DETAILED ACTION
This action is in response to the application filed 20 October 2025 claiming benefit back to 31 October 2024.
Claims 1 – 20 are pending and have been examined.
This action is Non-Final.
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 .
Information Disclosure Statement
The information disclosure statement (IDS) submitted on 18 February 2026 has been considered by the examiner.
Continuation
This application is a continuation application of U.S. application no. 18/933,591 filed on 31 October 2024, now U.S. Patent 12,505,389 (“Parent Application”). See MPEP §201.07. In accordance with MPEP §609.02 A. 2 and MPEP §2001.06(b) (last paragraph), the Examiner has reviewed and considered the prior art cited in the Parent Application. Also in accordance with MPEP §2001.06(b) (last paragraph), all documents cited or considered ‘of record’ in the Parent Application are now considered cited or ‘of record’ in this application. Additionally, Applicant(s) are reminded that a listing of the information cited or ‘of record’ in the Parent Application need not be resubmitted in this application unless Applicants desire the information to be printed on a patent issuing from this application. See MPEP §609.02 A. 2. Finally, Applicants are reminded that the prosecution history of the Parent Application is relevant in this application. See e.g., Microsoft Corp. v. Multi-Tech Sys., Inc., 357 F.3d 1340, 1350, 69 USPQ2d 1815, 1823 (Fed. Cir. 2004) (holding that statements made in prosecution of one patent are relevant to the scope of all sibling patents).
Double Patenting
The nonstatutory double patenting rejection is based on a judicially created doctrine grounded in public policy (a policy reflected in the statute) so as to prevent the unjustified or improper timewise extension of the “right to exclude” granted by a patent and to prevent possible harassment by multiple assignees. A nonstatutory double patenting rejection is appropriate where the conflicting claims are not identical, but at least one examined application claim is not patentably distinct from the reference claim(s) because the examined application claim is either anticipated by, or would have been obvious over, the reference claim(s). See, e.g., In re Berg, 140 F.3d 1428, 46 USPQ2d 1226 (Fed. Cir. 1998); In re Goodman, 11 F.3d 1046, 29 USPQ2d 2010 (Fed. Cir. 1993); In re Longi, 759 F.2d 887, 225 USPQ 645 (Fed. Cir. 1985); In re Van Ornum, 686 F.2d 937, 214 USPQ 761 (CCPA 1982); In re Vogel, 422 F.2d 438, 164 USPQ 619 (CCPA 1970); In re Thorington, 418 F.2d 528, 163 USPQ 644 (CCPA 1969).
A timely filed terminal disclaimer in compliance with 37 CFR 1.321(c) or 1.321(d) may be used to overcome an actual or provisional rejection based on nonstatutory double patenting provided the reference application or patent either is shown to be commonly owned with the examined application, or claims an invention made as a result of activities undertaken within the scope of a joint research agreement. See MPEP § 717.02 for applications subject to examination under the first inventor to file provisions of the AIA as explained in MPEP § 2159. See MPEP § 2146 et seq. for applications not subject to examination under the first inventor to file provisions of the AIA . A terminal disclaimer must be signed in compliance with 37 CFR 1.321(b).
The USPTO Internet website contains terminal disclaimer forms which may be used. Please visit www.uspto.gov/patent/patents-forms. The filing date of the application in which the form is filed determines what form (e.g., PTO/SB/25, PTO/SB/26, PTO/AIA /25, or PTO/AIA /26) should be used. A web-based eTerminal Disclaimer may be filled out completely online using web-screens. An eTerminal Disclaimer that meets all requirements is auto-processed and approved immediately upon submission. For more information about eTerminal Disclaimers, refer to:
www.uspto.gov/patents/process/file/efs/guidance/eTD-info-I.jsp.
Claims 1 – 10, 14, and 15 – 20 are rejected on the grounds of nonstatutory double patenting as being unpatentable over corresponding claims of U.S. Patent No. 12,505,389.
[Claims 11, 12, and 13 are not rejected on the grounds of nonstatutory double patenting, however they are dependent upon a rejected base claim; however, they stand rejected under 35 USC 101, as shown below].
Claim 1 is rejected on the ground of nonstatutory double patenting as being unpatentable over claim 1 of U.S. Patent No. 12,505,389 (’389 patent). Although the claims at issue are not identical, they are not patentably distinct from each other because, as shown in the claim comparison below, claim 1 of the ‘389 patent would anticipate claim 1 of the instant application.
U.S. 12,505,389
1. A computing platform comprising:
at least one network interface;
at least one processor;
at least one non-transitory computer-readable medium; and
program instructions stored on the at least one non-transitory computer-readable medium that, when executed by the at least one processor, cause the computing platform to:
detect a trigger event for determining environmental-impact indicators for product-level resources across multiple different food products;
in response to detecting the trigger event, invoke a data pipeline that is configured to determine environmental-impact indicators for product-level resources across multiple different food products rather than for an individual food product, wherein, when invoked, the data pipeline functions to:
extract a first source dataset from a first database table containing data about food products, wherein the first source dataset comprises (i) a set of rows representing data records for a given set of multiple different food products and (ii) a set of columns representing data variables that, for each respective row in the set of rows, provide respective information about a respective food product represented by the respective row;
extract a second source dataset from a second database table containing data about manufacturing processes for food products, wherein the second source dataset comprises (i) a set of rows representing data records for a given set of multiple different manufacturing processes and (ii) a set of columns representing data variables that, for each respective row in the set of rows, provide respective information about a respective manufacturing process represented by the respective row;
merge the first source dataset and the second source dataset into a first merged dataset by performing a left join operation using the first source dataset as a left table, the second source dataset as a right table, and a manufacturing-process identifier as a key for joining the first and second source datasets, wherein the first merged dataset comprises (i) a set of rows representing data records for the given set of multiple different food products and (ii) a set of columns representing data variables that, for each respective row in the set of rows, provide respective information about a respective food product represented by the respective row, wherein at least a given subset of columns in the set of columns represent data variables that each indicates an amount of a given type of resource that is used or produced by a respective manufacturing process used to manufacture the respective food product represented by the respective row;
update the first merged dataset by performing an unpivot operation on the given subset of columns in the set of columns and thereby generate an updated first merged dataset that comprises (i) an updated set of rows representing data records for a given set of multiple different product-level resources that are each defined by a respective combination of food product and resource type, and (ii) an updated set of columns representing data variables that, for each respective row in the set of rows, provide respective information about a respective product-level resource represented by the respective row;
extract a third source dataset from a third database table containing data about resource types that are used or produced by manufacturing processes for food products, wherein the third source dataset comprises (i) a set of rows representing data records for a given set of multiple different resource types and (ii) a set of columns representing data variables that, for each respective row in the set of rows, provide respective information about a respective resource type represented by the respective row;
extract a fourth source dataset from a fourth database table containing data about plants where food products are manufactured, wherein the fourth source dataset comprises (i) a set of rows representing data records for a given set of multiple different plants and (ii) a set of columns representing data variables that, for each respective row in the set of rows, provide respective information about a respective plant represented by the respective row;
extract a fifth source dataset from a fifth database table containing environmental-impact values for types of resources, wherein the third source dataset comprises (i) a set of rows representing data records for a given set of multiple different resource types and (ii) a set of columns representing data variables that, for each respective row in the set of rows, provide respective environmental-impact values for a respective resource type represented by the respective row;
merge the updated first merged dataset, the third source dataset, the fourth source dataset, and the fifth source dataset into a second merged dataset by (i) producing a first intermediate dataset by performing a first left join operation using the first merged dataset as a first left table, the third source dataset as a first right table, and a resource-type identifier as a first key for joining the first merged dataset and the third source dataset, (ii) producing a second intermediate dataset by performing a second left join operation using the first intermediate dataset as a second left table, the fourth source dataset as a second right table, and a plant identifier as a second key for joining the first intermediate dataset and the fourth source dataset, (iii) producing the second merged dataset by performing a third left join operation using the second intermediate dataset as a third left table, the fifth source dataset as a third right table, and an environmental-impact-contributor identifier as a third key for joining the second intermediate dataset and the fifth source dataset, wherein the second merged dataset comprises (i) a set of rows representing data records for the given set of product-level resources and (ii) a set of columns representing data variables that, for each respective row in the set of rows, provide respective information about a respective product-level resource represented by the respective row; and
determine a respective group of environmental-impact indicators for each respective product-level resource in the given set using the second merged dataset;
store the respective group of environmental-impact indicators for each respective product-level resource in the given set into a target database table; and
utilize the target database table to service network-based requests from users for visualizations of environmental-impact indicators for food products from the given set of multiple different food products.
Instant Application
1. A computing platform comprising:
at least one network interface;
at least one processor;
at least one non-transitory computer-readable medium; and
program instructions stored on the at least one non-transitory computer-readable medium that, when executed by the at least one processor, cause the computing platform to:
detect a trigger event for determining environmental-impact indicators for product-level resources across multiple different food products; and
in response to detecting the trigger event, invoke a data pipeline that is configured to determine environmental-impact indicators for product-level resources across multiple different food products rather than for an individual food product, wherein, when invoked, the data pipeline performs functions comprising:
applying a sequence of database operations to source data that is spread out across multiple different database tables and thereby constructing a dataset that comprises (i) a set of rows representing data records for a given set of multiple different product-level resources that are each defined by a respective combination of food product and resource type, and (ii) a set of columns representing data variables that, for each respective row in the set of rows, provide respective information about a respective product-level resource represented by the respective row; and
extract a third source dataset from a third database table containing data about resource types that are used or produced by manufacturing processes for food products, wherein the third source dataset comprises (i) a set of rows representing data records for a given set of multiple different resource types and (ii) a set of columns representing data variables that, for each respective row in the set of rows, provide respective information about a respective resource type represented by the respective row;
utilizing the constructed dataset to determine a respective group of environmental-impact indicators for each respective product-level resource in the given set
product-level resources.
Claim 2 is rejected on the ground of nonstatutory double patenting as being unpatentable over claim 1 of U.S. Patent No. 12,505,389. Although the claims at issue are not identical, they are not patentably distinct from each other because claim 1 of the ‘389 patent would anticipate claim 2 of the instant application.
Claim 3 is rejected on the ground of nonstatutory double patenting as being unpatentable over claim 1 of U.S. Patent No. 12,505,389. Although the claims at issue are not identical, they are not patentably distinct from each other because claim 1 of the ‘389 patent would anticipate claim 3 of the instant application..
Claim 4 is rejected on the ground of nonstatutory double patenting as being unpatentable over claim 1 of U.S. Patent No. 12,505,389. Although the claims at issue are not identical, they are not patentably distinct from each other because claim 1 of the ‘389 patent would anticipate claim 4 of the instant application..
Claim 5 is rejected on the ground of nonstatutory double patenting as being unpatentable over claim 1 of U.S. Patent No. 12,505,389. Although the claims at issue are not identical, they are not patentably distinct from each other because claim 1 of the ‘389 patent would anticipate claim 5 of the instant application..
Claim 6 is rejected on the ground of nonstatutory double patenting as being unpatentable over claim 1 of U.S. Patent No. 12,505,389. Although the claims at issue are not identical, they are not patentably distinct from each other because claim 1 of the ‘389 patent would anticipate claim 6 of the instant application..
Claim 7 is rejected on the ground of nonstatutory double patenting as being unpatentable over claim 8 of U.S. Patent No. 12,505,389. Although the claims at issue are not identical, they are not patentably distinct from each other because claim 8 of the ‘389 patent would anticipate claim 7 of the instant application..
Claim 8 is rejected on the ground of nonstatutory double patenting as being unpatentable over claim 9 of U.S. Patent No. 12,505,389. Although the claims at issue are not identical, they are not patentably distinct from each other because claim 9 of the ‘389 patent would anticipate claim 8 of the instant application.
Claim 9 is rejected on the ground of nonstatutory double patenting as being unpatentable over claim 1 of U.S. Patent No. 12,505,389. Although the claims at issue are not identical, they are not patentably distinct from each other because claim 1 of the ‘389 patent would anticipate claim 9 of the instant application.
Claim 10 is rejected on the ground of nonstatutory double patenting as being unpatentable over claim 10 of U.S. Patent No. 12,505,389. Although the claims at issue are not identical, they are not patentably distinct from each other because claim 10 of the ‘389 patent would anticipate claim 10 of the instant application.
Claim 14 is rejected on the ground of nonstatutory double patenting as being unpatentable over claim 11 of U.S. Patent No. 12,505,389. Although the claims at issue are not identical, they are not patentably distinct from each other because, using the same analysis as presented in the rejection of claim 1, claim 11 of the ‘389 patent would anticipate claim 14 of the instant application.
Claim 15 is rejected on the ground of nonstatutory double patenting as being unpatentable over claim 18 of U.S. Patent No. 12,505,389. Although the claims at issue are not identical, they are not patentably distinct from each other because, using the same analysis as presented in the rejection of claim 1, claim 18 of the ‘389 patent would anticipate claim 15 of the instant application.
Claim 16 is rejected on the ground of nonstatutory double patenting as being unpatentable over claim 18 of U.S. Patent No. 12,505,389. Although the claims at issue are not identical, they are not patentably distinct from each other because claim 18 of the ‘389 patent would anticipate claim 16 of the instant application.
Claim 17 is rejected on the ground of nonstatutory double patenting as being unpatentable over claim 18 of U.S. Patent No. 12,505,389. Although the claims at issue are not identical, they are not patentably distinct from each other because claim 18 of the ‘389 patent would anticipate claim 17 of the instant application.
Claim 18 is rejected on the ground of nonstatutory double patenting as being unpatentable over claim 18 of U.S. Patent No. 12,505,389. Although the claims at issue are not identical, they are not patentably distinct from each other because claim 18 of the ‘389 patent would anticipate claim 18 of the instant application.
Claim 19 is rejected on the ground of nonstatutory double patenting as being unpatentable over claim 18 of U.S. Patent No. 12,505,389. Although the claims at issue are not identical, they are not patentably distinct from each other because claim 18 of the ‘389 patent would anticipate claim 19 of the instant application.
Claim 20 is rejected on the ground of nonstatutory double patenting as being unpatentable over claim 15 of U.S. Patent No. 12,505,389. Although the claims at issue are not identical, they are not patentably distinct from each other because the only difference between claim 15 of the ‘389 patent and claim 20 of the instant application is that claim 15 is directed to a non-transitory computer readable medium with instructions for a computer to carry out the method steps, while claim 20 of the instant application is directed to a computer performing the method steps. It would have been obvious to one of ordinary skill to run a non-transitory computer readable medium with instructions on a computer to carry out the same method steps.
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1 – 3, 6 – 17, and 20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter. The claimed invention, when the claims are taken as a whole, is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
[Claims 4, 5, 18, and 19 are not rejected under 35 USC 101, as they are dependent upon a rejected base claim; however, they stand rejected on the grounds of nonstatutory double patenting, as shown above].
Step 2A – 1: The claims recite a Judicial Exception. Exemplary independent claim 1 recites the limitations of: a computing platform comprising:
at least one network interface;
at least one processor;
at least one non-transitory computer-readable medium; and
program instructions stored on the at least one non-transitory computer-readable medium that, when executed by the at least one processor, cause the computing platform to:
detect a trigger event for determining environmental-impact indicators for product-level resources across multiple different food products; and
in response to detecting the trigger event, invoke a data pipeline that is configured to determine environmental-impact indicators for product-level resources across multiple different food products rather than for an individual food product, wherein, when invoked, the data pipeline performs functions comprising:
applying a sequence of database operations to source data that is spread out across multiple different database tables and thereby constructing a dataset that comprises (i) a set of rows representing data records for a given set of multiple different product-level resources that are each defined by a respective combination of food product and resource type, and (ii) a set of columns representing data variables that, for each respective row in the set of rows, provide respective information about a respective product-level resource represented by the respective row; and
utilizing the constructed dataset to determine a respective group of environmental-impact indicators for each respective product-level resource in the given set of multiple different product-level resources.
These limitations (bolded and italicized), as drafted, are a process that covers determination of indicators, applying database operations to build a dataset, and determining a group of indicators for each resource, Under its broadest reasonable interpretation, the claimed invention covers the performance of the limitations in the human mind, using observation, evaluation, judgment, and opinion. See MPEP 2106.04(a)(2) III.
Step 2A – 2: This judicial exception is not integrated into a practical application, and the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. Exemplary independent claim 1 recites the additional limitations of: at least one network interface, at least one processor, at least one non-transitory computer-readable medium, and program instructions stored on the at least one non-transitory computer-readable medium, however, these are generic computer hardware at a high level of generality, and amount to no more than mere instructions to apply the exception using a generic computer (see MPEP 2106.05(f)); detect a trigger event, however, this is recited at a high level of generality, and amounts to mere data gathering, and is insignificant extra-solution activity (see MPEP 2106.05(g)); and a data pipeline, however this is also recited at high level of generality, and is merely a tool to perform the abstract idea (see MPEP 2106.05(f)).
Further, the claims do not provide for or recite any improvements to the functioning of a computer, or to any other technology or technical field; applying or using a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition; applying the judicial exception with, or by use of, a particular machine; effecting a transformation or reduction of a particular article to a different state or thing; or applying or using the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception.
Even when viewed in combination, these additional elements do not integrate the recited judicial exception into a practical application (Step 2A, Prong Two: NO). The claim is directed to the abstract idea. (Step 2A: YES).
The dependent claims have the same deficiencies as their parent claims as being directed towards an abstract idea, as the dependent claims merely narrow the scope of their parent claims, and it has been held that “[i]n defining the excluded categories, the Court has ruled that the exclusion applies if a claim involves a natural law or phenomenon or abstract idea, even if the particular natural law or phenomenon or abstract idea at issue is narrow.” (buySAFE, Inc. v. Google, Inc., 765 F.3d 1350. )
Turning to the dependent claims, none of the claimed features of the dependent claims further limit the claimed invention in such a way to direct the claimed invention to statutory subject matter (e.g. change the scope of the claimed invention as to no longer be directed towards an abstract idea, or include additional elements that are sufficient to amount to significantly more than the judicial exception because of the additional elements or combination of elements in the claims other than the abstract idea per se), nor do they add limitations that, when taken as a combination, result in the claim as a whole amounting to significantly more than the judicial exception. In respect to exemplary dependent claims 2, 3, and 6 – 13:
Claims 2, 6 – 8, and 12 merely further describes the contents of database tables;
Claim 3 merely recites additional steps of the abstract idea;
Claims 9 – 11 recite generic computer functions, recited at a high level of generality (see MPEP 2106.05(f));
Claim 13 merely further describes the collected data.
Step 2B: The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, explained with respect to Step 2A, Prong Two, the additional elements or combination of elements in the claims other than the abstract idea per se amount to no more than mere instructions to implement the idea on a computer, or the recitation of generic computer structure that serves to perform generic computer functions previously known to the industry1 [e.g. performing repetitive calculations; receiving, processing, and storing data; electronically scanning or extracting data from a physical document; electronic recordkeeping; automating mental tasks; receiving or transmitting data over a network, e.g., using the Internet to gather data] .
Applicant’s specification, at, e.g., paragraphs [0331]-[0343], provides evidence of generic computer hardware performing generic, well-known, computer functions.
Viewed as a whole, these additional claim elements, both individually and in combination, do not provide meaningful limitations to transform the above identified abstract idea into a patent eligible application of the abstract idea such that the claims amount to significantly more (e.g. improvements to another technology or technical fields, improvements to the functioning of the computer itself, or meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment) than the abstract idea itself. Thus, taken alone, the additional elements do not amount to significantly more than the above-identified judicial exception (the abstract idea). Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. Their collective functions merely provide conventional computer implementation2.
Therefore, the claims are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter. See Alice Corporation Pty. Ltd. v. CLS Bank International, 573 U.S. No. 13–298.
Conclusion
The prior art made of record and not relied upon considered pertinent to Applicant’s disclosure.
Abrams; JoAnna US 20200258094 A1 Rating Of An Environmental Health Impact Of A Product
Beal; Colin M. US 20210148891 A1 Lifecycle Assessment Systems And Methods For Determining Emissions From Animal Production
Masset; Yannick et al. US 20140108412 A1 Product Information System Consultable From Several Manufacturing Sites, Based On Configuration Management
Walker; Marcia Elaine et al. US 20100274603 A1 Dynamic Sustainability Factor Management
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ALAN S MILLER whose telephone number is (571)270-5288. The examiner can normally be reached on M-F 10am-6pm. Examiner’s fax phone number is (571) 270-6288.
Examiner interviews are available via telephone 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, Beth Boswell can be reached at (571) 272-6737. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000.
/ALAN S MILLER/Primary Examiner, Art Unit 3625
1 “It is well-settled that mere recitation of concrete, tangible components is insufficient to confer patent eligibility to an otherwise abstract idea. Rather, the components must involve more than performance of “‘well understood, routine, conventional activit[ies]’ previously known to the industry.” Alice, 134 S. Ct. at 2359 (quoting Mayo, 132 S.Ct. at 1294)”. Id, pages 10-11. “Likewise, the server fails to add an inventive concept because it is simply a generic computer that “administer[ s]” digital images using a known “arbitrary data bank system.” Id. at col. 5 ll. 45–46. But “[f]or the role of a computer in a computer-implemented invention to be deemed meaningful in the context of this analysis, it must involve more than performance of ‘well-understood, routine, [and] conventional activities previously known to the industry.’” Content Extraction, 776 F.3d at 1347–48 (quoting Alice, 134 S. Ct at 2359). “These steps fall squarely within our precedent finding generic computer components insufficient to add an inventive concept to an otherwise abstract idea. Alice, 134 S. Ct. at 2360 (“Nearly every computer will include a ‘communications controller’ and a ‘data storage unit’ capable of performing the basic calculation, storage, and transmission functions required by the method claims.”); Content Extraction, 776 F.3d at 1345, 1348 (“storing information” into memory, and using a computer to “translate the shapes on a physical page into typeface characters,” insufficient confer patent eligibility); Mortg. Grader, 811 F.3d at 1324–25 (generic computer components such as an “interface,” “network,” and “database,” fail to satisfy the inventive concept requirement); Intellectual Ventures I, 792 F.3d at 1368 (a “database” and “a communication medium” “are all generic computer elements”); BuySAFE v. Google, Inc., 765 F.3d 1350, 1355 (Fed. Cir. 2014) (“That a computer receives and sends the information over a network—with no further specification—is not even arguably inventive.”)”. TLI Communications LLC v. AV Automotive L.L.C., (No. 15-1372, (Fed. Cir. May 17, 2016)), at *12-13.
See additionally MPEP 2106.05(d).
2 “Nor, in addressing the second step of Alice, does claiming the improved speed or efficiency inherent with applying the abstract idea on a computer provide a sufficient inventive concept. See Bancorp Servs., LLC v. Sun Life Assurance Co. of Can., 687 F.3d 1266, 1278 (Fed. Cir. 2012) (“[T]he fact that the required calculations could be performed more efficiently via a computer does not materially alter the patent eligibility of the claimed subject matter.”); CLS Bank, Int’l v. Alice Corp., 717 F.3d 1269, 1286 (Fed. Cir. 2013) (en banc) aff’d, 134 S. Ct. 2347 (2014) (“[S]imply appending generic computer functionality to lend speed or efficiency to the performance of an otherwise abstract concept does not meaningfully limit claim scope for purposes of patent eligibility.” (citations omitted))”. Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 115 U.S.P.Q.2d 1636 (Fed. Cir. 2015).
