DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
This Office Action responds to the amendment and argument filed on March 02, 2026 in response to the Office Action mailed on December 03, 2025.
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 1-3, 5, 7-13, 15, 17-20 are rejected under 35 U.S.C. §101 because the claimed invention is directed to a judicial exception (i.e., an abstract idea) without significantly more.
Representative Claim
Independent claim 1 is representative. Claims 11 recites substantially similar limitations and is directed to the same judicial exception. The dependent claims merely add insignificant extra-solution activity and/or field-of-use limitations and therefore fall with their respective independent claims.
STEP 1: STATUTORY CATEGORY
Claim 1 is directed to a machine and therefore falls within one of the four statutory categories of invention (35 U.S.C. §101).
However, the claim must also be analyzed under the judicial exceptions set forth in Alice Corp. v. CLS Bank Int'l, 573 U.S. 208 (2014), Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66 (2012), and the 2024 USPTO Subject Matter Eligibility Guidance.
STEP 2A, PRONG ONE
Under Step 2A, Prong One, claim 1 recites a judicial exception.
Specifically, claim 1 recites limitations directed to: aggregating dealer data; generating a dashboard including financial information, credit information, inventory information, and recommendation information; analyzing dealership financial accounts, credit accounts, and inventory; training artificial intelligence using dealership data; recommending remedies when account balances are low; recommending changes to credit lines; recommending inventory changes and product orders.
These limitations describe collecting information, analyzing information, evaluating business conditions, and providing recommendations for business decision making.
Such activities constitute certain methods of organizing human activity including:
commercial interactions; sales activities; inventory management; financing activities;
credit management; business administration.
The claimed recommendations regarding financing, credit, inventory, dealership funding, financial products, and manufacturer incentives are commercial and business management practices that have traditionally been performed by financial analysts, dealership managers, inventory planners, and lending personnel.
Accordingly, the claim recites a method of organizing human activity and therefore recites an abstract idea. See MPEP §2106.04(a)(2).
Additionally, the claim recites mental processes because the steps of reviewing dealership information, evaluating financial conditions, determining inventory needs, assessing credit availability, and recommending actions can practically be performed in the human mind or with pen and paper, albeit more quickly using a computer.
Therefore, claim 1 recites: Certain methods of organizing human activity; and Mental processes.
Both groupings are identified abstract ideas under the 2024 USPTO Subject Matter Eligibility Guidance.
STEP 2A, PRONG TWO
Under Step 2A, Prong Two, the claim does not integrate the judicial exception into a practical application.
The additional elements beyond the abstract idea include: one or more processors;
non-transitory computer-readable storage media; dealer dashboard; artificial intelligence; data aggregation functionality; computer implementation generally.
These elements merely use generic computer technology as tools to collect, process, analyze, display, and communicate information.
The claim does not recite: an improvement to computer functionality;
an improvement to database technology; an improvement to artificial intelligence architecture;
an improvement to networking technology; an improvement to data storage technology;
an improvement to dealership hardware systems.
The claimed "artificial intelligence" is recited only at a high level of generality and merely performs the abstract task of generating business recommendations based upon collected data. The claim does not recite any particular machine-learning architecture, training technique, model structure, feature engineering process, inference mechanism, or technical improvement to artificial intelligence itself.
Rather, the artificial intelligence is used as a tool to perform the abstract business functions of: recommending financing actions; recommending credit actions;
recommending inventory actions; recommending dealership products.
Using generic artificial intelligence to automate a business analysis does not integrate the abstract idea into a practical application. See MPEP §2106.05(f).
Similarly, generating a "central dealer dashboard" merely displays the results of the business analysis and constitutes insignificant extra-solution activity. Displaying information does not impose a meaningful limit on the judicial exception.
Accordingly, claim 1 fails to integrate the judicial exception into a practical application.
Therefore, claim 1 is directed to an abstract idea.
STEP 2B
Because claim 1 is directed to a judicial exception, it must be evaluated to determine whether the claim recites significantly more than the judicial exception.
The additional elements, individually and in combination, do not amount to significantly more than the abstract idea itself.
The claim merely employs: generic processors; generic memory; generic computer-readable storage media; generic data aggregation functions; generic dashboard generation functions; generic artificial intelligence functions.
The specification describes these components at a high level of generality and does not indicate that any of these elements were unconventional in the field.
The recited processor and memory merely perform routine computer functions such as:
receiving data; storing data; analyzing data; generating recommendations; displaying information.
These activities represent well-understood, routine, and conventional computer operations.
The claim merely automates longstanding dealership management activities that previously could be performed by dealership personnel, financial advisors, inventory managers, and lenders.
The use of artificial intelligence does not provide an inventive concept because the claim merely invokes artificial intelligence as a generic tool for implementing the abstract idea. The claim does not recite any unconventional AI model, training mechanism, technical architecture, or improvement to computer technology.
Viewed as an ordered combination, the elements merely automate the abstract process of collecting dealership data, analyzing dealership operations, and providing business recommendations using conventional computer components.
The ordered combination therefore amounts to no more than applying the abstract idea using generic computer technology.
Accordingly, claim 1 does not include additional elements sufficient to amount to significantly more than the judicial exception.
DEPENDENT CLAIMS
Claims 2 and 12
Claims 2 and 12 further recite providing account balances and allowing transfers of funds.
These limitations merely add additional financial management activities and commercial interactions, which themselves constitute abstract ideas and do not provide an inventive concept.
Claims 3 and 13
Claims 3 and 13 recite monitoring cash flow.
Monitoring financial account cash flow constitutes financial analysis and evaluation, which is a fundamental economic practice and a method of organizing human activity.
These limitations do not integrate the exception into a practical application and do not add significantly more.
Claims 5 and 15
Claims 5 and 15 recite increasing a credit line.
Adjusting a credit line is a commercial lending activity and constitutes an abstract business practice.
The limitation merely narrows the content of the recommendation and does not provide an inventive concept.
Claims 7 and 17
Claims 7 and 17 recite adding additional inventory.
Inventory replenishment and stock planning are longstanding commercial practices and methods of organizing human activity.
These limitations do not add significantly more.
Claims 8, 18, 9, 19, 10, and 20
Claims 8, 18, 9, 19, 10, and 20 recite recommending financial products, dealership funding products, and manufacturer incentives.
These limitations constitute commercial interactions and sales activities, which are expressly recognized abstract ideas under the USPTO eligibility guidance.
The recommendations merely specify additional business content generated by the system and do not improve any technology.
Therefore, these claims likewise fail to recite significantly more than the abstract idea.
Claims 1-3, 5, 7-13, 15, 17-20 are directed to the abstract idea of collecting dealership financial, credit, and inventory information, analyzing that information, and generating business recommendations regarding financing, credit management, inventory management, and dealership operations, which constitute certain methods of organizing human activity and mental processes. These claims do not integrate the judicial exception into a practical application and do not recite additional elements that amount to significantly more than the abstract idea itself. Accordingly, claims 1-3, 5, 7-13, 15, 17-20 are rejected under 35 U.S.C. §101.
Allowable Subject Matter
Claims 1-3, 5, 7-13, 15, 17-20 are allowable over prior art. As allowable subject matter has been indicated, applicant's reply must either comply with all formal requirements or specifically traverse each requirement not complied with. See 37 CFR 1.111(b) and MPEP § 707.07(a).
Conclusion
THIS ACTION IS MADE FINAL. 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 nonprovisional extension fee (37 CFR 1.17(a)) 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 mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ROKIB MASUD whose telephone number is (571)270-5390. The examiner can normally be reached Mon-Fri 8:00-5:00.
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/ROKIB MASUD/Primary Examiner, Art Unit 3627
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