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 .
Claim Rejections – 35 U.S.C. § 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 an abstract idea without significantly more.
Claim 1
Claim 1 is rejected under 35 U.S.C. § 101 because the claimed invention is directed to a judicial exception (i.e., an abstract idea) without reciting significantly more.
Step 2A, Prong 1 (Identification of the Abstract Idea). The claim recites a device configured to determine priority levels based on assigned weights (a first weight based on alert type, a second based on account type, and a third based on an action date threshold)1 and to organize and display information in a stacked order based on those calculations. This constitutes a mental process, which is a recognized category of abstract ideas. The steps of evaluating account attributes, assigning weights to determine priority, and ordering items so the most critical one is on top are concepts that can be, and historically have been, performed practically in the human mind or with a pen and paper. For instance, a person managing their personal finances could mentally weigh the urgency of a fraud alert against an upcoming bill deadline, and subsequently organize their physical bank statements or bills into a stack where the most important document overlaps the others.
Step 2A, Prong 2 (Integration into a Practical Application). The claim does not integrate the abstract idea into a practical application. The additional elements in the claim merely recite generic computer functions: presenting interaction elements, detecting a selection, modifying the presentation, and displaying account information.
In Electric Power Group, LLC v. Alstom S.A., 830 F.3d 1350 (Fed. Cir. 2016), the Federal Circuit established that a process comprising collecting information, analyzing it according to a set of rules, and displaying the results of the analysis is an abstract idea. The court specifically noted that merely presenting the results of abstract calculations on a display or user interface does not provide the necessary integration into a practical application, as the presentation of information is itself an abstract concept. Here, the claim merely collects account data, analyzes it using weighting rules, and displays the prioritized results.
Furthermore, the limitation that the device “dynamically” presents the interaction elements does not integrate the mental process into a practical application. In the context of patent eligibility, claiming that a computer performs a task “dynamically” merely denotes that the system is executing the abstract mental steps of calculating and presenting the data quickly, automatically, or in real-time. Relying on the inherent speed and processing capabilities of a generic computer to “dynamically” update a display does not transform a mental process into a patent-eligible technological improvement. Moreover, “dynamically” is broadly recited in a way that simply requires the accounts to be ordered differently depending on the outcome of the priority level calculation at any given time.
Step 2B (Significantly More). Looking at the claim as a whole, it does not recite “significantly more” than the abstract idea itself. The hardware recited in the preamble (“one or more memories; and one or more processors”) is invoked at a high level of generality to perform basic, general-purpose computer functions: storing data, executing logical rules, detecting a user click, and rendering a user interface. The claim does not provide a specific, technical improvement to the functioning of the computer, the display hardware, or the underlying user interface technology itself. Instead, it merely uses generic computer components as a tool to automate the abstract mental process of prioritizing and displaying account information. Therefore, the claim is not patent eligible.
Claim 2
Claim 2 is rejected under 35 U.S.C. § 101 because the claimed invention is directed to a judicial exception (i.e., an abstract idea) without reciting significantly more.
The rejection of Claim 1 is incorporated herein by reference. Claim 2 further recites that the “display of the account information was overlapped by the primary interaction element prior to the modification.” This additional limitation merely describes the visual arrangement of the data on a graphical user interface (GUI). The concept of overlapping or hiding information until a user interacts with it is an ornamental display technique used to organize information. It does not integrate the abstract mental process of prioritizing accounts into a practical application, nor does it provide a specific technological improvement to the functioning of the device. It fails to add “significantly more” to the abstract idea.
Claim 3
Claim 3 is rejected under 35 U.S.C. § 101 because the claimed invention is directed to a judicial exception (i.e., an abstract idea) without reciting significantly more.
The rejection of Claim 1 is incorporated herein by reference. Claim 3 further recites that “each of the plurality of interaction elements is associated with account information related to a corresponding account identifier.” This limitation is directed to the abstract concept of data association and data gathering—specifically, linking a visual element to its corresponding underlying data. Merely storing or linking records in a computer memory is a generic computer function. The claim does not recite any specific, unconventional technological mechanism for how this association is achieved. Consequently, this generic data association does not integrate the abstract idea into a practical application or add significantly more to the claim.
Claim 4
Claim 4 is rejected under 35 U.S.C. § 101 because the claimed invention is directed to a judicial exception (i.e., an abstract idea) without reciting significantly more.
The rejection of Claim 1 is incorporated herein by reference. Claim 4 further recites that the “primary interaction element includes a first area that is larger than a second area of the secondary interaction element.” This limitation merely dictates the ornamental details of the output. Limitations concerning the ornamental arrangement of output data do not make an abstract idea any less abstract. See Affinity Labs of Tex. v. DIRECTV, LLC, 838 F.3d 1253, 1263 (Fed. Cir. 2016) (“a func-tion-ally described display of information . . . does not cross out of the abstract idea category”); Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d 1350, 1355 (Fed. Cir. 2016) (holding that the display of a visualization, no matter how complex, does not add significantly more to an abstract idea when “the displays needed for that purpose are anything but readily available”). They do not solve a technical problem or improve the functioning of the display hardware, and therefore fail to amount to significantly more than the abstract idea of organizing and presenting prioritized information.
Claim 5
Claim 5 is rejected under 35 U.S.C. § 101 because the claimed invention is directed to a judicial exception (i.e., an abstract idea) without reciting significantly more.
The rejection of Claim 1 is incorporated herein by reference. Claim 5 further recites that the “secondary interaction element includes a second area that is larger than a first area of the primary interaction element after the modification.” Similar to Claim 4, this limitation simply describes changing the physical dimensions of a generic GUI element in response to a user selection. This limitation merely dictates the ornamental details of the output. Limitations concerning the ornamental arrangement of output data do not make an abstract idea any less abstract. See Affinity Labs of Tex. v. DIRECTV, LLC, 838 F.3d 1253, 1263 (Fed. Cir. 2016) (“a func-tion-ally described display of information . . . does not cross out of the abstract idea category”); Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d 1350, 1355 (Fed. Cir. 2016) (holding that the display of a visualization, no matter how complex, does not add significantly more to an abstract idea when “the displays needed for that purpose are anything but readily available”). They do not solve a technical problem or improve the functioning of the display hardware, and therefore fail to amount to significantly more than the abstract idea of organizing and presenting prioritized information.
Claim 6
Claim 6 is rejected under 35 U.S.C. § 101 because the claimed invention is directed to a judicial exception (i.e., an abstract idea) without reciting significantly more.
The rejection of Claim 1 is incorporated herein by reference. Claim 6 further recites that the “plurality of interaction elements includes rounded corners to form a visual representation of transaction cards.” This limitation introduces a purely aesthetic, skeuomorphic design choice (making a digital interface look like a physical object). Visual or aesthetic features that do not provide a functional technological benefit do not carry patentable weight under § 101. See Affinity Labs of Tex. v. DIRECTV, LLC, 838 F.3d 1253, 1263 (Fed. Cir. 2016) (“a func-tion-ally described display of information . . . does not cross out of the abstract idea category”); Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d 1350, 1355 (Fed. Cir. 2016) (holding that the display of a visualization, no matter how complex, does not add significantly more to an abstract idea when “the displays needed for that purpose are anything but readily available”). They do not solve a technical problem or improve the functioning of the display hardware, and therefore fail to amount to significantly more than the abstract idea of organizing and presenting prioritized information.
Rendering rounded corners on a display does not integrate the abstract idea into a practical application, nor does it represent an unconventional technological step. Therefore, it does not add significantly more to the abstract idea.
Claim 7
Claim 7 is rejected under 35 U.S.C. § 101 because the claimed invention is directed to a judicial exception (i.e., an abstract idea) without reciting significantly more.
The rejection of Claim 1 is incorporated herein by reference. Claim 7 further recites that the “type of alert includes at least one of: a fraud alert, or an impending action alert.” This limitation merely specifies the content or category of the data being analyzed within the mental process. As established by the Federal Circuit, limiting an abstract idea to a specific data environment or a specific type of information (e.g., fraud or impending actions) does not render the concept less abstract. It simply narrows the scope of the abstract calculation. Collecting and analyzing specific financial data categories relies on general-purpose computer functions and fails to provide significantly more to the claim.
Claims 8–14
Claims 8–14 are rejected for the same reasons as claims 1–7, except it is acknowledged at step 1 that they are directed to an apparatus rather than a machine.
Claims 15–20
Claims 15–20 are rejected for the same reasons as claims 1–6, except it is acknowledged at step 1 that they are directed to a process rather than a machine.
Claim Rejections – 35 U.S.C. § 112
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 1–20 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 applicant regards as the invention.
Independent claims 1, 8, and 15 each say that the priority levels (one for each of the plurality of account identifiers) are each determined based on three weights. However, the description of the weights in claims 1, 8, and 15 is exclusively for the primary account. In other words, all three claims require every secondary account’s priority level to be based on the weight values for the primary account. If read literally, the claim language results in all of the accounts being assigned an identical priority level, i.e., a copy of the priority level determined by the weights associated with the primary account. This would render the claims inoperable, since they do not recite any mechanism for resolving ties between priority levels.
Moreover paragraph 17 exacerbates the problem, because as paragraph 17 correctly explains, the priority levels are based on the weights applied to each of the accounts, not merely the primary account. See MPEP § 2173.03 (“A claim, although clear on its face, may also be indefinite when a conflict or inconsistency between the claimed subject matter and the specification disclosure renders the scope of the claim uncertain as inconsistency with the specification disclosure or prior art teachings may make an otherwise definite claim take on an unreasonable degree of uncertainty.”).
The Examiner recommends the following correction to each of the independent claims to correct the problem:
… wherein the priority levels for each account identifier are determined based on: a first weight based on a type of alert associated with each account identifier of the plurality of account identifiers, a second weight based on a type of account associated with each account identifier, and a third weight based on a threshold time frame associated with an action date associated with each account identifier
Claims 2–7, 9–14, and 16–20 are each rejected because they depend from one of claims 1, 8, or 15, and therefore, incorporate the indefinite subject matter of their parent claims by reference.
Claim Rejections – 35 U.S.C. § 102
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 1–7 are rejected under 35 U.S.C. § 102(a)(1) as being anticipated by U.S. Patent Application Publication No. 2014/0244494 A1 (“Davis”).
Claim 1
Davis discloses:
A device comprising: one or more memories; and one or more processors, coupled to the one or more memories, configured to:
“Stored in the memory [of an electronic device] is an electronic payment module comprising software instructions that cause the device to present a user interface (UI) on the display. One such user interface is shown in FIG. 1.” Davis ¶ 26.
dynamically present, based on priority levels associated with a plurality of account identifiers associated with an account, a plurality of interaction elements corresponding to the plurality of account identifiers,
“The depicted user interface shows graphical representations of plural different cards of the sort typically carried in a user's wallet, e.g., credit cards, shopping loyalty cards, frequent flier membership cards, etc. (‘wallet cards’).” Davis ¶ 26. In other words, each graphical representation is an interaction element that corresponds to a respective card (i.e., different accounts).
The user interface is a dynamic presentation because “[t]he software enables the user to scroll through the collection of cards and select one or more for use in a payment transaction, using a fliptych arrangement.” Davis ¶ 26.
With respect to the presentation being “based on priority levels,” Davis further incorporates by reference the “Details of the Cover Flow fliptych interface used by Apple . . . in published patent application 20080062141.” Davis ¶ 144. Looking to the incorporated patent application, we can confirm that the Cover Flow fliptych interface indeed calls for sorting the images in the Cover Flow fliptych arrangement according to “various sort criteria.” U.S. Patent Application Publication No. 2008/0062141 A1 (hereafter “Chandhri”) ¶¶ 136 and 216.
wherein the priority levels are determined based on: a first weight based on a type of alert associated with a primary account identifier of the plurality of account identifiers, a second weight based on a type of account associated with the primary account identifier, and a third weight based on a threshold time frame associated with an action date associated with the primary account identifier,
The following discussion, and this rejection in general, is based on a reading of claim 1 where the above claim language is considered optional. For the sake of compact prosecution, a separate ground of rejection is provided later in this Office Action, in which the above claim language is treated as required by the claim, to help the Applicant see the current coverage of the prior art.
Nevertheless, the above claim language fails to limit the device of claim 1 to a device that determines the priority levels, and therefore, does not require a prior art determine the priority levels mased on any of the three weights recited above. This is because “[c]laim scope is not limited by claim language that suggests or makes optional but does not require steps to be performed, or by claim language that does not limit a claim to a particular structure.” MPEP § 2111.04.
The above claim language is non-limiting as to the device of claim 1 because it uses the passive voice (“are determined”), in contrast to the remaining steps recited in the rest of claim 1 (e.g., “dynamically present,” “modify,” and “display”). Principles of claim construction presume that this shift in verb tense also shifts the scope of the claim.2 In this case, the shift in scope is that the device of claim 1 is not required to determine the priority levels, in contrast to the other operations recited in the claim (i.e., the device of claim 1 must still perform the dynamically presenting, modifying, and displaying). The passive voice, by definition, removes the subject from the verb—the device of claim 1 does not necessarily determine the priority levels, rather, they merely “are determined” by the time they’ve arrived at the device.
Importantly, this interpretation is further supported by the Applicant’s written description. The written description does not disclose a single device responsible for both the dynamic presentation of accounts and the determination of priority levels. Instead, the specification splits these functions into two different devices: a server (such as processing system 210 in FIG. 2) is responsible for calculating the priority levels, and simply communicates those pre-calculated priority levels to the separate user device (e.g., user device 230 in FIG. 2), which then displays the accounts according to the given priority levels, totally ignorant of how the priority levels were chosen. Claim 1 is clearly directed to the user device, because every other step recited in the active voice is a step that the written description discloses for the user device, rather than for the processing system/server 210.
Since claim 1 is directed to what the user device is configured to do, rather than some other, external device (i.e., the server), this means the prior art does not need to teach or disclose how the priority levels are determined, much less the three different weights involved in determining the priority levels.
and wherein a primary interaction element, of the plurality of interaction elements and associated with the primary account identifier, overlaps a secondary interaction element, of the plurality of interaction elements and associated with a secondary account identifier of the plurality of account identifiers, based on the priority levels;
FIG. 1 discloses that the currently-selected card overlaps at least two of the other non-selected cards in the stack. See Davis FIG. 1.
modify, based on detecting a selection of the secondary interaction element, the dynamic presentation of the plurality of interaction elements;
“The software enables the user to scroll through the collection of cards and select one.” Davis ¶ 26.
and display, based on the modification, account information associated with the secondary account identifier.
“In the illustrated embodiment, after the user has scrolled to a desired card . . . it is selected for use in the transaction by a user signal, such as a single-tap on the touch screen.” Davis ¶ 26; see also Chandhri ¶ 103 and FIG. 7 (describing how secondary images 94 in the fliptych arrangement move to the primary position 92 in response to a scrolling input). As a result, the face of the card is fully displayed, and most (if not all) of the cards illustrated in FIG. 1 have one or more pieces of account information printed on their face.
The scrolling to reveal even the full face of a card alone is sufficient to anticipate this claim element. However, Davis further discloses this step even under a narrower reading of the claim language: “A double-tap causes the depicted card to virtually flip-over and reveal, on its back side, information about recent account usage and available credit.” Davis ¶ 27.
Claim 2
Davis discloses the device of claim 1,
wherein display of the account information was overlapped by the primary interaction element prior to the modification.
As shown in FIG. 1, prior to scrolling, the currently-selected Visa® card overlaps other non-selected cards to the left and right of the Visa®. Scrolling to one of those cards causes it to become the selected card, and thus be displayed in the same manner as the Visa® was displayed (i.e., non-overlapped) prior to the scroll. See Davis FIG. 1; see also Chandhri ¶ 106 (explaining that “each consecutive secondary image partially falls underneath the previous image thereby leaving an edge portion exposed 87,” until, “[d]uring browsing, when the images 86 are moved from the primary position 92 to subsequent secondary positions 94, the images 86 are reconfigured as a partially exposed edge portion 87 and when the images 86 are moved from secondary position 94 to the primary position 92, the images are reconfigured to be a full image view”).
Claim 3
Davis discloses the device of claim 1,
wherein each of the plurality of interaction elements is associated with account information related to a corresponding account identifier of the plurality of account identifiers.
“The depicted user interface shows graphical representations of plural different cards of the sort typically carried in a user's wallet, e.g., credit cards, shopping loyalty cards, frequent flier membership cards, etc.” Davis ¶ 26. “The card number, a logo distinctive of the selected payment service (e.g., an American Express, Visa or MasterCard logo) and/or card issuer (e.g., US Bank, Bank of America) can be included in the artwork, for viewing by the user.” Davis ¶ 31.
Claim 4
Davis discloses the device of claim 1,
wherein the primary interaction element includes a first area that is larger than a second area of the secondary interaction element prior to the modification.
The currently selected card is displayed much larger than the other, non-selected cards. Davis FIG. 1. The discussion of the Cover Flow fliptych arrangement, which Davis incorporates by reference at paragraph 144, confirms this. See Chandhri ¶ 107.
Claim 5
Davis discloses the device of claim 1,
wherein the secondary interaction element includes a second area that is larger than a first area of the primary interaction element after the modification.
The currently selected card is displayed much larger than the other, non-selected cards. Davis FIG. 1. The discussion of the Cover Flow fliptych arrangement, which Davis incorporates by reference at paragraph 144, confirms this. See Chandhri ¶ 107.
Claim 6
Davis discloses the device of claim 1,
wherein the plurality of interaction elements includes rounded corners to form a visual representation of transaction cards.
Davis’s FIG. 1 clearly discloses that the corners of the cards are rounded, because they are meant to depict “different cards of the sort typically carried in a user's wallet.” Davis ¶ 26.
Claim 7
Davis discloses the device of claim 1, which claim 7 incorporates by reference, for all of the reasons provided in the rejection of claim 1 above. Davis does not need to further disclose that “the type of alert includes at least one of: a fraud alert, or an impending action alert” to anticipate claim 7, because the “type of alert” is a further limitation of the “first weight” involved in determining the priority levels. Claims 1 and 7 are not directed to a device that determines priority levels, they are directed to a device that displays interaction elements in a user interface based on priority levels that are already determined by a separate entity.
Since the language of claim 7 is merely a further description of something that is allowed to happen externally from the claimed device under the broadest reasonable interpretation of the claim, Davis need not disclose this further description of activity performed by an entity that is external to the user’s device itself. See MPEP § 2111.04 (“Claim scope is not limited by claim language that suggests or makes optional but does not require steps to be performed, or by claim language that does not limit a claim to a particular structure”); see also Nazomi Communications, Inc., v. Nokia Corp., 739 F.3d 1339, 1345 (Fed Cir. 2014) (explaining that “a description of the environment in which a claimed invention operates” is to be “distinguished” from “a limitation on the claimed invention itself.”).
Claim Rejections – 35 U.S.C. § 103
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.
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 at the time any inventions covered therein were effectively filed absent any evidence to the contrary. Applicant is advised of the obligation under 37 C.F.R. § 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned at the time a later invention was effectively filed 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.
Claim 1
Miller teaches:
A device comprising: one or more memories; and one or more processors, coupled to the one or more memories, configured to:
“FIG. 14 is a flow diagram illustrating a method for displaying transfer accounts in accordance with some embodiments. Method 1400 is performed at a computer system (e.g., 100, 300, 500, 600a, 600b, 800, 1000, 1050, 1200, 1600).” Miller ¶ 396. Each of the foregoing computer systems includes a memory and one or more processors coupled to the memory that cause the electronic device to perform the functionality described in Miller’s disclosure and this rejection. See Miller ¶¶ 70, 74, and 75.
dynamically present, based on priority
“The computer system displays (1402), via the display generation component, an account user interface (e.g., 1208, 1302) that includes a plurality of visual representations (e.g., 1210, 1304) of a plurality of different accounts (e.g., including a first visual representation of a first account and a second visual representation of a second account).” Miller ¶ 398. Note that while the examples mentioned in conjunction with method 1400 involve computer system 1200, this rejection will focus on how electronic device 1600 shown in FIGS. 17A–17N performs method 1400. See Miller ¶ 396 (disclosing that method 1400 may be performed at computer system 1600).
In the case of electronic device 1600, step 1402 causes electronic device 1600 to “display[] account user interface 1700 for a transfer account application of electronic device 1600.” Miller ¶ 499 (referring to FIG. 17A). “At FIG. 17A, account user interface 1700 includes a plurality of user interface objects 1702 associated with respective transfer accounts (e.g., payment accounts, such as a third-party credit card account, a debit card account, and/or a stored-value account; pass accounts; ticket accounts; point accounts; rewards accounts; and/or transit accounts) linked to (e.g., provisioned onto) electronic device 1600.” Miller ¶ 499.
Transfer card user interface object 1702a (i.e., the “first visual representation of a first account” in the parlance of method 1400) is “prioritized” in the sense that it is displayed first in the order while other user interface objects displayed subsequent to the transfer card user interface object 1702a, see Miller ¶ 500 and FIG. 17A, but Miller does not disclose whether the prioritization is based on priority levels, let alone calculating the levels according to the three weights mentioned in claim 1.
and wherein a primary interaction element, of the plurality of interaction elements and associated with the primary account identifier, overlaps a secondary interaction element, of the plurality of interaction elements and associated with a secondary account identifier of the plurality of account identifiers, based on the priority
Transfer card user interface object 1702a currently overlaps the Bank of Alaska user interface object 1702b, among the plurality of user interface objects 1702.
modify, based on detecting a selection of the secondary interaction element, the dynamic presentation of the plurality of interaction elements;
“While displaying the account user interface, the computer system receives (1404), via the one or more input devices (e.g., via the touch-sensitive surface and/or via the rotatable input mechanism), a scroll input” or a “swipe on the touch-sensitive surface” that corresponds to “a request to scroll the account user interface.” Miller ¶ 399. “In response to receiving the scroll input, (e.g., concurrently) the computer system scrolls (1406), via the display generation component, the account user interface (e.g., 1208, 1302) to cause a first visual representation of a first account (e.g., 1210a, 1304a) and a second visual representation of a second account (e.g., 1210b, 1304b) to scroll (e.g., first visual representation to scroll to a first location, second visual representation to scroll to a second location, different from the first location).” Miller ¶ 400.
“Subsequent to receiving the scroll input, while the computer system displays the account user interface (e.g., once the scrolling of the account user interface has stopped) (1408), and in accordance with a determination that the second visual representation of the second account (e.g., 1210b, 1304c) satisfies the set of selection criteria, the computer system reduces (1412) (e.g., as in FIGS. 12C, 13E) a visual emphasis of the first visual representation of the first account (e.g., 1210a, 1304b, 1304d) relative to a visual emphasis of the second visual representation of the second account.” Miller ¶ 401.
and display, based on the modification, account information associated with the secondary account identifier.
“In some embodiments, in accordance with the determination that the second visual representation of the second account satisfies the set of selection criteria (and, optionally, and in accordance with a determination that the second account is available for use), displaying (e.g., in the account user interface), via the display generation component, a balance of the second account (e.g., an amount of resources (such as available or used) of the second account).” Miller ¶ 412.
Miller does not explicitly disclose how the priority levels are determined for each of the accounts.
Olson, however, teaches a device that is configured to:
dynamically present, based on priority levels associated with a plurality of account identifiers associated with an account, a plurality of interaction elements corresponding to the plurality of account identifiers,
“In FIG. 6, the tiles associated with the consumer are sorted based on one or more attributes selected by the consumer.” Olson ¶ 60 (emphasis added). It should be understood that the claimed “factors” correspond to Olson’s “attributes,” hence, the ability to sort by “more” than one attribute teaches determining which accounts should be ordered first in the list based on a plurality of attributes.
wherein the priority levels are determined based on:
a first weight based on a type of alert associated with a primary account identifier of the plurality of account identifiers,
One of the sorting criteria includes sorting the accounts based on their “necessity of attention from the consumer.” Olson ¶ 60.
a second weight based on a type of account associated with the primary account identifier, and
Another of the sorting criteria includes sorting the accounts based on whether or not they are the type of account to have a particular “attribute,” e.g., “if accounts are sorted by credit usage, only those accounts with that attribute would be displayed in FIG. 6. Therefore, the consumer's revolving credit accounts would be displayed in FIG. 6, but the consumers other accounts, such as mortgages and loans, may not be displayed.” Olson ¶ 60.
a third weight based on a threshold time frame associated with an action date associated with the primary account identifier,
Yet another one of the sorting criteria includes sorting the accounts based on their “nearest payment due dates.” Olson ¶ 60.
It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to sort the accounts in Miller’s user interface according to account types, account balances, and alert types, as taught by Olson. One would have been motivated to improve Miller with Olson based on an explicitly recognized need for consumers to quickly investigate potential problems in their financial health. See Olson ¶¶ 4–5.
Claim 2
Miller and Olson teach the device of claim 1,
wherein display of the account information was overlapped by the primary interaction element prior to the modification.
“In some embodiments, visual representations of multiple accounts (e.g., all displayed visual representations of accounts other than the visual representation of the account that satisfied the set of selection criteria) are visually de-emphasized (e.g., by changing the visual characteristic of the visual representations of the multiple accounts to a different value, by reducing the opacity and/or size of the displayed visual representations) as compared to the visual representations of the single account that satisfied the set of selection criteria.” Miller ¶ 403. For example, as shown in FIG. 17A, transfer card user interface object 1702a overlaps the Bank of Alaska user interface object 1702b.
Claim 3
Miller and Olson teach the device of claim 1,
wherein each of the plurality of interaction elements is associated with account information related to a corresponding account identifier of the plurality of account identifiers.
“For example, upon receiving access to the transfer account of a user, electronic device 1200 receives and stores credentials associated with the transfer account (e.g., account numbers, pin codes, authorization codes, pass codes, card number, balance information, and/or address) in a secure element of electronic device 1200.” Miller ¶ 358.
Olson likewise provides, in an overlapping disclosure: “In FIG. 9, the consumer is presented with an account level screen from which the consumer can perform actions associated with a specific account. This screen may be presented when the consumer selects one of the accounts from the user-interfaces described in reference to FIGS. 2–8.” Olson ¶ 64. Notably, the interface in FIG. 9 includes a second rectangular shaped element 94 that includes a second set of information about the account, such as contact information for the institution at which the account is held. See Olson FIG. 9 and ¶ 64.
Claim 4
Miller and Olson teach the device of claim 1,
wherein the primary interaction element includes a first area that is larger than a second area of the secondary interaction element prior to the modification.
After the scrolling and/or selection, the electronic device reduces a visual emphasis of the first visual representation of the first account relative to a visual emphasis of the second account (including by reducing its relative size), Miller ¶ 401, meaning before the scrolling or selection, the first visual representation of the first account was relatively larger than that of the second account. This is also shown in FIG. 17A, where transfer card 1702a is larger than Bank of Alaska 1702b.
Claim 5
Miller and Olson teach the device of claim 1,
wherein the secondary interaction element includes a second area that is larger than a first area of the primary interaction element after the modification.
“[I]n accordance with a determination that the second visual representation of the second account (e.g., 1210b, 1304c) satisfies the set of selection criteria, the computer system reduces (1412) (e.g., as in FIGS. 12C, 13E) a visual emphasis of the first visual representation of the first account (e.g., 1210a, 1304b, 1304d) relative to a visual emphasis of the second visual representation of the second account (e.g., reducing the opacity and/or size of the first visual representation (e.g., visually deemphasizing the visual representation to the predetermined opacity and/or size).” Miller ¶ 401.
Claim 6
Miller and Olson teach the device of claim 1,
wherein the plurality of interaction elements includes rounded corners to form a visual representation of transaction cards.
As shown in FIG. 17A, Miller explicitly teaches that each of the card elements 1702 have rounded corners.
Claim 7
Miller and Olson teach the device of claim 1,
wherein the type of alert includes at least one of: a fraud alert, or an impending action alert.
“For example, the consumer may have the option to sort accounts based on . . . nearest payment due dates, necessity of attention from the consumer, and/or other attributes associated with credit accounts.” Olson ¶ 60.
Claims 8–14
Claims 8–14 differ from claims 1–7 in only two respects. First, claims 8–14 require fewer computer components than claims 1–7 (only the memory portion and its instructions are required). Since Miller and Olson teach both the memory and the instructions recited in claims 1–7, they likewise teach the same for claims 8–14.
Second, claims 8–14 require the interaction elements to be displayed in a vertical stack. Miller explicitly teaches this in at least FIG. 17A.
Claims 15–20
Claims 15–20 recite the method that the computer-readable medium of claims 8–13 causes a computer to perform as part of its normal operation. “Under the principles of inherency, if a prior art device, in its normal and usual operation, would necessarily perform the method claimed, then the method claimed will be considered to be anticipated by the prior art device.” MPEP § 2112.02. Therefore, claims 15–20 are rejected over all of the findings and rationale provided above for claims 8–13.
Conclusion
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Justin R. Blaufeld
Primary Examiner
Art Unit 2151
/Justin R. Blaufeld/Primary Examiner, Art Unit 2151
1 Claim 1 does not actually require the device to perform these calculations under the broadest reasonable interpretation of the claim, but this rejection will assume for the sake of compact prosecution that these elements are indeed required.
2 See, Helmsderfer v. Bobrick Washroom Equip., Inc., 527 F.3d 1379, 1382 (Fed. Cir. 2008) (“different claim terms are presumed to have different meanings.”) and Applied Med. Res. Corp. v. U.S. Surgical Corp., 448 F.3d 1324, 1333 n.3 (Fed. Cir. 2006) (“the use of two terms in a claim requires that they connote different meanings”).
Prosecution Insights