selected first subcategory or second subcategory; displaying, by the computer system via the user interface and responsive to receiving the user input, a summary section of the selected first subcategory or second subcategory, the summary section including at least one of a subcategory name, an amount attributed to the subcategory, or a percentage of a total budgeted amount attributed to the subcategory, and an area-based graphical visualization of the plurality of merchants of the selected first subcategory or second subcategory, the area-based graphical visualization displaying each merchant as a graphical representation having a size that is based on the data associated with the plurality of transactions; receiving, by the computer system, updated data of the plurality of transactions; and updating, by the computer system via the user interface, the characteristic of the graphical representations of each of the first subcategory and the second subcategory based on the updated data" considered collectively is also a form of fulfilling agreements between the company (represented by the computer system) and the user. 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, a computer system comprising a data storage, a processor, program logic (including rights management logic and a personal financial management logic), a user interface including graphical representation of budget category and subcategories, and an area-based graphical visualization nothing in the claim precludes the steps from being performed as a method of organizing human activity, 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. Claimed limitations including those listed on page 11 of the remarks such as “causing display of a first graphical user interface including graphical representations of first and second subcategories; receiving a selection of one of those subcategories; and in response to that selection, causing display of a second graphical user interface including an area-based graphical visualization of a plurality of merchants associated with the selected subcategory, where each merchant is displayed as a graphical representation having a size based on data associated with the plurality of transactions” are normal functions of a computer. The Applicants are merely using the computer, as a tool in its normal 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 claims only recite the additional elements of a computer system comprising a data storage, a processor, program logic (recited in claim 10) including rights management logic and a personal financial management logic), a communication network (not explicitly claimed), a user interface including graphical representation of budget category and subcategories, and an area-based graphical visualization to perform all the steps. A plain reading of Figures 1 and 5A-18 and the associated descriptions in at least paragraphs [0017] – [0024], [0032] – [0045] reveals that the data storage is a generic data storage suitably programmed to store the associated data/information. The processor may be a generic processor, the program logic, the user interface including graphical representation of budget category and subcategories and an area-based graphical visualization may be generic software suitably programmed to perform the associated functions. The communication network (not explicitly claimed) may be a generic communication network such as the Internet. 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.
The claimed limitations including those listed on page 12 of the remarks such as “causing display of a first graphical user interface including graphical representations of a first subcategory and a second subcategory associated with a category of a budget, receives a user selection of the first subcategory or the second subcategory, and in response to that selection causes display of a second graphical user interface including an area-based graphical visualization of a plurality of merchants of the selected subcategory, where each merchant is displayed as a graphical representation having a size based on data associated with the plurality of transactions ….. using transaction-associated data to generate a structured visual hierarchy for the selected subcategory and to alter how merchant-level information is arranged and explored on the screen …... a particular interface mechanism that changes the presentation and navigation of information within the computing environment ….. producing a specific, machine-generated visual arrangement” are normal functions of a computer. The Applicants are merely using the computer, as a tool in its normal capacity, to apply the abstract idea. Hence, the claims are directed to an abstract idea.
The Examiner does not see the parallel between the Applicant’s claims and that of Claim 1 of Example 37 of the USPTO's Subject Matter Eligibility Examples. Therefore, the Applicant’s arguments are not persuasive.
Response to Applicants’ arguments regarding Step 2B:
As discussed in the rejection, the claims do 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 in the rejection) to perform the claimed steps, amount 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.
The claimed limitations including those listed on pages 13-14 of the remarks such as “causing display of a first graphical user interface including graphical representations of a first subcategory and a second subcategory associated with a category of a budget; receiving a selection of one of those subcategories; and in response to the selection, causing display of a second graphical user interface including an area-based graphical visualization of a plurality of merchants of the selected subcategory, the area-based graphical visualization displaying each merchant as a graphical representation having a size based on data associated with the plurality of transactions” are normal functions of a computer. The Applicants are merely using the computer, as a tool in its normal capacity, to apply the abstract idea. Hence, the claims are not patent eligible.
In Summary, the computer system is merely a platform on which the abstract idea is implemented. Hence, the claims do not recite significantly more than an abstract idea.
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) Roth; Valerie Ann et al. (US Patent 11429980 B1) discloses a method and system of increasing the security of requests to access funds from a joint bank account by secondary users in order to permit a primary user to securely regulate fund usage. The system and method are configured to link to a bank account and restrict the access of funds by secondary users per conditions defined by the primary user(s). An application can be accessed via a computing device that receives requests for funds from secondary users and requires the secondary user to also submit a digital image or video that supports their proposed transaction. The request will only be conveyed to the primary user if the necessary digital verification is received by the system.
6. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice.
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
October 12, 2026
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