DETAILED ACTION
Status of Claims
1. This office action is in response to filing dated 11/3/2025.
2. Claims 21-40 are pending.
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 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 21-40
Claims 21-40 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
Step 1: Claims 21-32 are directed to a system; claims 33-36 are directed to a method; claims 37-40 directed to a non-transitory computer readable medium – each of which is one of the statutory categories of inventions.
Step 2A: A claim is eligible at revised Step 2A unless it recites a judicial exception and the exception is not integrated into a practical application of the application.
Prong 1: Prong One of Step 2A evaluates whether the claim recites a judicial exception (an abstract idea enumerated in the 2019 PEG, a law of nature, or a natural phenomenon).
Groupings of Abstract Ideas:
I. MATHEMATICAL CONCEPTS
A. Mathematical Relationships
B. Mathematical Formulas or Equations
C. Mathematical Calculations
II. CERTAIN METHODS OF ORGANIZING HUMAN ACTIVITY
A. Fundamental Economic Practices or Principles (including hedging, insurance, mitigating risk)
B. Commercial or Legal Interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations)
C. Managing Personal Behavior or Relationships or Interactions between People (including social activities, teaching, and following rules or instructions)
III. MENTAL PROCESSES.
Concepts performed in the human mind (including an observation, evaluation, judgment, opinion).
See MPEP 2106.04 (a) (2) Abstract Idea Groupings [R-10.2019]
The limitations recited in independent claim 21, 32 and 37 –
receive an input from a data source, the input comprising transaction event data;
transmit the transaction event data to a data store;
transform the transaction event data into tabulated event data;
normalize the tabulated event data;
filter the normalized event data through a net flows dimension;
transmit the filtered event data to a summary table;
transform the summary table into an aggregated data table; and
transmit the summary table and the aggregated data table to a compensation management platform configured for internal reporting
– fall under the abstract idea categories of Mental Process and/or Certain Methods of Organizing Human Activity (Commercial/Legal Interactions).
The dependent claims further limit the abstract idea to –
(Claim 22) wherein the summary table comprises data associated with a plurality of transaction events.
(Claim 23) wherein the aggregated data table comprises a cumulative amount of transaction event data associated with a period of time.
(Claim 24) wherein the compensation management platform comprises a graphical user interface configured to display the aggregated data table.
(Claim 25) wherein the graphical user interface is configured to allow a user to view the net amount of assets for an adjustable period of time.
(Claim 26) wherein the compensation management platform provides reporting to an advisor, a manager, or an executive user.
(Claim 27) wherein the compensation management platform compares a net flow associated with the summary table and the aggregated data table to a predetermined productivity level.
(Claim 28) wherein the data source comprises at least one of a financial management service, an investment service, an automated teller machine network, or a clearing platform.
(Claim 29) wherein the transaction event data comprises at least one of a deposit into an account or a withdrawal from the account.30. (New) The system of claim 21, wherein transforming the transaction event data comprises at least one of modifying the transaction event data, normalizing the transaction event data, aggregating the transaction event data, removing duplicates from the transaction event data, sorting the transaction event data, or merging the transaction event data.
(Claim 31) wherein normalizing the transaction event data comprises removing unstructured data or redundant data from the transaction event data.
(Claim 32) wherein normalizing the transaction event data comprises creating a standardized format for the transaction event data.
(Claim 34) wherein the summary table includes a total asset amount associated with one or more preset category.
(Claim 35) wherein the one or more preset category comprises at least one of a product, an advisor, a sales manager, or a firm level.
(Claim 36) wherein the aggregated data table comprises cumulative net flow data.
(Claim 38) wherein the aggregated data table comprises a central table in a data warehouse dimensional data model configured to store net flow calculations.
(Claim 39) wherein the compensation management platform comprises a net flow summary report associated with the summary table.
(Claim 40) wherein the compensation management platform comprises a report viewable by a user.
– that also constitute Mental Process and/or Certain Methods of Organizing Human Activity.
Hence under Prong One of Step 2A, claims 21-40 recite a combination of judicial exception(s).
Prong 2: Prong Two of Step 2A evaluates whether the claim recites additional elements that integrate the judicial exception into a practical application of the exception.
Limitations the courts have found indicative that an additional element (or combination of elements) may have integrated the exception into a practical application include:
An improvement in the functioning of a computer, or an improvement to other technology or technical field, as discussed in MPEP §§ 2106.04(d)(1) and 2106.05(a);
Applying or using a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition, as discussed in MPEP § 2106.04(d)(2);
Implementing a judicial exception with, or using a judicial exception in conjunction with, a particular machine or manufacture that is integral to the claim, as discussed in MPEP § 2106.05(b);
Effecting a transformation or reduction of a particular article to a different state or thing, as discussed in MPEP § 2106.05(c); and
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, as discussed in MPEP § 2106.05(e).
The courts have also identified limitations that did not integrate a judicial exception into a practical application:
Merely reciting the words “apply it” (or an equivalent) with the judicial exception, or merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea, as discussed in MPEP § 2106.05(f);
Adding insignificant extra-solution activity to the judicial exception, as discussed in MPEP § 2106.05(g); and
Generally linking the use of a judicial exception to a particular technological environment or field of use, as discussed in MPEP § 2106.05(h).
Additional elements recited by the claims, beyond the abstract idea, include: system comprising memory and at least one processor; graphical user interface; data warehouse. Examiner thus finds that any additional element(s), beyond the judicial exception, has been recited at a high level of generality such that the claim limitations amount to no more than mere instructions to apply the exception using generic components (see MPEP 2106.05(f)) or insignificant data gathering activities (see MPEP 2106.05(g)).
The combination of additional elements does not purport to improve the functioning of a computer or effect an improvement in any other technology or technical field. Instead, the additional elements do no more than use the computer as a tool and/or link the use of the judicial exception to a particular technological environment or field of use. The focus of the claims is not on improvement in computers, but on certain independently abstract ideas – receive an input from a data source, the input comprising transaction event data; transmit the transaction event data to a data store; transform the transaction event data into tabulated event data; normalize the tabulated event data; filter the normalized event data through a net flows dimension; transmit the filtered event data to a summary table; transform the summary table into an aggregated data table; and transmit the summary table and the aggregated data table to a compensation management platform configured for internal reporting – that merely uses generic computers as tools. Steps that do no more than spell out what it means to “apply it on a computer” cannot confer patent eligibility. Indeed, nothing in claim 1 improves the functioning of the computer, makes it operate more efficiently, or solves any technological problem. See Trading Techs. Int’l, Inc. v. IBG LLC, 921 F.3d 1378, 1384-85 (Fed. Cir. 2019).
Hence, under Prong Two of Step 2A, the additional elements, when considered individually or in combination, do not integrate the judicial exception into a practical application.
Hence, the claims are ineligible under Step 2A.
Step 2B:
In Step 2B, the evaluation consists of whether the claim recites additional elements that amount to an inventive concept (aka “significantly more”) than the recited judicial exception.
As discussed in Prong Two, the additional elements in the claims amount to no more than mere instructions to apply the exception using generic components. When considered individually or as an ordered combination, the additional elements fail to transform the abstract idea of – receive an input from a data source, the input comprising transaction event data; transmit the transaction event data to a data store; transform the transaction event data into tabulated event data; normalize the tabulated event data; filter the normalized event data through a net flows dimension; transmit the filtered event data to a summary table; transform the summary table into an aggregated data table; and transmit the summary table and the aggregated data table to a compensation management platform configured for internal reporting – into significantly more. See MPEP 2106.05(f) Mere Instructions To Apply An Exception [R-10.2019].
(2) Whether the claim invokes computers or other machinery merely as a tool to perform an existing process. Use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) or simply adding a general purpose computer or computer components after the fact to an abstract idea (e.g., a fundamental economic practice or mathematical equation) does not integrate a judicial exception into a practical application or provide significantly more.
Hence, the claims are ineligible under Step 2B.
Therefore, the claim(s) are rejected under 35 U.S.C. 101 as being directed to a judicial exception without significantly more.
Claim Rejections - 35 USC § 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.
Claims 21-40
Claims 21-40 are rejected under 35 U.S.C. 103 as being unpatentable over Johnas et al. (US20230205743) in view of Strutt (US20020133368).
Claim 21:
A system for calculating a net amount of assets, comprising:
a memory storing a set of instructions; and
at least one processor configured to execute the set of instructions to:
receive an input from a data source, the input comprising transaction event data;
(See Johnas: Figs. 1, 2)
transmit the transaction event data to a data store;
(See Johnas: Figs. 1, 2)
transform the transaction event data into tabulated event data;
(See Johnas: Para [0018] (“Since each enterprise data model instance is created based on the enterprise data model schema, each enterprise data model instance may include data structures having identical characteristics (e.g., the same number of tables, the same fields in each table, etc.)”)
normalize the tabulated event data;
(See Johnas: Para
[0029] (“Second, the common enterprise data model schema used to store data associated with the different entities enables the data management system to merge data from different entities for easier presentation and/or analysis.”)
[0065] (“The transformations performed by the data transformation module 210 may include normalizing the data such that data of the same (or similar type) across different entities may be stored in the enterprise data model instances according the same scale (e.g., a risk score between 0 to 100, a rating between 1 and 5, etc.). The transformation may also include converting the data to a common unit (e.g., U.S. dollars for a monetary amount, inches for length, etc.).”)
…
transmit the filtered event data to a summary table;
(See Johnas: Para [0078] (“In some embodiments, instead of or in addition to presenting the consolidated data views 302, 304, and 306, the data view module 206 may further analyze the data organized under the consolidated data views 302, 304, and 306, and may provide an outcome of the analysis to a device or an application (e.g., the applications 232, 234, and 236). For example, using the consolidated data view 302, the data view module 206 may summarize the transaction data and generate an accounting report that may represent related transactions conducted with different entities. The data view module 206 may then present the account report on a user device or transmit the account report to a requesting application (e.g., the application 232). In another example, using the consolidated data view 304, the data view module 206 may generate a user report based on the user data that represents user accounts with different entities that are associated with common users. The data view module 206 may then present the user report on a user device or transmit the account report to a requesting application (e.g., the application 232). Thus, using the consolidated data view feature of the data management module 116, such reports can be more easily generated and presented to users.”)
Johnas does not specifically disclose; however, Strutt discloses the following limitations:
filter the normalized event data through a net flows dimension;
(See Strutt: Para [0532] (“‘GL’ displays a list of all detailed transactions for the accounting period for each account as selected in initial prompt filters such as document/transaction number. The GL report presents transaction description, credit, debit, and final balance information.”)
…
transform the summary table into an aggregated data table; and
(See Strutt: Para [1073] (“The configuration unit may provide a means to set multipliers that are used to aggregate and attach meaning to the amounts which are loaded into the data warehouse system 100.”)
transmit the summary table and the aggregated data table to a compensation management platform configured for internal reporting.
(See Strutt: Para [01136] (“Types of financial reports available to end users include”)
Therefore, it would have been obvious to a person having ordinary skills in the art before the effective filing date to modify the above noted disclosure of Johnas as it relates to enterprise data management platform to include the above noted disclosure of Strutt as it relates to data warehouse system. The motivation for combining the references would have been to perform risk assessment based on historical warehouse data.
Claims 33 and 37 are similar to claim 21 and hence rejected on similar grounds.
Claim 22:
wherein the summary table comprises data associated with a plurality of transaction events.
(See Strutt: Para [01170])
Claim 23:
wherein the aggregated data table comprises a cumulative amount of transaction event data associated with a period of time.
(See Strutt: Para [01701])
Claim 24:
wherein the compensation management platform comprises a graphical user interface configured to display the aggregated data table.
(See Strutt: Figs. 22-24)
Claim 25:
wherein the graphical user interface is configured to allow a user to view the net amount of assets for an adjustable period of time.
(See Strutt: Figs. 21-24)
Claim 26:
wherein the compensation management platform provides reporting to an advisor, a manager, or an executive user.
(See Strutt: Para [0556])
Claim 27:
wherein the compensation management platform compares a net flow associated with the summary table and the aggregated data table to a predetermined productivity level.
(See Strutt: Para [1133])
Claim 28:
wherein the data source comprises at least one of a financial management service, an investment service, an automated teller machine network, or a clearing platform.(See Johnas: Para [0051])
Claim 29:
wherein the transaction event data comprises at least one of a deposit into an account or a withdrawal from the account.
(See Strutt: Para [0302])
Claim 30:
wherein transforming the transaction event data comprises at least one of modifying the transaction event data, normalizing the transaction event data, aggregating the transaction event data, removing duplicates from the transaction event data, sorting the transaction event data, or merging the transaction event data.
(See Strutt: Para [1093])
Claim 31:
wherein normalizing the transaction event data comprises removing unstructured data or redundant data from the transaction event data.
(See Strutt: Para [0126])
Claim 32:
wherein normalizing the transaction event data comprises creating a standardized format for the transaction event data.
(See Johnas: Para [0022])
Claim 34:
wherein the summary table includes a total asset amount associated with one or more preset category.
(See Strutt: Para [1071])
Claim 35:
wherein the one or more preset category comprises at least one of a product, an advisor, a sales manager, or a firm level.
(See Strutt: Para [1159])
Claim 36:
wherein the aggregated data table comprises cumulative net flow data.
(See Strutt: Para [1547])
Claim 38:
wherein the aggregated data table comprises a central table in a data warehouse dimensional data model configured to store net flow calculations.
(See Strutt: Para [1049])
Claim 39:
wherein the compensation management platform comprises a net flow summary report associated with the summary table.
(See Strutt: Figs. 21-24)
Claim 40:
wherein the compensation management platform comprises a report viewable by a user.
(See Strutt: Figs. 21-24)
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ARUNAVA CHAKRAVARTI whose telephone number is (571)270-1646. The examiner can normally be reached 9 AM - 5 PM ET.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Ryan Donlon can be reached at 571-270-3602. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/ARUNAVA CHAKRAVARTI/Primary Examiner, Art Unit 3692
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