Allstate Insurance Company

Patent Trials and Appeals Board

Jan 13, 2022

2021002459 (P.T.A.B. Jan. 13, 2022)

UNITED STATES PATENT AND TRADEMARK OFFICE UNITED STATES DEPARTMENT OF COMMERCE United States Patent and Trademark Office Address: COMMISSIONER FOR PATENTS P.O. Box 1450 Alexandria, Virginia 22313-1450 www.uspto.gov APPLICATION NO. FILING DATE FIRST NAMED INVENTOR ATTORNEY DOCKET NO. CONFIRMATION NO. 15/245,343 08/24/2016 David MacInnis 111147-691038 4248 180284 7590 01/13/2022 Polsinelli - Allstate PO Box 140310 Kansas City, MO 64114-0310 EXAMINER TRAN, HAI ART UNIT PAPER NUMBER 3697 NOTIFICATION DATE DELIVERY MODE 01/13/2022 ELECTRONIC Please find below and/or attached an Office communication concerning this application or proceeding. The time period for reply, if any, is set in the attached communication. Notice of the Office communication was sent electronically on above-indicated "Notification Date" to the following e-mail address(es): allstateip@polsinelli.com patentdocketing@polsinelli.com PTOL-90A (Rev. 04/07) UNITED STATES PATENT AND TRADEMARK OFFICE ____________________ BEFORE THE PATENT TRIAL AND APPEAL BOARD ____________________ Ex parte DAVID MACINNIS, JENNIFER JABBEN, and TERESA J. DALENTA __________________ Appeal 2021-002459 Application 15/245,343 Technology Center 3600 ____________________ Before JOSEPH A. FISCHETTI, JAMES P. CALVE, and KENNETH G. SCHOPFER, Administrative Patent Judges. CALVE, Administrative Patent Judge. DECISION ON APPEAL STATEMENT OF THE CASE Pursuant to 35 U.S.C. § 134(a), Appellant1 appeals from the decision of the Examiner to reject claims 1-8 and 21-32, which are all of the pending claims.2 Appeal Br. 7. We have jurisdiction under 35 U.S.C. § 6(b). We AFFIRM. 1 “Appellant” refers to “applicant” as defined in 37 C.F.R. § 1.42. Appellant identifies Allstate Insurance Company as the real party in interest. Appeal Br. 2. 2 Claims 9-20 are cancelled. See Appeal Br. 30 (Claims App); Final Act. 2. Appeal 2021-002459 Application 15/245,343 2 CLAIMED SUBJECT MATTER Claims 1, 21, and 29 are independent. Claim 1 recites: 1. An insurance system server, comprising: one or more processors; a security and integration layer to authenticate users and restrict access to unauthorized users; a communication interface; and at least one memory storing computer-readable instructions that, when executed by the one or more processors, cause the insurance system server to: execute an application, executing the application including: retrieve, from one or more insurance system database caches, insurance information related to a new insurance policy, wherein the insurance information comprises an insurance policy premium; determine an unrestrained rating plan premium based on a plurality of premium components, wherein the plurality of premium components comprise at least one multiplicative factor and at least one additive factor determined from the insurance information and wherein the unrestrained rating plan premium includes factors and modeling techniques different from the factors and modeling techniques used to generate the insurance policy premium; employ lists of key-pairs to store the plurality of premium components in a cloud-based storage device; determine an underwriting score based on the unrestrained rating plan premium and the insurance policy premium; identify a geographical region; determine a first underwriting score threshold based on the identified geographical region; dynamically modify the first underwriting score threshold to a second underwriting score threshold responsive to monitoring of one or more underwriting factors within the identified geographical region; Appeal 2021-002459 Application 15/245,343 3 compare the underwriting score to the second underwriting score threshold; responsive to determining that the underwriting score fails to meet the second underwriting score threshold, cause rejection of the new insurance policy; and cause display of the rejection of the new insurance policy on a user computing device. Appeal Br. 28-29 (Claims App.). REJECTION Claims 1-8 and 21-32 are rejected under 35 U.S.C. § 101 as directed to a judicial exception without significantly more. ANALYSIS Eligibility of Claims 1-8 and 21-32 The Examiner determines the claims relate to optimizing insurance policy underwriting and insurance coverage by collecting information (retrieving insurance information), processing information (determining an unrestrained rating plan premium, determining a first underwriting score, identifying a geographical region, determining an underwriting score threshold, modifying the first to a second underwriting score), comparing information (comparing underwriting score to underwriting score threshold), and identifying option (rejecting the new insurance policy if the determined underwriting score fails to meet the underwriting score threshold). Final Act. 6-7. The Examiner determines that managing an insurance policy by gathering and analyzing insurance data and rejecting a new insurance policy if the determined underwriting score fails to meet the underwriting score threshold recites a method of organizing human activity because it relates to a fundamental economic practice of insurance. Id. at 7. Appeal 2021-002459 Application 15/245,343 4 The Examiner determines that the additional elements of a processor, system, and database are general purpose computer elements used as tools to perform generic functions of retrieving, determining, identifying, modifying, comparing, and rejecting activities. Id. at 7. The Examiner determines that these elements require no more than a generic system used to carry out the abstract idea by performing such generic computer functions that are well- understood, routine, and conventional activities known in the industry to implement the abstract idea in an existing technological environment. Id. at 7-8. The Examiner further determines that there is no inventive concept in the claims because a new type of server, processor, or a system memory is not claimed, and no improvement is made to computer-related technology or technological processes for processing data. Id. at 9. Principles of Law 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. 35 U.S.C. § 101. Laws of nature, natural phenomena, and abstract ideas are not patentable. See Alice Corp. v. CLS Bank Int’l, 573 U.S. 208, 216 (2014). To distinguish patents that claim laws of nature, natural phenomena, and abstract ideas from those that claim patent-eligible applications, we first determine whether the claims are directed to a patent-ineligible concept. Id. at 217. If they are, we consider the claim elements, individually and as an ordered combination, to determine if any additional elements provide an inventive concept sufficient to ensure that the claims in practice amount to significantly more than a patent on the ineligible concept. Id. at 217-18. Appeal 2021-002459 Application 15/245,343 5 The USPTO has issued guidance about this framework. 2019 Revised Patent Subject Matter Eligibility Guidance, 84 Fed. Reg. 50 (Jan. 7, 2019) (“Revised Guidance”). To determine if a claim is “directed to” an abstract idea, we evaluate whether the claim recites: (1) any judicial exceptions, including certain groupings of abstract ideas listed in the Revised Guidance (i.e., mathematical concepts, certain methods of organizing human activities such as a fundamental economic practice, or mental processes); and (2) additional elements that integrate the judicial exception into a practical application.3 Id. at 52-55. If a claim (1) recites a judicial exception and (2) does not integrate that exception into a practical application, we consider whether the claim (3) provides an inventive concept such as by adding a limitation beyond a judicial exception that is not “well-understood, routine, conventional” in the field or (4) appends well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception. Revised Guidance, 84 Fed. Reg. at 56. Step 1 We agree with the Examiner that the claims recite a method, computer system, and computer program, which fall within the statutory categories of invention of a process, machine, and article of manufacture, respectively. See 35 U.S.C. § 101; Final Act. 6. 3 “A claim that integrates a judicial exception into a practical application will apply, rely on, or use the judicial exception in a manner that imposes a meaningful limit on the judicial exception, such that the claim is more than a drafting effort designed to monopolize the judicial exception.” Revised Guidance, 84 Fed. Reg. at 54. Appeal 2021-002459 Application 15/245,343 6 Alice Step One Revised Guidance Step 2A, Prong One: Do the Claims Recite a Judicial Exception? We agree with the Examiner that the claims recite steps and functions that manage and organize insurance information for new insurance policies, which is a fundamental economic practice and method of organizing human activity. See Final Act. 6-7; Ans. 5; Revised Guidance, 84 Fed. Reg. at 52. Some limitations also recite mental processes and mathematical calculations. The focus of the claims is on “optimizing coverage for an insurance policy based on a comparison between a currently charged premium and an unrestrained rating plan” premium. Spec. ¶ 1. The application title reflects this focus as SYSTEM AND NETWORK FOR TIERED OPTIMIZATION. Organizing and managing information to develop insurance policies to issue recites a fundamental economic practice. See Accenture Glob. Servs., GmbH v. Guidewire Software, Inc., 728 F.3d 1336, 1346 (Fed. Cir. 2013) (claims to generating tasks based on rules in an insurance organization is an abstract idea) (cited in OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1362 (Fed. Cir. 2015) as illustrative of a fundamental economic practice of “generating tasks in an insurance organization”); Bancorp Servs., L.L.C. v. Sun Life Assur. Co. of Can. (U.S.), 687 F.3d 1266, 1280 (Fed. Cir. 2012) (managing a stable value protected life insurance policy by performing calculations and manipulating the results is an abstract idea); see also buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1354-55 (Fed. Cir. 2014) (claiming a contractual relationship of a transaction performance guaranty is a longstanding commercial transaction and abstract idea); OIP, 788 F.3d at 1362 (offer-based price optimization is a fundamental economic concept). Here, an insurance premium is optimized. See Spec. ¶¶ 15-17, 21-27, 49. Appeal 2021-002459 Application 15/245,343 7 We agree with the Examiner that retrieving insurance information, determining an unrestrained rating plan premium and an underwriting score based thereon, determining a first underwriting score threshold based on an identified geographical region, dynamically modifying the threshold to a second threshold, comparing the second threshold to the underwriting score, and rejecting a new insurance policy when the underwriting score does not meet the second threshold recite aspects of this abstract idea. Ans. 5. According to the Specification, the unrestrained premium is based on a combination of components that may be determined by a variety of factors and various algorithms and/or equations. Spec. ¶¶ 28, 29. An underwriting score is determined by comparing an insurance policy premium quotation with an unrestrained premium by using various algorithms or equations. Id. ¶¶ 49-56. An underwriting score threshold may be determined by region or zone, and it may be modified dynamically based on monitoring. Id. ¶¶ 57, 104. If the underwriting score is below an underwriting score threshold, an underwriting score threshold indicator may indicate that a new insurance policy should be rejected. Id. ¶ 58. No technical details are claimed. This description confirms the abstract nature of these limitations. See Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d 1350, 1354 (Fed. Cir. 2016) (“In a similar vein, we have treated analyzing information by steps people go through in their minds, or by mathematical algorithms, without more, as essentially mental processes within the abstract-idea category.”); see also SAP Am., Inc. v. InvestPic, LLC, 898 F.3d 1161, 1167 (Fed. Cir. 2018) (“The focus of the claims, as reflected in what is quoted above, is on selecting certain information, analyzing it using mathematical techniques, and reporting or displaying the results of the analysis. That is all abstract.”). Appeal 2021-002459 Application 15/245,343 8 Retrieving an insurance policy premium for a new insurance policy can be performed as a mental process. Elec. Power, 830 F.3d at 1355 (“But merely selecting information, by content or source, for collection, analysis, and display does nothing significant to differentiate a process from ordinary mental processes, whose implicit exclusion from § 101 undergirds the information-based category of abstract ideas.”); CyberSource Corp. v. Retail Decisions, Inc., 654 F.3d 1366, 1372-73 (Fed. Cir. 2011) (obtaining credit card transaction information can be performed by a human who simply reads records of Internet credit card transactions from a preexisting database even if physical steps are used such as entering a query via keyboard or a mouse); see also Revised Guidance, 84 Fed. Reg. at 55 (mere data gathering adds only insignificant extra-solution activity to a judicial exception). In view of these precedents, we are not persuaded by Appellant’s arguments that the claims do not recite fundamental economic principles or practices, methods of organizing human activity, or another enumerated abstract idea in the Revised Guidance. See Appeal Br. 7-9 (claim 1), 14-16 (claim 21), 20-22 (claim 29); see also Revised Guidance, 84 Fed. Reg. at 52 nn.12-14 (citing Bancorp as an example of a claim reciting mathematical concepts and a fundamental economic practice of managing a stable value protected life insurance policy and CyberSource as an example of a claim reciting mental processes). The Specification indicates that the “insurance policy premium” may be determined using traditional or conventional methods that apply business rules. Spec. ¶ 15. The “unrestrained rating plan premium” may be based on “factors, interactions, rating variables, and modeling techniques” that are not based on traditional or conventional methods. Id. ¶¶ 15, 27. Appeal 2021-002459 Application 15/245,343 9 Determining an underwriting score based on an unrestrained rating plan premium and a regular insurance policy premium and comparing that score to a threshold value optimizes underwriting decisions and mitigates risk. Indeed, “[t]he underwriting module 208 may perform the underwriting determination during a risk assessment phase of a quoting process.” Spec. ¶ 58 (emphasis added). If the underwriting score is below a threshold, an underwriting score threshold indicator may indicate to reject an insurance policy. Id. Mitigating risk is a fundamental economic practice and a method of organizing human activity. See Alice, 573 U.S. at 219-20 (exchanging financial obligations between parties via a third-party intermediary mitigates settlement risk which is a fundamental economic practice); Bilski v. Kappos, 561 U.S. 593, 611 (2010) (hedging/protecting against risk is a fundamental economic practice that reduces to a mathematical formula); see also Revised Guidance, 84 Fed. Reg. at 52. Here, “[t]he unrestrained premium 203 may serve as a secondary unconstrained rating plan with which to compare an insurance premium determined using a traditional or conventional method.” Spec. ¶ 27. Its use in performing underwriting decisions and underwriting calculations mitigates the risk of underwriting errors. See id. ¶¶ 27, 58, 59. As discussed above, determining an unrestrained rating plan with at least one multiplicative and one additive factor, determining an underwriting score, determining a first underwriting score threshold, modifying it to a second underwriting score threshold, comparing the underwriting score to the second threshold, and determining that the underwriting score fails to meet the second threshold also recite mental processes and mathematical concepts in addition to reciting the fundamental economic practices of insurance policy underwriting and processing and risk mitigation. Appeal 2021-002459 Application 15/245,343 10 As described in the Specification, the determinations and comparison involve mathematical formulas and/or equations. See Spec. ¶¶ 28, 29, 49- 58, 77, 90. Thus, they recite the abstract idea identified above. Elec. Power, 830 F.3d at 1354 (analyzing information by mental steps or mathematical algorithms is an abstract idea in the mental process category); Bancorp, 687 F.3d at 1277-78 (citing definitions of “computer” and explaining that the meanings illustrate the interchangeability of certain mental processes and basic digital computation, and help explain why the use of a computer in an otherwise patent-ineligible process for no more than its basic functions of making calculations and computations fails to circumvent the prohibition against patenting abstract ideas and mental processes). Accordingly, we determine that the claims recite the abstract idea identified above. Alice Step One Revised Guidance Step 2A, Prong Two: Is There an Integration into a Practical Application? We next consider whether the claims recite additional elements that integrate the abstract idea into a practical application. Revised Guidance, 84 Fed. Reg. at 54. We agree with the Examiner that the additional elements of an insurance system server, security and integration layer, communication interface, processor, memory, and database cache are tools used to perform the abstract idea by performing generic functions of retrieving, determining, identifying, determining, modifying, and comparing without improving any computer technology, using a particular machine that is integral to the claim, or transforming or reducing a particular article to a different state or thing. See Final Act. 7-8; Ans. 7-8. Thus, they do not integrate the abstract idea into a practical application. See Revised Guidance, 84 Fed. Reg. at 55. Appeal 2021-002459 Application 15/245,343 11 The server is a computer device 101 with processor 103 to controls its operation and RAM 105, ROM 107, input/output module 109, and memory 115. Spec. ¶ 16. It may operate in a network connected to remote terminals or computers 141, 151. Id. ¶ 19. The memory stores software in volatile, nonvolatile, removable, and non-removable media using computer-readable instructions, data structures, or program modules. Id. ¶ 17. Processor 103 may be a single central processing unit (CPU), a single-core or multi-core processor, or multiple CPUs of various bit sizes and speeds. Id. ¶ 18. Such a generic computer implementation does not improve computers or other technology as a patent-eligible application. See Alice, 573 U.S. at 223-24; Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709, 716-17 (Fed. Cir. 2014). Security and integration layer 160 may comprise one or more separate computing devices, e.g., web servers, authentication servers, and/or various networking components like firewalls, routers, gateways, and load balancers. Id. ¶ 20. It may authenticate users and restrict access to unauthorized users using various secure transmission network communication protocols such as File Transfer Protocol, Secure File transfer Protocol or Pretty Good Privacy encryption. Id. Thus, it does not improve computers or security technology. See Universal Secure Registry LLC v. Apple Inc., 10 F.4th 1342, 1352 (Fed. Cir. 2021) (a biometric sensor, user interface, communication interface, and processor working together to authenticate a user based on two factors and generate encrypted authentication information without improving any underlying technology or solving any technological problem was directed to an abstract idea); Prism Techs. LLC v. T-Mobile USA, Inc., 696 F. App’x 1014, 1016-17 (Fed. Cir. 2017) (merely using an authentication server to control or restrict access to computer resources is an abstract idea); Ans. 6. Appeal 2021-002459 Application 15/245,343 12 Using a generic security and integration layer to authenticate users and restrict access to authorized users does not improve computers or other technology without more. The description of this feature confirms it is not a specific technical solution for authentication or restricted access. Spec. ¶ 20. The communication interface is a local area network (LAN) interface or adapter 123 for a LAN networking environment or a modem 127 or other means for establishing communications over a wide area network (WAN). Spec. ¶ 19; see Appeal Br. 2 (citing Spec. ¶ 19 as support for this element). The key-pairs are described generically as well. A reporting module 206 may use flat files, lists of key-pairs, object-oriented databases, relational databases, and the like to maintain and/or store the premium components. Spec. ¶ 28. No technical details are provided to indicate an improvement to computers or other technology by the use of key-pairs to store components of premium data. See BSG Tech LLC v. Buyseasons, Inc., 899 F.3d 1281, 1287 (Fed. Cir. 2018) (“Thus, the recitation of a database structure slightly more detailed than a generic database does not save the asserted claims at step one.”); Intellectual Ventures I LLC v. Capital One Fin. Corp., 850 F.3d 1332, 1341 (Fed. Cir. 2017) (“Although these data structures [PRTs and MRTs] add a degree of particularity to the claims, the underlying concept embodied by the limitations merely encompasses the abstract idea itself of organizing, displaying, and manipulating data of particular documents.”). Appellant argues that the claims recite multiple, specific, detailed steps to retrieve data from particular caches, evaluate data, determine underwriting scores and thresholds, and dynamically modify the threshold based on geographical location and monitoring of factors. Appeal Br. 9-11, 16-17, 22-23. Appeal 2021-002459 Application 15/245,343 13 The Specification describes “database caches” from which insurance information for a new insurance policy is retrieved as generic components. “[A] database cache may be created in which certain data from a database 121 (e.g., insurance policy data, confidential user data, etc.) is cached in a separate smaller database on an application server separate from the database server (e.g., at a personal mobile device, or intermediary network device or cache device, etc.).” Spec. ¶ 22. A database cache may “reduce data retrieval and data manipulation time by not needing to communicate over a network with a back-end database server.” Id. This description indicates that the “database caches” perform generic functions of storing insurance information in a location that may be easier or faster to retrieve according to the Specification. Cf. Visual Memory LLC v. NVIDIA Corp., 867 F.3d 1253, 1259-60 (Fed. Cir. 2017) (The ’740 patent’s claims focus on a “specific asserted improvement in computer capabilities”-the use of programmable operational characteristics that are configurable based on the type of processor-instead of “on a process that qualifies as an ‘abstract idea’ for which computers are invoked merely as a tool.”). The claims in Visual Memory “require[d] a memory system with a main memory and a cache memory, where the memory system is configured by a computer to store a type of data in the cache memory based on the type of processor connected to the memory system.” Id. at 1260. Thus, a programmable operational characteristic of the system determined a type of data stored by the cache so the system could be configured based on the type of processor. The selective definition of the functions of the cache memory based on the processor type outperformed prior art memory systems of much larger size. Id. at 1259. Appeal 2021-002459 Application 15/245,343 14 Here, the claims recite an insurance system server that retrieves “insurance information related to a new insurance policy, wherein the insurance information comprises an insurance policy premium” from “insurance system database caches.” No improvement to computers results from retrieving insurance policy premiums from database caches beyond generic speed or efficiency improvements commonly associated with the use of a cache. The cache is a storage location from which an insurance policy premium may be retrieved. Any improvements in speed from such generic computer implementation are not sufficient to make an abstract idea patent eligible. See Accenture, 728 F.3d at 1345 (“The limitations of claim 1 are essentially a database of tasks, a means to allow a client to access those tasks, and a set of rules that are applied to that task on a given event.”); see also Customedia Techs., LLC v. Dish Network Corp., 951 F.3d 1359, 1365 (Fed. Cir. 2020) (“The claims of the ’090 and ’494 patents do not enable computers to operate more quickly or efficiently, nor do they solve any technological problem. They merely recite reserving memory to ensure storage space is available for at least some advertising data. . . . The only improvements identified in the specification are generic speed and efficiency improvements inherent in applying the use of a computer to any task. ”); Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 1370 (Fed. Cir. 2015) (“[O]ur precedent is clear that merely adding computer functionality to increase the speed or efficiency of the process does not confer patent eligibility on an otherwise abstract idea.”). Here, the “database caches” are generic components. They do not improve ways for systems to store and access data. See BSG, 899 F.3d at 1288; Spec. ¶ 22 (caches may provide potential advantages such as faster response times). Appeal 2021-002459 Application 15/245,343 15 A similar method of generating tasks in an insurance organization and updating insurance transaction information (policy, claim, participant, line levels) recited an abstract idea in Accenture. Accenture, 728 F.3d at 1338- 39. Using rules to generate tasks to be completed on occurrence of an event is “a database of tasks, a means to allow a client to access those tasks, and a set of rules that are applied to that task on a given event.” Id. at 1345. The complexity of implementing software and level of detail in the specification did not transform a claim that recited only an abstract concept into a patent- eligible application. Id. The client component and its business component served as a data cache with logic for manipulating data. Id. at 1338. Here, in addition to retrieving an insurance policy premium, which the Specification indicates is determined by business rules (see Spec. ¶ 15), the claims process data by determining an unrestrained rating plan premium, an underwriting score, and thresholds that are compared to scores. All of these functions are recited without any technical implementation details. As such, they recite result-based activities without any improvements to computers or other technology. See Ericsson Inc. v. TCL Commc’n Tech. Holdings Ltd., 955 F.3d 1317, 1328 (Fed. Cir. 2020) (“Merely claiming ‘those functions in general terms, without limiting them to technical means for performing the functions that are arguably an advance,’ does not make a claim eligible at step one.”) (citations omitted)); see SAP, 898 F.3d at 1167-68 (to avoid patent ineligibility, a claim must have the specificity that transforms it from one claiming only a result to one claiming a way of achieving the result); Elec. Power, 830 F.3d at 1356 (noting that the essentially result-focused, functional character of the claim language at issue is a frequent feature of claims that are held to be ineligible under § 101). Appeal 2021-002459 Application 15/245,343 16 Even if the Specification described particular technical improvements for implementing database caches, none of those details are claimed. Thus, they cannot be relied on for an integration. See Ericsson, 955 F.3d at 1325 (“[T]he specification may be ‘helpful in illuminating what a claim is directed to . . . [but] the specification must always yield to the claim language’ when identifying the ‘true focus of a claim.’”); Accenture, 728 F.3d at 1345 (“[T]he complexity of the implementing software or the level of detail in the specification does not transform a claim reciting only an abstract concept into a patent-eligible system or method.”). The other features relied on by Appellant to support integration are features of the abstract idea identified under Prong One. Thus, they cannot provide additional elements that integrate that abstract idea into a practical application. See Revised Guidance, 84 Fed. Reg. at 55 n.24 (“additional elements” refer to claim features, limitations, and/or steps that are recited in a claim beyond the identified judicial exception); see also Alice, 573 U.S. at 221 (a claim that recites an abstract idea must include additional features to ensure it is more than a drafting effort designed to monopolize the abstract idea); Versata Dev. Grp., Inc. v. SAP Am., Inc., 793 F.3d 1306, 1332 (Fed. Cir. 2015) (same). Even if we consider these limitations as additional elements, they do not improve computers or other technology. They recite data processing steps to retrieve insurance information (a policy premium), determine an unrestrained rating plan premium based on premium components, factors, and modeling techniques different from factors and modeling techniques used to generate an insurance policy premium, and determine an underwriting score and underwriting score threshold that is modified. Appeal 2021-002459 Application 15/245,343 17 No technical implementation details are claimed. They recite result- based functions that “do not ‘ha[ve] the specificity required to transform a claim from one claiming only a result to one claiming a way of achieving it.’” Ericsson, 955 F.3d at 1328. As discussed above, the Specification describes the structure and functions of these components generically with no indication that they represent improvements to computers, software, or other technology. See Interval Licensing LLC v. AOL, Inc., 896 F.3d 1335, 1343 (Fed. Cir. 2018) (software can make non-abstract improvements to computer technology but software-based inventions that do not pass § 101 muster fail because “they did not recite any assertedly inventive technology for improving computers as tools and/or because the elements of the asserted invention were so result-based that they amounted to patenting the patent- ineligible concept itself.”). Even if the claims do not monopolize every process of managing an insurance policy, they nonetheless recite an abstract idea without integrating it into a practical application. “[W]hile preemption may signal patent ineligible subject matter, the absence of complete preemption does not demonstrate patent eligibility.” FairWarning IP, LLC v. Iatric Sys., Inc., 839 F.3d 1089, 1098 (Fed. Cir. 2016) (quoting Ariosa Diagnostics, Inc. v. Sequenom, Inc., 788 F.3d 1371, 1379 (Fed. Cir. 2015)); OIP, 788 F.3d at 1362-63 (“[T]hat the claims do not preempt all price optimization or may be limited to price optimization in the e-commerce setting do not make them any less abstract.”). Furthermore, as the court held in Ariosa, “[w]here a patent’s claims are deemed only to disclose patent ineligible subject matter under the Mayo framework, as they are in this case, preemption concerns are fully addressed and made moot.” Ariosa, 788 F.3d at 1379. Appeal 2021-002459 Application 15/245,343 18 Even if the claimed arrangement determines an insurance premium based on “factors, interactions, rating variables and/or modeling techniques that were not used in determining a premium in conventional systems” to “enable greater flexibility and accuracy in generating insurance premiums for a user” (see Appeal Br. 11, 17, 23), as claimed, any improvement is in the abstract realm rather than to computers or other technology. Even if the techniques are groundbreaking, innovative, or brilliant, that is not enough for eligibility. SAP, 898 F.3d at 1163 (“No matter how much of an advance in the finance field the claims recite, the advance lies entirely in the realm of abstract ideas, with no plausibly alleged innovation in the non-abstract application realm. An advance of that nature is ineligible for patenting.”). Here, the features do not improve computers or other technology. They do not require a particular machine that is integral to the claims. They do not transform a particular article to a different state or thing. They do not limit the abstract idea in a meaningful way. Ans. 7-8. Combining one abstract idea (fundamental economic practices) with another abstract idea (mental processes) is not sufficient. See RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327 (Fed. Cir. 2017) (“Adding one abstract idea (math) to another abstract idea (encoding and decoding) does not render the claim non-abstract.”); Apple, Inc. v. Ameranth, Inc., 842 F.3d 1229, 1240 (Fed. Cir. 2016) (“An abstract idea can generally be described at different levels of abstraction.”); Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 1151 (Fed. Cir. 2016) (“[A] claim for a new abstract idea is still an abstract idea.”). Accordingly, we determine that the claims lack additional elements that are sufficient to integrate the abstract idea into a practical application. Appeal 2021-002459 Application 15/245,343 19 Alice, Step Two and Revised Guidance Step 2B: Do the Claims Include an Inventive Concept? We next consider whether the claims recite any additional elements, individually or as an ordered combination, to provide an inventive concept. Alice, 573 U.S. at 217-18. This step is satisfied when limitations involve more than well-understood, routine, and conventional activities known in the industry. See Berkheimer v. HP Inc., 881 F.3d 1360, 1367 (Fed. Cir. 2018). The server, processors, security and integration layer, communication interface, memory, and database caches are sufficiently well-known that the details of their structure and functionality do not need to be described in the Specification beyond their conventional nature. See Memorandum, Subject: Changes in Examination Procedure Pertaining to Subject Matter Eligibility, Recent Subject Matter Eligibility Decision (Berkheimer v. HP, Inc.), dated April 19, 2018; Spec. ¶¶ 16-23, Fig. 1; Ans. 10-11; Final Act. 7. As an ordered combination, they recite no more than when they are considered individually. See BSG, 899 F.3d at 1290-91 (“If a claim’s only ‘inventive concept’ is the application of an abstract idea using conventional and well-understood techniques, the claim has not been transformed into a patent-eligible application of an abstract idea.”); SAP, 898 F.3d at 1169-70 (claims to already available databases and processors that perform already available basic functions to include generic parallel processing components that are not asserted to be inventive to carry out improved mathematical calculations amounts to reciting what is well-understood, routine, and conventional); Elec. Power, 830 F.3d at 1355 (claims to using off-the-shelf, conventional computer, network, and display technology to gather, send, and present desired information lack an inventive concept). Appeal 2021-002459 Application 15/245,343 20 Without more, automation of a manual process does not improve technology. See Alice, 573 U.S. at 225 (“Using a computer to create and maintain ‘shadow’ accounts amounts to electronic recordkeeping-one of the most basic functions of a computer.”); OIP, 788 F.3d at 1363 (“At best, the claims describe the automation of the fundamental economic concept of offer-based price optimization through the use of generic computer functions.”); Credit Acceptance Corp. v. Westlake Servs., 859 F.3d 1044, 1055 (Fed. Cir. 2017) (configuring generic computers to supplant and enhance an abstract manual process is the sort of invention that is ineligible for patenting); see also Bozeman Fin. LLC v. Fed. Reserve Bank of Atl., 955 F.3d 971, 980-81 (Fed. Cir. 2020) (using well-known computer components to collect and analyze data, present data, and send notifications recites a logical sequence with no inventive concept); Inventor Holdings, 876 F.3d at 1378 (sequence of data retrieval, analysis, modification, generation, display and transmission amounts to instructions to apply the abstract idea using generic computer technology with no inventive concept); Two-Way Media, 874 F.3d at 1339 (“The claim uses a conventional ordering of steps--first processing the data, then routing it, controlling it, and monitoring its reception--with conventional technology to achieve its desired result.”); Versata, 793 F.3d at 1335 (steps of arranging, storing, retrieving, sorting, eliminating, and determining are conventional, routine, and well-known functions of a computer); In re Katz Interactive Call Processing Patent Litig., 639 F.3d 1303, 1316 (Fed. Cir. 2011) (processing, receiving, and storing functions can be performed by any general purpose computer). Accordingly, we sustain the rejection of claims 1-8 and 21-32 as directed to an abstract idea without significantly more. Appeal 2021-002459 Application 15/245,343 21 CONCLUSION In summary: Claim(s) Rejected 35 U.S.C. § References/Basis Affirmed Reversed 1-8, 21-32 101 Eligibility 1-8, 21-32 TIME PERIOD FOR RESPONSE No time period for taking any subsequent action in connection with this appeal may be extended under 37 C.F.R. § 1.136(a). See 37 C.F.R. § 1.136(a)(1)(iv). AFFIRMED