David Brooker et al.

Patent Trials and Appeals Board

Feb 1, 2022

2021002872 (P.T.A.B. Feb. 1, 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. 12/718,556 03/05/2010 David E. Brooker 002328.0784 5106 5073 7590 02/01/2022 BAKER BOTTS L.L.P. 2001 Ross Avenue, Suite 900 Dallas, TX 75201 EXAMINER OJIAKU, CHIKAODINAKA ART UNIT PAPER NUMBER 3696 NOTIFICATION DATE DELIVERY MODE 02/01/2022 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): PTOmail1@bakerbotts.com PTOL-90A (Rev. 04/07) UNITED STATES PATENT AND TRADEMARK OFFICE ____________________ BEFORE THE PATENT TRIAL AND APPEAL BOARD ____________________ Ex parte DAVID E. BROOKER, CARLETON D. BURTT, CHRISTOPHER D. SCHOTT, and DANIEL STRINGHAM __________________ Appeal 2021-002872 Application 12/718,556 Technology Center 3600 ____________________ Before HUBERT C. LORIN, JAMES P. CALVE, and BRADLEY B. BAYAT, 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 1-4 and 6-25, which are all of the pending claims.2 See Appeal Br. 3. 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 The Prudential Insurance Company of America as the real party in interest. See Appeal Br. 2. 2 Claim 5 is cancelled. See Appeal Br. 14 (Claims App.). Appeal 2021-002872 Application 12/718,556 2 CLAIMED SUBJECT MATTER Claims 1, 15, and 21 are independent. Claim 1 is illustrative and recites a method with brackets added to individual limitations: 1. A method for managing a group life insurance policy with a plurality of certificates funded by a sponsor, each certificate providing a death benefit to at least one beneficiary designated by a respective person insured under the certificate, the method comprising: [a] determining, by a computing system, an initial payment to be paid by the sponsor as a lump sum in exchange for the plurality of certificates, the initial payment representing a principal balance in a financial account corresponding to the group life insurance policy; [b] after receiving the initial payment from the sponsor, allocating, by the computing system, at least a respective portion of the initial payment to each certificate of the plurality of certificates; [c] monitoring, by the computing system, for a non- death-related event that affects one of the plurality of certificates; and in response to detection of the non-death-related event: [d] receiving, by the computing system, input corresponding to one or more of the affected certificate and a new certificate providing a death benefit to at least one beneficiary designated by a person insured under the new certificate; [e] generating, by the computing system, a data table comprising information derived from the received input; and [f] determining, by the computing system, a reallocation of the financial account based at least in part on data within the data table, wherein determining the reallocation comprises: [g] retrieving, from storage, a plurality of rules configured to increase the likelihood that each certificate of the plurality of certificates is optimally funded; and Appeal 2021-002872 Application 12/718,556 3 [h] determining that one or more of the plurality of rules is applicable based on the data within the data table; [i] in response to determining the reallocation of the financial account, exchanging, by the computing system, the one of the plurality of certificates for the new certificate, wherein the exchanging comprises reallocating to the new certificate at least a portion of the respective portion of the initial payment allocated to the one of the plurality of certificates; and [j] automatically processing one or more debits drawn against the financial account in accordance with the group life insurance policy. Appeal Br. 13-14 (Claims App.). REJECTION Claims 1-4 and 6-25 are rejected under 35 U.S.C. § 101 as directed to a judicial exception without significantly more. ANALYSIS Eligibility of Claims 1-4 and 6-25 Appellant argues the claims as a group. See Appeal Br. 7-11. We select claim 1 as representative. See 37 C.F.R. § 41.37(c)(1)(iv)(2019). The Examiner determines that claim 1 recites a method of managing a group life insurance policy by optimizing a re-allocation of insurance policy certificates triggered by a non-death-related event, which is a fundamental economic practice and a method of organizing human activity. Final Act. 5; Ans. 3-5. The Examiner cites limitations [a], [c], and [d]-[j], as annotated on claim 1 above, as reciting this abstract idea. Ans. 3-4; Final Act. 4-5. The Examiner determines that claims 15 and 21 contain similar limitations as claim 1 and are rejected on the same basis. Ans. 3. Appeal 2021-002872 Application 12/718,556 4 The Examiner determines that the additional element of a “computing system” is recited at a high level of generality as a generic computer that performs generic computer functions to receive/generate/exchange data and amounts to no more than instructions to apply the abstract idea on generic computer components. Ans. 6-7; Final Act. 5-6. The Examiner determines that the Specification describes this computing system as a generic computer that performs generic functions and automates tasks to reduce processing time, which, without more, is not a technical improvement. Ans. 6. For similar reasons, the Examiner determines that the additional element does not amount to significantly more than the judicial exception but merely applies the judicial exception by using generic computer components that do not provide an inventive concept. Final Act. 6. 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 2021-002872 Application 12/718,556 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 claim 1 recites a method, which falls within a statutory category of invention of a “process.” See 35 U.S.C. § 101; Final Act. 5. 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 2021-002872 Application 12/718,556 6 Alice Step One Revised Guidance Step 2A, Prong One: Do the Claims Recite a Judicial Exception? We agree with the Examiner that claim 1 recites a method for managing and administering a group life insurance policy by reallocating insurance policy certificates upon occurrence of a non-death-related event, which is a fundamental economic practice within the certain methods of organizing human activity category of abstract ideas. See Final Act. 4-5; Ans. 3-5; Revised Guidance, 84 Fed. Reg. at 52 (identifying certain methods of organizing human activity as including fundamental economic principles and practices such as hedging, insurance, and mitigating risk). The title of the application reflects this focus on a SYSTEM AND METHOD FOR MANAGING A GROUP INSURANCE POLICY. The Technical Field “relates in general to the field of financial systems, and more particularly to a system and method for managing a group insurance policy.” Spec. 1:7-8. The Summary of the Invention also focuses on “a method for providing a group life insurance policy with a plurality of certificates funded by a sponsor.” Id. at 3:2-3. Group life insurance policies are offered to a group that shares a qualifying characteristic such as being employees of a sponsor, and these people designate beneficiaries to receive a benefit under a certificate. Id. at 2:11-13, 5:10-6:1, 7:3-10. A sponsor is a company that purchases a group life insurance policy. Id. at 6:20-21. Each certificate 152 insures the life of a covered designator 108 while the designator 108 is employed by sponsor 106. Id. at 8:1-3. When a designator’s employment ends, the group life insurance policy may exchange the former employee’s certificate for a new certificate that insures the life of a new designator who may be a current or a new employee of sponsor 106. Id. at 8:8-13. Appeal 2021-002872 Application 12/718,556 7 Because a new certificate of a new employee added to a group life insurance policy may require different funding than the certificate of the former employee for which it is exchanged, funds may be reallocated from their initial values and new deposits provided to continue the group life insurance policy so the new certificate is funded at an optimum cell value (OCV) and the group life insurance policy no longer reflects the surrendered certificate of the former employee. See Spec. 18:3-20:7, 21:16-22:11. Consistent with this description, the preamble of claim 1 recites “[a] method for managing a group life insurance policy with a plurality of certificates funded by a sponsor, each certificate providing a death benefit to at least one beneficiary designated by a respective person insured under the certificate.” Appeal Br. 13 (Claims App.). Claim 1 recites various steps that are followed to manage or administer the group life insurance policy from its inception through the occurrence of a non-death-related event to include the exchange of a surrendered certificate for a new certificate under the policy. The first two steps (steps [a] and [b]) are initial steps in administering a group life insurance policy by receiving and applying funds to the policy. They are “determining . . . an initial payment to be paid by the sponsor as a lump sum in exchange for the plurality of certificates” and “allocating . . . at least a respective portion of the initial payment to each certificate of the plurality of certificates.” Appeal Br. 13 (Claims App.). An initial aggregate payment 158 is paid by sponsor 106 to issuer 104 at the inception of group life insurance policy 102. Payment 158 may be used to establish financial account 160 from which issuer 104 withdraws funds for premiums and costs. Spec. 10:17-11:30. Portions of payment 158 are allocated as deposits to each certificate to fund it at an optimal cell value (OCV). Id. at 18:17-20:7. Appeal 2021-002872 Application 12/718,556 8 Funds may be held in financial account 60 of the group life insurance policy 102 as a principal balance of amounts deposited by sponsor 106 to issuer 104 (id. at 11:15-28) and allocated for each certificate 152 based on an allocation factor calculated using various factors such as age, gender, health, salary, years of employment, job code, and lifestyle (id. at 18:17-26). The remaining limitations (steps [c] through [j]) involve administering the group life insurance policy by monitoring for a non-death-related event and, when an event is detected, receiving input for affected certificates and a new certificate, “generating . . . a data table” with this data, and using the table to determine a reallocation of the financial account so one of the plural certificates affected by a non-death-related event can be exchanged for the new certificate. Appeal Br. 13-14 (Claims App.). Reallocation can occur by determining an applicable stored rule that is configured to increase the likelihood that each certificate is optimally funded. Id. at 13. According to the Specification, Manager Application 310 monitors for non-death-related events such as data indicating a change in a relationship of one or more designators 108 and sponsor 106 such as a designator(s) 108 no long is employed by sponsor 106. Spec. 21:16-22:4. Clients 302 of sponsor 106 may communicate this data to Manager Application 310. Id. at 23:9-15. Human resources and/or automated programs may generate a data table with this information extracted from communicated files. Id. at 23:3-9. Rules are applied so a reallocation occurs in a way that increases a likelihood that each certificate 152 is funded optimally. Id. at 24:10-30. If the OCV of a pending certificate 152 is within a predetermined reallocation tolerance of the OCV for a surrendering certificate, the surrendering certificate may be exchanged for the pending certificate of a new designator. Id. Appeal 2021-002872 Application 12/718,556 9 Our reviewing court has determined that similar claims to managing an insurance policy and performing tasks under an insurance policy such as processing insurance claims involve a fundamental economic practice. See Accenture Glob. Servs., GmbH v. Guidewire Software, Inc., 728 F.3d 1336, 1346 (Fed. Cir. 2013) (“The abstract idea at the heart of system claim 1 of the ’284 patent is ‘generating tasks [based on] rules ... to be completed upon the occurrence of an event.’”) (cited in OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1362 (Fed. Cir. 2015) as an example of the 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) (cited in Revised Guidance, 84 Fed. Reg. at 52 n.13 as an example of a fundamental economic practice). In Accenture, the claims recited a method of generating tasks to be performed in an insurance organization by applying information related to an insurance transaction to rules to determine tasks to be completed. Accenture, 728 F.3d at 1338-39. Here, claim 1 recites a method of generating tasks (determining reallocation of a financial account) to be performed by an insurance entity upon the occurrence of an event (a non-death-related event that affects one of the plurality of certificates) by applying rules from “storage” to insurance information in a data table. The Specification describes insurance as a form of risk management used to hedge against the risk of contingent loss. Spec. 2:2-3. Hedging or mitigating risk is a fundamental economic practice. See Alice, 573 U.S. at 219; Bilski v. Kappos, 561 U.S. 593, 611 (2010); Revised Guidance, 84 Fed. Reg. at 52. Thus, claim 1 recites an abstract idea on this basis as well. Appeal 2021-002872 Application 12/718,556 10 Appellant argues that the Examiner failed to establish a prima facie case that claim 1 is directed to an abstract idea because the rejection cites the entirety of claim 1 as reciting a fundamental economic practice and method of organizing human activity without explaining why specific limitations fall within any of the enumerated groupings of abstract ideas. Appeal Br. 7. The Examiner’s rejection adequately advised Appellant of the grounds of rejection by identifying limitations of claim 1 that recite certain methods of organizing human activity and a fundamental economic practice. Final Act. 4-5; Ans. 3-5. The Examiner explained that the limitations “describe steps a person would take to protect against a potential risk of loss which is similar to concepts courts have held to be abstract (see Bancorp and Bilski) [wherein] insurance premium payments are reallocated towards an existing group policy based on a non-death related event.” Ans. 5. The Examiner cited the Specification’s description of the allocation of funds from financial account 160 among multiple certificates as steps for administering a group life insurance policy. Id. at 4-5. Even if these steps recite an improvement to existing group life insurance policy administration systems, as Appellant asserts (Reply Br. 2-3), they still recite steps of administering an insurance policy, which is a fundamental economic practice and an abstract idea as discussed above. See 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.”). Appellant received adequate notice of the grounds of rejection but has not explained persuasively why the identified limitations do not relate to managing a group life insurance policy. See In re Jung, 637 F.3d 1356, 1362 (Fed. Cir. 2011). Accordingly, we determine that claim 1 recites the abstract idea identified above. Appeal 2021-002872 Application 12/718,556 11 Alice Step One Revised Guidance Step 2A, Prong Two: Is There an Integration into a Practical Application? We next consider whether claim 1 recites additional elements that integrate the abstract idea into a practical application. Revised Guidance, 84 Fed. Reg. at 54. We agree with the Examiner that a “computing system” is recited at a high level of generality as a generic computer component that performs generic functions of the abstract idea. Final Act. 5-6; Ans. 6. It does not integrate the abstract idea into a practical application because it does not represent improvements to computer technology or computer capabilities. It is not a particular machines that is integral to the claim or that transforms or reduces a particular article to a different state or thing or applies the abstract idea in some other meaningful way beyond generally linking it to a particular technological environment. See Revised Guidance, 84 Fed. Reg. at 55. The Specification describes the computing system as a generic server 306 and illustrates it in Figure 3 as a generic computing device. See Spec. 15:1-17:4. Server(s) 306 may include hardware, software, firmware, or a combination, and it be capable of receiving communication from client 302. Id. at 16:12-13. It may include one or more directory servers, client servers file servers, domain name servers, proxy servers, web servers, application servers, computer workstations, data repositories, and combinations. Id. at 16:13- 19. Management application 310, which performs the reallocation and exchange of certificates based on data tables and funding deposits, as claimed, resides in a memory 312 of server 306. Id. at 16:25-27. This description confirms that the computing system is a generic component that is used as a tool to perform the abstract idea without improving computers. Appeal 2021-002872 Application 12/718,556 12 Appellant argues that the claim includes other additional features that (1) actively monitor for and detect non-death-related events that affect a certificate(s), (2) convert input data for an affected certificate or a new certificate into a standard format that can be stored in a data table, (3) use the standardized data stored in the data table to determine a beneficial reallocation of a portion of a financial account for a group life insurance policy to the new certificate, and (4) automatically process one or more debits drawn against the financial account, and these additional elements apply the abstract idea in a meaningful way. Appeal Br. 8. Appellant asserts that the claimed system includes features that enable it to process input data received in any format automatically by transforming, parsing, formatting, and mapping it into a form that Manager Application 310 can interpret and automated programs may use to generate a data table with the information extracted or derived from communication data files. Id. at 8-9. These arguments are not commensurate with the scope of claim 1, which does not require input data for certificates to be converted into a standard format that is stored in a data table. See Ericsson Inc. v. TCL Commc’n Tech. Holdings Ltd., 955 F.3d 1317, 1325 (Fed. Cir. 2020) (“[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.”). Here, claim 1 receives input, generates a table from information derived from this data, and determines applicable rules based on data in the table without any technical details. Appeal 2021-002872 Application 12/718,556 13 Furthermore, these features are features of the abstract idea identified under Prong One and therefore cannot be additional elements. See Revised Guidance, 84 Fed. Reg. at 55 n.24 (“additional elements” are 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 does not monopolize the abstract idea). Even if we consider these limitations as additional elements, they do not improve computers or other technologies. “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.” Ericsson, 955 F.3d at 1328; SAP Am., Inc. v. InvestPic, LLC, 898 F.3d 1161, 1167-68 (Fed. Cir. 2018) (to avoid 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); Interval Licensing LLC v. AOL, Inc., 896 F.3d 1335, 1346 (Fed. Cir. 2016) (because content data update instructions that enable updating of displayed information are recited only at the broadest, functional level, without any explanation of how that is accomplished, let alone providing a technical means for performing that function, they are not directed to a technological improvement for performing those functions and consist only of generic and conventional information acquisition and organization steps that do not convert the abstract idea into a particular conception of how to carry out that concept); 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 2021-002872 Application 12/718,556 14 “Software can make non-abstract improvements to computer technology just as hardware improvements can, and . . . the improvements can be accomplished through either route.” Enfish, LLC v. Microsoft Corp., 822 F.3d 1327, 1335 (Fed. Cir. 2016). However, “to be directed to a patent- eligible improvement to computer functionality, the claims must be directed to an improvement to the functionality of the computer or network platform itself.” Customedia Techs., LLC v. Dish Network Corp., 951 F.3d 1359, 1365 (Fed. Cir. 2020) (citing Enfish, 822 F.3d at 1336-39). These limitations merely process data by steps that can be performed as mental steps when recited at this level of generality as in claim 1 without any technical implementation details to take them outside of the abstract realm. No technical implementation details are provided to indicate that these elements represent improvements to computers or other technology. Essentially, these steps can be performed by any and all means. Automation of manual processes does not improve computers. See Credit Acceptance Corp. v. Westlake Servs., 859 F.3d 1044, 1055 (Fed. Cir. 2017) (automation of manual processes using generic computers to supplant and enhance a manual process is not ineligible for patenting); NetSoc, LLC v. Match Grp., LLC, 838 F. App’x 544, 548 (Fed. Cir. 2020) (automatically establishing a conventional social network that allows humans to exchange information and form relationships involves a method of organizing human activity); see also 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.”); Cellspin Soft, Inc. v. Fitbit, Inc., 927 F.3d 1306, 1316 (Fed. Cir. 2019) (“But the need to perform tasks automatically is not a unique technical problem.”). Appeal 2021-002872 Application 12/718,556 15 Receiving input, generating a data table from the input, retrieving rules and determining their applicability can be performed as mental steps. See In re TLI Commc’ns LLC Patent Litig., 823 F.3d 607, 613 (Fed. Cir. 2016) (classifying and storing images in an organized manner based on classification data is a method of organizing human activity); Content Extraction & Transmission LLC v. Wells Fargo Bank, Nat’l Ass’n, 776 F.3d 1343, 1347 (Fed. Cir. 2014) (collecting data, recognizing and extracting data in the collection, and storing the recognized data in an organized manner are functions humans always have performed to organize and store data); see also Berkheimer v. HP Inc., 881 F.3d 1360, 1367 (Fed. Cir. 2018) (using a parser to determine and extract components of a document and reassemble the components into a composite output file is an abstract idea of storing and editing data where the parsing and comparing steps are similar to collecting and recognizing of Content Extraction and to classifying in an organized manner of TLI); Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d 1350, 1355 (Fed. Cir. 2016) (“[S]electing 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) (a person can obtain information about credit card transactions by reading records of transactions from a database, construct a map of credit card numbers by writing down a list of credit card transactions made from a particular IP address, and use the map to identify fraudulent transactions by observing if a transaction uses different credit cards with different user names and addresses all originating from the same IP address). Appeal 2021-002872 Application 12/718,556 16 Here, claim 1 recites steps to collect, extract, organize, and analyze data that encompass mental steps. For example, human resources and/or automated programs may generate a data table with information extracted or derived from communicated data files. Spec. 23:5-7. The system 100 may receive input from sponsor 106 via clients 302. Id. at 23:14-15. Speed or efficiency increases from generic computers is not enough. See Credit Acceptance, 859 F.3d at 1056-57 (using computers to perform routine tasks more quickly or more accurately is insufficient to make a claim patent eligible) (citations omitted); buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1354 (Fed. Cir. 2014) (using a computer to create electronic records, track multiple transactions, and automatically issue instructions is a form of “electronic recordkeeping” and using a computer to obtain data, adjust account balances, and automatically issue instructions does not improve the functioning of the computer itself); see also Customedia, 951 F.3d at 1364 (“‘[C]laiming the improved speed or efficiency inherent with applying the abstract idea on a computer’ [is] insufficient to render the claims patent eligible.” (citation omitted)); 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.”); Bancorp, 687 F.3d at 1279 (“[T]he claims merely employ computers to track, reconcile, and administer a life insurance policy with a stable value component-i.e., the computer simply performs more efficiently what could otherwise be accomplished manually.”; “[T]he computer merely permits one to manage a stable value protected life insurance policy more efficiently than one could mentally. Using a computer to accelerate an ineligible mental process does not make that process patent-eligible.”). Appeal 2021-002872 Application 12/718,556 17 We disagree that claim 1 of Example 42 of the 2019 Subject Matter Eligibility Examples is relevant to the claims here. See Appeal Br. 8-9. Claim 1 of Example 42 involved a method of medical record keeping that allowed different parties to input changes to medical records of a patient in any format and the system converted the records to a standardized format and then sent out notifications to all parties that an update had been received and posted. The claim involved more than simply converting data into a standard format. Indeed, University of Florida Research Foundation, Inc. v. General Elec. Co., 916 F.3d 1363, 1368 (Fed. Cir. 2019) held that claims to converting physiological data from a machine specific format to a machine independent format with a computer did not improve the functioning of the computer. See University of Florida, 916 F.3d at 1368 (“Neither the ’251 patent, nor its claims, explains how the drivers do the conversion that UFRF points to. That is, the drivers are described in purely functional terms: they ‘facilitate data exchanges,’ ‘convert received data streams to a format independent of any particular bedside machine,’ and ‘interpret [discrete] segments.’ . . . The mere function of converting is not a ‘specific improvement to the way computers operate.’”) (citation omitted); see also Adaptive Streaming Inc. v. Netflix, Inc., 836 F. App’x 900, 903 (Fed. Cir. 2020) (claims reciting a fundamental communication practice of translating content from a format of a sender to one suited to a recipient without any advance in coding or any other technique are not patent eligible). Accordingly, we determine that claim 1 lacks additional elements that are sufficient to integrate the abstract idea into a practical application. Appeal 2021-002872 Application 12/718,556 18 Alice, Step Two and Revised Guidance Step 2B: Do the Claims Include an Inventive Concept? We next consider whether claim 1 recites 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, 881 F.3d at 1367. Individually, the computing system performs conventional functions. It monitors events, receives data (input), generates data (a data table), determines a reallocation of financial accounts, retrieves data (rules), and determines which rules are applicable. As an ordered combination, the limitations recite no more than when they are considered individually. “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.” BSG Tech LLC v. Buyseasons, Inc., 899 F.3d 1281, 1290-91 (Fed. Cir. 2018); see 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); SAP, 898 F.3d at 1169-70 (claims to 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 2021-002872 Application 12/718,556 19 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.”). See 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, 839 F.3d at 1151 (“[A] claim for a new abstract idea is still an abstract idea.”). “It has been clear since Alice that a claimed invention’s use of the ineligible concept to which it is directed cannot supply the inventive concept that renders the invention ‘significantly more’ than that ineligible concept.” BSG, 899 F.3d at 1290. “As a matter of law, narrowing or reformulating an abstract idea does not add ‘significantly more’ to it.” Id. at 1291; see also Berkheimer, 881 F.3d at 1370 (claims to performing the abstract idea of parsing and comparing data with conventional computer components lacked an inventive concept); Inventor Holdings, LLC v. Bed Bath & Beyond, Inc., 876 F.3d 1372, 1378 (Fed. Cir. 2017) (sequence of data retrieval, analysis, modification, generation, display and transmission is not inventive and amounts to instructions to apply the abstract idea using generic computer technology); buySAFE, 765 F.3d at 1355 (“That a computer receives and sends the information over a network-with no further specification-is not even arguably inventive.”). Accordingly, we sustain the rejection of claims 1-4 and 6-25 as directed to an abstract idea without significantly more. Appeal 2021-002872 Application 12/718,556 20 DECISION In summary: Claim(s) Rejected 35 U.S.C. § References/Basis Affirmed Reversed 1-4, 6-25 101 Eligibility 1-4, 6-25 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