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 January 26, 2026. Amendments to claims 1, 4, 5, 8, 10, 13, 14, 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, wherein the user interface comprises graphical representations of each of the first subcategory and the second subcategory having a characteristic based on the data associated with the at least one transaction, 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;
receiving, by the computer system from the second user account, a user input comprising a selection of at least one of a first subcategory or a second subcategory of the plurality of subcategories;
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, wherein the user interface comprises graphical representations of each 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, updated data of the plurality of transactions; and
updating, by the computer system via the user interface, the characteristic of the graphical representations” 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.
“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; receiving, by the computer system from the second user account, a user input comprising a selection of at least one of a first subcategory or a second subcategory of the plurality of subcategories; 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, wherein the user interface comprises graphical representations of each 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, 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” 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) and a user interface including graphical representation of budget category and subcategories, 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) and a user interface including graphical representation of budget category and subcategories 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 and the user interface including graphical representation of budget category and subcategories 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, wherein the user interface comprises graphical representations of each of the first subcategory and the second subcategory having a characteristic based on the data associated with the at least one transaction, 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.
“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; receiving, by the computer system from the second user account, a user input comprising a selection of at least one of a first subcategory or a second subcategory of the plurality of subcategories; 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, wherein the user interface comprises graphical representations of each 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, 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” 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) and a user interface including graphical representation of budget category and subcategories, 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 “receiving ... updated data of the plurality of transactions; and updating ... via the user interface, the characteristic of the graphical representations ... based on the updated data” 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) and a user interface including graphical representation of budget category and subcategories 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 and the user interface including graphical representation of budget category and subcategories 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 “receiving ... updated data of the plurality of transactions; and updating ... via the user interface, the characteristic of the graphical representations ... based on the updated data” 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 those in Enfish, LLC v. Microsoft Corp 822 F.3d 1327 (2016). Similarly, the Examiner does not see the parallel between the Applicant’s claims and that 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 page 14 of the remarks such as “receiving ... updated data of the plurality of transactions; and updating ... via the user interface, the characteristic of the graphical representations ... based on the updated data” 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.
Regarding applicant's arguments alleging the lack of prior art as evidence that the claims contain an improvement and therefore are significantly more, this argument-sounding in § 102 novelty-is beside the point for a §101 inquiry. See Amdocs (Isr.) Ltd. v. Openet Telecom, Inc., No. 1: 10cv910 (LMB/TRJ), 2014 WL 5430956, at *11 (E.D. Va. Oct. 24, 2014) ("The concern of § 101 is not novelty, but preemption.").
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) Ebersole; Elizabeth M. et al. (US Patent 7792748 B1) discloses a system and method for performing a financial transaction by determining a master account number associated with one or more accounts that a user may access, providing data to generate a user interface displaying a list of the accounts and an indicator associated with a financial transaction, receiving indicator information associating the indicator with one or more of the accounts, receiving terms for the financial transaction, and performing the financial transaction. The list of accounts may be expanded to view account information.
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
March 12, 2026