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 .
Response to Arguments
Applicant's arguments filed 2/17/2026 have been fully considered but they are not persuasive.
The Terminal Disclaimer filed 2/17/2026 has been entered and acknowledged by the Examiner.
Applicant’s representative argues that the claims integrate the abstract idea into a practical application.
Applicant’s representative then states:
“the claimed invention defines a specific series of display elements that, although including individual steps that may be argued to each be unremarkable in their own right, are nevertheless unconventional in their combination since they define a combination of operations, and specifically simultaneously displayed pieces of information, that improve the user interaction without any predictable or routine outcome from the otherwise expected result of combining simple steps…”.
In response, the claims fail to recite technological implementation details of how the claimed functions are being realized. Claims of this nature are almost always found to be ineligible for patenting under Section 101." Beteiro, LLC V. DraftKings Inc., 104 F.4th 1350, 1356 (Fed. Cir. 2024). The specification does not even provide details of a specific architecture or means or structures or specific computer executed modules for performing the claimed functions. Taken claim 1 as an example, Claim 1 recites an improvement to the business of:
“determining, by the finance server, a one or more past card-based transactions that are eligible for refinancing, the one or more past card-based transactions being eligible for refinancing based in part on being above a predetermined minimum value, determining refinancing terms for the one or more past card-based transactions, simultaneously causing display, at the client computer, of information associated with both the one or more past card-based transactions along with a selectable element for initiating refinancing of the one or more past card-based transactions, and responsive to selection of the selectable element at the client computer, causing display of the refinancing terms at the client computer, wherein the refinancing terms define a number of payments and a repayment plan”.
The claims "do[es] not improve the functioning of the client computer, or the financial server or make it operate more efficiently, or solve any technological problem." Trading Techs. Int'l, Inc. V. IBG LLC, 921 F.3d 1084, 1093 (Fed. Cir. 2019). "Nothing in the claim[s], understood in light of the specification, calls for anything but preexisting computers and displays, programmed using techniques known to skilled artisans, to present the new arrangement of information." Brumfield V. IBG LLC, 97 F Ath 854, 868 (Fed. Cir. 2024). The claims also do not show a technical improvement in the architecture of a processor using a computing logic of the computing system or the mobile device. The recited functions involve generic or conventional functions and setup of a basic computer system.
The mere recitation of a client computer or financial server performing their expected functions cannot transform a patent-ineligible abstract idea into a patent-eligible invention as stated in Alice Corp., 134S.Ct. at 2358; DDR Holdings, LLC V. Hotels.com, L.P., 773 F.3d 1245, 1256 (Fed. Cri. 2014) ("And after Alice, there can remain no doubt: recitation of generic computer limitations does not make an otherwise ineligible claim patent-eligible. (citation omitted)). Thus, if a patent's recitation of a computer amounts to a mere instruction to 'implement' an abstract idea 'on a computer', that addition cannot impart patent eligibility." Alice Corp., 134 S. Ct. at 2358 (internal citation omitted). The claimed client computer and financial server are merely a field of use that attempts to limit the abstract idea to a particular technological environment.
Each of the independent claims uses generic computer technology (such as a generic computing system and mobile device) for determining displaying data, and providing the data to a computing system as such do not recite an improvement to a particular computer technology. See, e.g., McRO, Inc. v. Bandai Namco Games Am. Inc., 837 F .3 d 1299, 1314-1315 (Fed. Cir. 2016) ( finding claims not abstract because they "focused on a specific asserted improvement in computer animation").
The claims are void of anything significantly more than the abstract idea itself.
Applicant’s representative argues that the recited elements of at least claims 1 and 11 amount to a significantly more than the judicial exception.
In response, the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because :
The additional elements when considered both individually and as a combination do not amount to significantly more than the abstract idea. The claims recite the additional elements of a client computer and a financial server which when taken individually or as a whole is/are seen as general purpose computer or a computer system (see the applicant’s specification). These claimed devices are noted to perform routine computer functions such as determining data, and displaying data on a computer screen or graphical user interface.
The claimed client computer and financial server are seen as generic computers performing generic functions without an inventive concept as such do not amount to significantly more. These devices are simply a field of use that attempts to limit the abstract idea to a particular environment. The type of data being manipulated does not impose meaningful limitations. Looking at the elements as a combination does not add anything more than the elements analyzed individually. Therefore the claims do not amount to significantly more than the abstract idea itself.
Accordingly, the claims are not patent eligible.
The prior rejection is repeated below.
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.
Subject Matter Eligibility Standard
When considering subject matter eligibility under 35 U.S.C. 101, it must be determined whether the claim is directed to one of the four statutory categories of invention, i.e., process, machine, manufacture, or composition of matter.
Specifically, claim 1 is directed to a method. Claim 11 is directed to a system. Each of
the claims falls under one of the four statutory classes of invention under step 1.
If the claim does fall within one of the statutory categories, it must then be determined whether the claim is directed to a judicial exception (i.e., law of nature, natural phenomenon, and abstract idea) under step 2.
Step 2A, Prong One: For example, the claims recite the following limitations that are understood to recite an abstract idea absent the bolded limitations:
Claim 1 recites:
A method for displaying information associated with card purchases on a client computer in communication with a finance server, the method comprising:
responsive to a pre-purchase request from a customer via the client computer, determining, by the finance server, a spending limit for a pay-over time loan to be extended relative to one or more card purchases;
causing display at the client computer of loan terms and an offer for selection by the customer to accept the offer;
determining, by the finance server, a one or more past card-based transactions that are eligible for refinancing, the one or more past card-based transactions being eligible for refinancing based in part on being above a predetermined minimum value;
determining refinancing terms for the one or more past card-based transactions;
simultaneously causing display, at the client computer, of information associated with both the one or more past card-based transactions along with a selectable element for initiating refinancing of the one or more past card-based transactions; and
responsive to selection of the selectable element at the client computer, causing display of the refinancing terms at the client computer,
wherein the refinancing terms define a number of payments and a repayment plan.
Claim 2 recites: providing a client database in communication with the finance server, and saving bank account sign-in information and card- based sign-in information for a client in the client database.
Claim 3 recites: wherein the client computer is a mobile phone.
Claim 4 recites: wherein causing display of the refinancing terms for the one or more past card-based transactions includes causing display of multiple options for the number of payments and a refinancing fee for each respective one of the multiple options.
Claim 5 recites: wherein responsive to the selectable element being selected for more than one card-based transaction, the finance server further causes displaying, on a display of the client computer, loan repayment information for a combination of each of the more than one card-based transactions.
Claim 6 recites: causing display of the cumulative total of the combination of the more than one card-based transactions and a refinancing fee.
Claim 7 recites: causing display of the refinancing terms comprises causing display of payment dates for each of the number of payments, and an amount of each payment on the displayed payment dates.
Claim 8 recites: causing display of the refinancing terms comprises executing a client-side application at the client computer to cause display of the refinancing terms at a display of the client computer.
Claim 9 recites: wherein the one or more card-based transactions are associated with a same type of card.
Claim 10 recites: wherein the same type of card comprises a credit card.
Claim 11 recites: An apparatus for facilitating refinancing transactions for eligible prior purchases on a client computer in communication with a finance server, the apparatus comprising processing circuitry configured to:
responsive to a pre-purchase request from a customer via the client computer, determine, by the finance server, a spending limit for a pay-over time loan to be extended relative to one or more card purchases;
cause display at the client computer of loan terms and an offer for selection by the customer to accept the offer;
determine, by the finance server, one or more past card-based transactions that are eligible for refinancing, the one or more past card-based transactions being eligible for refinancing based in part on being above a predetermined minimum value;
determine refinancing terms for the one or more past card-based transactions;
simultaneously cause display, at the client computer, of information associated with the one or more card-based transactions along with a selectable element for initiating refinancing of the one or more card-based transactions; and
responsive to selection of the selectable element at the client computer, cause display of the refinancing terms at the client computer,
wherein the refinancing terms define a number of payments and a repayment plan.
Claim 12 recites: wherein the processing circuitry is further configured to provide a client database in communication with the finance server, and save bank account sign-in information and card-based sign-in information for a client in the client database.
Claim 13 recites: wherein the client computer is a mobile phone.
Claim 14 recites: wherein causing display of the refinancing terms includes causing display of multiple options for the number of payments and a refinancing fee for each respective one of the multiple options.
Claim 15 recites: wherein responsive to the selectable element being selected for more than one card-based transaction, the finance server further causes displaying, on a display of the client computer, loan repayment information for a combination of each of the one or more card-based transactions.
Claim 16 recites: wherein the processing circuitry is further configured to cause display of the cumulative total of the combination of the one or more card-based transactions and a refinancing fee.
Claim 17 recites: wherein causing display of the refinancing terms comprises causing display of payment dates for each of the number of payments, and an amount of each payment on the displayed payment dates.
Claim 18 recites: wherein causing display of the refinancing terms comprises executing a client-side application at the client computer to cause display of the refinancing terms at a display of the client computer.
Claim 19 recites: wherein the one or more card-based transactions are associated with a same type of card.
Claim 20 recites: wherein the same type of card comprises a credit card.
The above limitations, under their broadest reasonable interpretation, fall within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas, enumerated in MPEP 2106.04(a)(2)(II), such as managing commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations).
The BRI describes steps or functions of: determining, a one or more past card-based transactions that are eligible for refinancing, the one or more past card-based transactions being eligible for refinancing based in part on being above a predetermined minimum value, and determining refinancing terms for the one or more past card-based transactions.
Step 2A, Prong Two: This judicial exception is not integrated into a practical application. In particular, the claims recite the above bolded limitations noted in the claims as understood to be the additional limitations:
These limitations perform steps or functions of :
determining, a one or more past card-based transactions that are eligible for refinancing, the one or more past card-based transactions being eligible for refinancing based in part on being above a predetermined minimum value, and determining refinancing terms for the one or more past card-based transactions using a computer and a finance sever, merely amount to instructions to implement an abstract idea on a computer or merely using a computer as a tool to perform an abstract idea– see MPEP 2106.05(f). See the applicant's specification for guiding interpretation of these claim features, describing implementation with generic commercially available devices or any machine capable of executing a set of instructions, similarly describing usage of general and special purpose computer.
The apparatus or server and client device or computer are similarly understood in light of applicant's specification as mere usage of any arrangement of computer software or hardware intermediate components potentially using networks to communicate between systems now available or later developed may be used, which are properly understood to be mere instructions to apply the abstraction using a computer. Performance of a monitoring step or function by a system or server or device amounts to data gathering function and amounts to performing steps which amount to insignificant extra-solution activity of data gathering – see MPEP 2106.05(g).
Performing steps by a client device or server or computer with a processor and memory merely limit the abstraction to computer field by execution by generic computers – see MPEP 2106.05(h). As noted in MPEP 2106.04(d), limitations which amount to instructions to implement an abstract idea on a computer or merely using a computer as a tool, limitations which amount to insignificant extra-solution activity, and limitations which amount to generally linking to a particular technological environment do not integrate a judicial exception into a practical application.
The claimed client computer or server or device is understood to be similar to Alappat, which as noted in MPEP 2106.05(b)(I), is superseded, and the correct analysis is to look whether the added elements integrate the exception into a practical application or provide significantly more than the judicial exception.
Consideration of these steps or functions as a combination does not change the analysis as they do not add anything compared to when the steps pr functions are considered separately. The claims recite a particular sequence of determining, a one or more past card-based transactions that are eligible for refinancing, the one or more past card-based transactions being eligible for refinancing based in part on being above a predetermined minimum value, and determining refinancing terms for the one or more past card-based transactions using a computer and a finance sever.
Performance of these steps technologically does present a meaningful limit to the scope of the claim which would reasonably integrate the abstraction into a practical application.
Step 2B: The elements discussed above with respect to the practical application in Step 2A, prong 2 are equally applicable to consideration of whether the claims amount to significantly more. Accordingly, the claims fail to recite additional elements which, when considered individually and in combination, amount to significantly more. Reconsideration of these elements identified as insignificant extra-solution activity as part of Step 2B does not change the analysis. Determining data and displaying data has been recognized by the courts as well-understood, routine, and conventional (See MPEP 2106.05(d)(II), citing Symantec, 838 F.3d at 1321, 120 USPQ2d at 1362 (utilizing an intermediary computer to forward information); TLI Communications LLC v. AV Auto. LLC, 823 F.3d 607, 610, 118 USPQ2d 1744, 1745 (Fed. Cir. 2016) (using a telephone for image transmission); OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1093 (Fed. Cir. 2015) (sending messages over a network); buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014) (computer receives and sends information over a network)).
Independent claim 11 recites similar limitations as claim 1.
Positively reciting a circuitry does not change the analysis as these aspects are properly considered as additional elements which amount to instructions to apply it with a computer.
These claimed elements also as found in the dependent claims are also recited at a high level of generality such that they amount to no more than mere instructions to apply the exception using a generic component. In processing the claims, it is noted that the recitation of these additional elements do not impact the analysis of the claims because these elements in combination are noted only to be a general purpose computer for performing basic or routine computer functions. These claimed elements are noted to a be a generic computer for determining and displaying data.
These additional elements do not overcome the analysis as these elements are merely considered as additional elements which amount to instructions to be applied to the generic apparatus or computer.
Accordingly, the 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 elements are also seen as generic computer components and performing generic functions without an inventive concept as they do not amount to significantly more than the abstract idea. The claimed additional elements are interpreted as being recited at a high level of generality and even if the claims recited in the affirmative.
The type of data being manipulated does not impose meaningful limitations or renders the idea less abstract. Looking at the elements as a combination, the elements do not add anything more than the elements analyzed individually. Therefore, the claims do not amount to significantly more than the abstract idea itself.
Applicant is reminded that a statutory claim would recite an automated machine implemented method or system with specific structures for performing the claimed invention so as to provide an improvement to another technology or technical field, an improvement to the functioning of the computer itself, or meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment. Each claim as a whole, does not amount to significantly more than the abstract idea itself. This is because the claims do not effect an improvement to another technology or technical field; the claims do not amount to an improvement to the functioning of a computer itself; and the claims do not move beyond a general link of the use of an abstract idea to a particular technological environment.
Accordingly, claims 1-20 are directed to an abstract idea.
The prior art taken alone or in combination failed to teach or suggest:
“determining refinancing terms for the one or more past card-based transactions,; simultaneously causing display, at the client computer, of information associated with both the one or more past card-based transactions along with a selectable element for initiating refinancing of the one or more past card-based transactions; and responsive to selection of the selectable element at the client computer, causing display of the refinancing terms at the client computer, wherein the refinancing terms define a number of payments and a repayment plan” as recited in independent claim 1 and as similarly recited in independent claim 11.
Van Os (US Patent No. 10783576 B1 ) discloses many user interfaces for provisioning an electronic device with an account. In some embodiments, exemplary user interfaces for providing usage information of an account are described. In some embodiments, exemplary user interfaces for providing visual feedback on a representation of an account are described. In some embodiments, exemplary user interfaces for managing the tracking of a category are described. In some embodiments, exemplary user interfaces for managing a transfer of items are described. In some embodiments, exemplary user interfaces for managing an authentication credential connected with an account are described. In some embodiments, exemplary user interfaces for activating a physical account object are described. In some embodiments, exemplary user interfaces for managing balance transfers are described.
Rieger (US Patent No. 10664907 B2) discloses a systems and computer-implemented method to determine recurring loan payments for a financing plan. The system is configured to determine a predetermined interest rate based on a comparison of the expected profits to configurable threshold profit levels; and compute a value for the recurring loan payments based on the initial loan amount, the predetermined interest rate and the predetermined term and frequency of payments. A new interest rate may be computed in response to receiving an interest rate buy down activation from a user device, wherein a portion of the expected profits is applied to buy down the interest. Comparative financing plans are generated including and excluding the sale of products wherein loan parameters and interest rates are adjusted so that the loan payments for a first financing plan are the same as or within a configurable range of the loan payments for a second financing plan.
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.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to FRANTZY POINVIL whose telephone number is (571)272-6797. The examiner can normally be reached M-Th 7:00AM to 5:30PM.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Michael Anderson can be reached at 571-270-0508. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/fp/
/FRANTZY POINVIL/Primary Examiner, Art Unit 3693
March 6, 2026