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 .
Acknowledgements
This Office Action is in response to the original claims filed on August 19, 2024.
Claims 1-20 are currently pending and have been examined.
Information Disclosure Statement
The Information Disclosure Statements filed on June 30, 2025, July 17, 2025, October 15, 2025, February 18, 2026, March 13, 2026, and April 15, 2026 have been considered. Initialed copies of each respective Form 1449 are enclosed herewith.
Claim Objections
Claim 5 is objected to because of the following informalities: the claim recites “herein” which appears to be a typographical error of “wherein.” Appropriate correction is required.
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
Step 1 of the Subject Matter Eligibility Analysis for Products and Processes1 (“SME Analysis”):
Claims 1-20 are directed to one of the statutory categories.
Claims 1-10 are directed to a system.
Claims 11-19 are directed to an article of manufacture.
Claim 20 is directed to a process.
Step 2A- Prong One of the SME Analysis:
Claim 1 (representative of independent claim(s) 11 and 20) recites/describes the following steps:
during a call session between a call representative and a user, generate a content flow for the call representative to advance a claim process with the user, a request feature that enables the call representative to make requests to the user; and
in response to the call representative making a request to the user using the request feature, initiate communications with the user to facilitate the first request.
These steps, under its broadest reasonable interpretation, describe or set-forth processing an insurance claim between a call representative and a user, which amounts to a fundamental economic principle or practice (including hedging, insurance, mitigating risk); a commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations); and managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions). These limitations therefore fall within the “certain methods of organizing human activity” subject matter grouping of abstract ideas.
As such, Claim 1 recites an abstract idea.
Independent Claims 11 and 20 recite/describe nearly identical steps (and therefore also recite limitations that fall within this subject matter grouping of abstract ideas), and this/these claim(s) is/are therefore determined to recite an abstract idea under the same analysis.
Each of the depending claims likewise recite/describe these steps (by incorporation - and therefore also recite limitations that fall within this subject matter grouping of abstract ideas), and this/these claim(s) is/are therefore determined to recite an abstract idea under the same analysis. Any element(s) recited in a dependent claim that are not specifically identified/addressed by the Examiner under step 2A (prong two) or step 2B of this analysis shall be understood to be an additional part of the abstract idea recited by that particular claim.
As such, Claims 1-20 recite an abstract idea.
Step 2A- Prong Two of the SME Analysis:
The claim(s) recite the additional elements/limitations of
dynamically generate a user interface,
the user interface including a digital request feature,
digital requests,
using the digital request feature,
initiate communications with a computing device of the user to facilitate the first digital request.
The requirement to execute the claimed steps/functions using “a user interface” (via dynamically generating, and the user interface including a digital request feature) “digital requests,” “using the digital request feature,” and “initiate communications with a computing device of the user to facilitate the first digital request” are equivalent to adding the words “apply it” on a generic computer and/or mere instructions to implement the abstract idea on a generic computer. These limitations do not impose any meaningful limits on practicing the abstract idea, and therefore do not integrate the abstract idea into a practical application (see MPEP 2106.05(f)).
Furthermore, although the claims recite a specific sequence of computer-implemented functions, and although the specification suggests certain functions may be advantageous for various reasons (e.g., business reasons), the Examiner has determined that the ordered combination of claim elements (i.e., the claims as a whole) are not directed to an improvement to computer functionality/capabilities, an improvement to a computer-related technology or technological environment, and do not amount to a technology-based solution to a technology-based problem.
The dependent claims fail to include any additional elements. In other words, each of the limitations/elements recited in respective dependent claims are further part of the abstract idea as identified by the Examiner for each respective dependent claim (i.e. they are part of the abstract idea recited in each respective claim).
Therefore, the additional elements, or combination of additional elements, do not integrate the abstract idea into a practical application. Accordingly, the claims are directed to an abstract idea.
Step 2B of the SME Analysis:
As discussed above in “Step 2A – Prong 2”, the requirement to execute the claimed steps/functions using “a user interface” (via dynamically generating, and the user interface including a digital request feature) “digital requests,” “using the digital request feature,” and “initiate communications with a computing device of the user to facilitate the first digital request” are equivalent to adding the words “apply it” on a generic computer and/or mere instructions to implement the abstract idea on a generic computer. These limitations therefore do not qualify as “significantly more” (see MPEP 2106.05(f)).
Furthermore, it is noted that the determination that associating/storing data in a database is well-understood, routine, and conventional is supported by the Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015); OIP Techs., 788 F.3d at 1363, 115 USPQ2d at 1092-93), and MPEP 2106.05(d)(II), which note the well-understood, routine, conventional nature of associating/storing data in a database.
Furthermore, it is noted that receiving data/messages over a network is well-understood, routine, and conventional is supported by Symantec, 838 F.3d at 1321, 120 USPQ2d at 1362; TLI Communications LLC v. AV Auto. LLC, 823 F.3d 607, 610, 118 USPQ2d 1744, 1745 (Fed. Cir. 2016); OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1093 (Fed. Cir. 2015); buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014), and MPEP 2106.05(d)(II), which note the well-understood, routine, conventional nature of receiving data/messages over a network.
For example, the courts have recognized the following computer functions to be well‐understood, routine, and conventional functions when they are claimed in a merely generic manner:
performing repetitive calculations2,
receiving, processing, and storing data3,
electronically scanning or extracting data from a physical document4,
electronic recordkeeping5,
automating mental tasks6, and
receiving or transmitting data over a network, e.g., using the Internet to gather data7.
Viewing the additional limitations in combination also shows that they fail to ensure the claims amount to significantly more than the abstract idea. When considered as an ordered combination, the additional components of the claims add nothing that is not already present when considered separately, and thus simply append the abstract idea with words equivalent to “apply it” on a generic computer and/or mere instructions to implement the abstract idea on a generic computer.
The dependent claims fail to include any additional elements. In other words, each of the limitations/elements recited in respective dependent claims are further part of the abstract idea as identified by the Examiner for each respective dependent claim (i.e. they are part of the abstract idea identified by the Examiner to which each respective claim is directed).
As such, no additional element, or combination of additional claims elements are sufficient to ensure the claims amount to significantly more than the abstract idea identified above.
For the reasons stated above, Claims 1-20 as whole do not amount to significantly more than the abstract idea itself.
Claim Rejections - 35 USC § 112(b)
The following is a quotation of 35 U.S.C. 112(b):
(b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention.
The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph:
The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention.
Claims 2 and 12 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor, or for pre-AIA the applicant regards as the invention.
Claims 2 and 12 recite “the computing system automatically verifies the phone number by (i) contacting the computing device of the user, (ii) performing a lookup of the phone number in a database.” However, due to the grammatical structure of the phrase, it is unclear if verifying the phone number requires performing either (i) or (ii), or requires performing both (i) and (ii). For purposes of applying the prior art, the limitation will be interpreted as requiring either (i) or (ii).
Claim Rejections - 35 USC § 102
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
A person shall be entitled to a patent unless –
(a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention.
(a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention.
Claims 1, 4-8, 11, 14-18, and 20 are rejected under both 35 U.S.C. 102 (a)(1) and 35 U.S.C. 102 (a)(2) as being anticipated by James et al. (US 11,361,383 B1)(“James”).
As to Claim 1, Claim 11, and Claim 20, James discloses
a computing system comprising:
a network communication interface (“network interfaces” C.9, L.20);
one or more processors (“processors,” C.10, L.52); and
a memory (memory 1820) storing instructions that, when executed by the one or more processors, cause the computing system to: [non-transitory computer readable medium (memory 1820) storing instructions that, when executed by one or more processors (“processors,” C.10, L.52) of a computing system, cause the computing system to:][A computer-implemented method of facilitating digital requests for call sessions, the method being performed by one or more processors (“processors,” C.10, L.52) and comprising:]
during a call session between a call representative (Customer Service Representative (CSR) 106) and a user (“user,” C.3, L.40)(“The user uses the mobile application 102 to contact 108 the Customer Service Representative (CSR) 106. The Customer Service Representative receives the call…” C.3, L.40-42), dynamically generate a user interface (“application or tool 106 installed on a computer of a customer service representative,” C.3, L.30-31) comprising a content flow for the call representative to advance a claim process with the user (“The Customer Service Representative receives the call and uses the tool to send 110 a push notification to the user, the push notification signals to the mobile application 102 to start the information collection process.” C.3, L.40-45, “While the user is collecting information, as described further below, the customer service representative may be maintaining a voice conversation with the user.” C.3, L.58-60), the user interface including a digital request feature that enables the call representative to make digital requests to the user (“I’m now going to send a notification to your device. Once you accept, we’ll go through the claims process together.” “Send Push Notification” see Fig.13 at 1308 and 1310); and
in response to the call representative making a first digital request to the user using the digital request feature, initiate communications with a computing device of the user to facilitate the first digital request (“The input section 1304 includes instructions 1308 to send to the customer. The instructions 1308 are send to the customer when the customer service representative presses the send push notification button 1310.” C.6, L.42-45, “The push notification may be sent to the mobile device of the user by a push notification service 112. The mobile application 102 receives the push notification 114. In some implementations, the user has the option of accepting the push notification and starting a claim 120.” C.3, L.46-50).
Claims 4 and 14
James further discloses wherein the executed instructions further cause the computing system to: receive input indicating text message authorization from the user (“The push notification may be sent to the mobile device of the user by a push notification service 112. The mobile application 102 receives the push notification 114. In some implementations, the user has the option of accepting the push notification and starting a claim 120.” C.3, L.46-50); and based on the text message authorization, activate a set of digital request features that enable real-time communications with features of the computing device of the user (“The mobile application begins with an option to select which kind of information the user wish to provide. Referring to Fig.2, the user may select between providing accident details 202, claimant vehicle information 204, claimant driver information 206, and the claimant vehicle damage” C.4, L.46-52, “The data transfer service 124 also coordinates communication and screen ‘mirroring’ between the mobile application 102 and the CSR tool 106” C.4, L.1-4).
Claims 5 and 15
James further discloses wherein the set of digital request features include at least one of a guided content capture feature (see Fig.6), a damage input feature (see Fig.11), and a collision input feature (see “Accident Details” 202 in Fig.2, and corresponding interfaces Fig.3 and Fig.4).
Claims 6 and 16
James further discloses wherein the guided content capture feature enables the user to capture images of vehicle damage during the call session with the call representative (“While the user is collecting information, as described further below, the customer service representative may be maintaining a voice conversation with the user.” C.3, L.58-60), the images being automatically transmitted to the computing system to include in an information corpus of the claim process, the information corpus comprising all data gathered pertaining to the claim process (“Referring to FIG.6, the user is asked to take a picture of the VIN of the other vehicle. The user interface may include a guide 602 that provides queues to the user about how to center the camera and how close the camera should be (for example, so that the VIN fills the guides). Once the image is taken by the user, object recognition is used to determine the VIN value. As described above, the image and VIN value are then sent to the customer service representative. The customer service representative analyzes the picture and determines if the quality is sufficient for insurance claim purposes. If so, the picture and VIN are added to the claim.” C.5, L.17-28, “The data transfer service 124 saves claim data provided by either the mobile application 102 or the CSR tool 106.” C.4, L.66-67, C.5, L.1-3).
Claims 7 and 17
James further discloses wherein the damage input feature presents a damage input interface that includes a three-dimensional representation of a vehicle of the user (See Fig.11), and enables the user to indicate one or more damage locations (See Fig.11) and damage severity on the vehicle of the user during the call session (“Once the user has selected a part of the vehicle that is damaged, the mobile application may ask the user to take a picture of that part of the vehicle. In other implementations, the mobile application may ask the user to take pictures of the vehicles from each angle and may provide guidance to assist them in doing so.” C.6, L.3-8).
Claims 8 and 18
James further discloses wherein the collision input feature presents a collision input interface that enables the user to provide contextual details about a vehicle collision involving a vehicle of the user (see “Accident Details” 202 in Fig.2, and corresponding interfaces Fig.3 and Fig.4), the contextual details including a collision location (see Fig.4) and one or more vehicle trajectories (see Fig.3, i.e.: “Rear Ended” “Backed Into”).
Claim Rejections - 35 USC § 103
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention.
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
Claims 2 and 12 are rejected under 35 U.S.C. 103 as being unpatentable over James in view of Limas et al. (US 9,792,654 B1)(“Limas”).
Claims 2 and 12
As to Claims 2 and 12, James does not directly disclose wherein the first digital request comprises a phone number verification request in which the user provides the call representative with a phone number, and wherein, upon the call representative inputting the phone number provided by the user, the computing system automatically verifies the phone number by (i) contacting the computing device of the user, (ii) performing a lookup of the phone number in a database.
Limas teaches a first digital request comprises a phone number verification request in which the user provides the call representative with a phone number, and wherein, upon the call representative inputting the phone number provided by the user, the computing system automatically verifies the phone number (“The MSR may solicit the address of the insured’s mobile device or, with the MSR application and via the member data database 108 or other databases in the insurance claim processing system 100 in communication with the MSR computer, automatically determine the address of the insured’s mobile device having video capability. The address may be a URL address, an email address, mobile telephone number or any other address that identifies, or can be used to reach, the insured’s mobile device (at 216). With the retrieved address, the MSR computer 118 may invite the insured to join the video conference (at 218). A one-way video conference, where the video camera 122 on the insured’s mobile device 116 sends streaming video to the MSR computer 118, is preferably automatically started when the insured's positive response to the invitation is received (at 220, 222).” C.5, L.21-36) by (i) contacting the computing device of the user, (ii) performing a lookup of the phone number in a database (“The information stored in the member database may include account information for users of the system participating in a transaction. The user information may include information such as name, e-mail address, telephone number,…” C.2, L.18-22).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify James’s first digital request by the feature of Limas and in particular to include in James’s first digital request, a phone number verification request in which the user provides the call representative with a phone number, and wherein, upon the call representative inputting the phone number provided by the user, the computing system automatically verifies the phone number, as taught by Limas.
A person having ordinary skill in the art would have been motivated to combine these features because it would help to enhance security of the insurance claims processing (Limas, C.3, L.5-9).
Claims 3, 10, and 13 are rejected under 35 U.S.C. 103 as being unpatentable over James in view of Kim et al. (US 2017/0318012 A1)(“Kim”).
Claims 3 and 13
As to Claims 3 and 13, James further discloses wherein the first digital request comprises requesting a location of the user (“user interface screen 400 enables the user to identify where the accident occurred.” C.4, L.62-63, see also Fig.16), and wherein the executed instructions further cause the computing system to: based on authorizing location verification, communicate, over one or more networks, with a location-based resource of the computing device of the user to receive location data (“The mobile application may provide a default location based on the current location of the mobile device (as reported by a GPS device embedded in the mobile device).” C.4, L.63-66); and verify the location of the user using the location data (“The user is able to drag and drop the icon on a map to the location of the accident (as explained by the instructions 404) or type an address in a text field (404). Under the map the user interface may display the selected address 406 for easy confirmation.” C.5, L.1-5).
James does not directly disclose the user authorizing location verification.
Kim teaches a user authorizing location verification (“Examples of things that may be requested by a customer service agent…location data.” [0096]).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify James’s authorizing by the feature of Kim and in particular to include in James’s authorizing, the user authorizing location verification, as taught by Kim.
A person having ordinary skill in the art would have been motivated to combine these features because it would help to “preserve[s] privacy be preventing the answers from being directly observed by the customer service agent interacting with the user” (Kim, [0096]).
Claim 10
As to Claim 10, James does not directly disclose wherein the set of digital request features include a digital signature feature that enables the user to e-sign on or more documents during the call session.
Kim teaches a digital signature feature that enables the user to e-sign on or more documents during the call session (“Examples of things that may be requested by a customer service agent…electronic signature.” [0096], “The customer service agent may require that the customer provide authentication data, a menu selection, an approval, and/or other information. Specifically, the response may include a request for an electronic signature” [0146]).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify James’s digital request features by the feature of Kim and in particular to include in James’s digital request features, the digital signature feature that enables the user to e-sign on or more documents during the call session, as taught by Kim.
A person having ordinary skill in the art would have been motivated to combine these features because it would help to make the claims process more convenient for the user.
Claims 9 and 19 are rejected under 35 U.S.C. 103 as being unpatentable over James in view of Mousty (US 2021/0174456 A1)(“Mousty”).
Claims 9 and 19
As to Claims 9 and 19, James does not directly disclose wherein the set of digital request features include an injury input feature that comprises an injury interface enabling the user to indicate one or more injuries during the call session.
Mousty teaches an injury input feature (“By selecting an icon, a claim associate may be able to quickly enter information… As a result, insurance-related information given during the call with the customer may be entered accurately and stored for future use and reference in a time efficient manner, which may enhance the customer experience by lessening requirements on customer time, and/or not requiring the customer to repeat information or answer repetitive questions. Additionally or alternatively, the customer may be presented with a similar graphical user interface for self-entry of insurance-related information” [0023]) that comprises an injury interface enabling the user to indicate one or more injuries during the call session (“The loss reporting display screen may also include inputs or for entering person and property information that is to be added to the loss report. For example, one input (e.g., a virtual button, drop-down menu, etc.) may allow the claim associate to add, or begin adding, a new person to the loss report. If that input is activated, an additional input may allow the claim associate to select whether the new person is an insured, a claimant, or ‘other’ (e.g., a person having a different role in the loss event), and to enter information such as the person's name, the person's properties that were involved in the loss event, the person's home address, whether the person was injured in the loss event” [0024]).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify James’s digital request features by the feature of Mousty, and in particular to include in James’s digital request features, the injury input feature that comprises an injury interface enabling the user to indicate one or more injuries during the call session, as taught by Mousty.
A person having ordinary skill in the art would have been motivated to combine these features because it would help to expedite the insurance claims process.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure:
Dutta et al. (US 2020/0177730 A1) which discloses “[a] display of an option to interact with a human agent is caused during the ongoing speech synchronized web session. In response to a selection of the option by the caller, a co-browsing of the speech synchronized web session by the caller and the human agent is facilitated. The co-browsing of the speech synchronized web session and the contextual information stored in relation to the speech synchronized web session enable the human agent to provide assistance to the caller.” (Abstract).
Any inquiry concerning this communication or earlier communications from the examiner should be directed to MONICA A MANDEL whose telephone number is (571)270-7046. The examiner can normally be reached Monday and Thursday 10:00 AM-6:00 PM.
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.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Ilana Spar can be reached at (571) 270-7537. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000.
/M.A.M/Examiner, Art Unit 3622
/ILANA L SPAR/Supervisory Patent Examiner, Art Unit 3622
1 See Subject Matter Eligibility Analysis for Products and Processes in MPEP §2106 III.
2 See Flook, 437 U.S. at 594; Bancorp Services v. Sun Life, 687 F.3d 1266, 1278 (Fed. Cir. 2012) ("The computer required by some of Bancorp's claims is employed only for its most basic function, the performance of repetitive calculations, and as such does not impose meaningful limits on the scope of those claims."). But see Examples 3 (AI-3: digital image processing) and 25 (rubber manufacturing).
3 See Alice Corp., 134 S. Ct. at 2360. But see Example 4 (AI-4: global positioning system).
4 See Content Extraction, 776 F.3d at 1358 (optical character recognition).
5 See Alice Corp., 134 S. Ct. at 2359 (creating and maintaining "shadow accounts"); Ultramercial, 772 F.3d at 716 (updating an activity log).
6 See Benson, 409 U.S. at 65-67; Bancorp, 687 F.3d at 1275; CyberSource, 654 F.3d at 1375.
7 See Ultramercial, 772 F.3d at 716-17; buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355 (Fed. Cir. 2014); Cyberfone Systems, LLC v. CNN Interactive Group, Inc., 558 Fed. Appx. 988, 993 (Fed. Cir. 2014). But see DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d 1245, 1258 (Fed. Cir. 2014) ("Unlike the claims in Ultramercial, the claims at issue here specify how interactions with the Internet are manipulated to yield a desired result--a result that overrides the routine and conventional sequence of events ordinarily triggered by the click of a hyperlink." (emphasis added)).
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