Ex Parte Sankolli et al

Patent Trial and Appeal BoardSep 14, 2018

12842927 (P.T.A.B. Sep. 14, 2018)

UNITED STA TES p A TENT AND TRADEMARK OFFICE APPLICATION NO. FILING DATE FIRST NAMED INVENTOR 12/842,927 07/23/2010 San jay Dattatreya Sankolli 66945 7590 09/18/2018 KILPATRICK TOWNSEND & STOCKTONLLP/VISA Mailstop: IP Docketing - 22 1100 Peachtree Street Suite 2800 Atlanta, GA 30309 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 ATTORNEY DOCKET NO. CONFIRMATION NO. 79900-787629 (064910US) 5052 EXAMINER BRANDENBURG, WILLIAM A ART UNIT PAPER NUMBER 3681 NOTIFICATION DATE DELIVERY MODE 09/18/2018 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): ipefiling@kilpatricktownsend.com KTSDocketing2@kilpatrick.foundationip.com PTOL-90A (Rev. 04/07) UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE PATENT TRIAL AND APPEAL BOARD Ex parte SANJAY DATTATREYA SANKOLLI and IGOR KARPENKO Appeal2016-007100 Application 12/842,927 Technology Center 3600 Before BRADLEY W. BAUMEISTER, MICHAEL M. BARRY, and AARON W. MOORE, Administrative Patent Judges. BARRY, Administrative Patent Judge. DECISION ON APPEAL Appellants 1 appeal under 35 U.S.C. Â§ 134(a) from a Final Rejection of claims 21, 23-30, 32-34, 36-43, and 45-50, which are all the pending claims. We have jurisdiction under 35 U.S.C. Â§ 6(b). We AFFIRM. 1 Appellants identify Visa International Service Association as the real party in interest. App. Br. 3. Appeal2016-007100 Application 12/842,927 Introduction Appellants describe embodiments of their invention as addressing problems related to credit and debit card usage. Spec. ,r,r 2-5. A mobile payment service uses a server for "generating a unique one-time-use identifier" that is sent to a mobile device user "as an electronic coupon" for use in completing a transaction. Abstract. Claim 21 is illustrative of the claims on appeal: 21. A method comprising: receiving, at a server computer, information related to a user and an associated user account identifier associated with a user account; receiving, at the server computer, a request for an electronic coupon, wherein the request includes user account information and one or more user-specified parameters for the electronic coupon; storing, in a database of users, the one or more user- specified parameters, wherein the one or more user-specified parameters are pre-defined by the user; determining, by the server computer, one or more global parameters, wherein the one or more global parameters are determined by a service provider, an issuer, or a payment processing network; generating, by the server computer, the electronic coupon containing a one-time-use identifier, wherein generating the electronic coupon is based on the one or more user-specified parameters and the one or more global parameters; sending, from the server computer, the electronic coupon to a mobile device, thereby enabling the mobile device to conduct one or more transactions using the electronic coupon[;] receiving, at the server computer, an authorization request message that contains the one-time-use identifier during a transaction from a merchant; 2 Appeal2016-007100 Application 12/842,927 accessing and searching, by the server computer, the database of users; identifying the one or more user-specified parameters associated with the electronic coupon through the one-time-use identifier stored in the database of users; determining, by the server computer, the one or more global parameters associated with the electronic coupon; comparing, by the server computer, transaction information in the authorization request message with the one or more user-specified parameters and the one or more global parameters; validating, by the server computer, the transaction when the transaction does not violate any of the one or more user- specified parameters or the one or more global parameters upon comparison; substituting, by the server computer, the one-time-use identifier with the associated user account identifier in the authorization request message; transmitting, from the server computer, the authorization request message comprising the user account identifier to an issuer of the user account, the issuer being separate and distinct from the server computer, wherein the issuer authorizes the transaction and generates a response message comprising an indication that the transaction has been authorized; receiving the response message comprising the indication from the issuer; substituting, by the server computer, the one-time-use identifier for the user's user account identifier in the response message; transmitting, from the server computer, the response message with the one-time-use identifier to the merchant; and performing, by the server computer, a settlement process for the transaction after transmitting the response message to the merchant. App. Br. 34--35 (Claims App'x). 3 Appeal2016-007100 Application 12/842,927 Re} ections and References Claims 21, 23-30, 32-34, 36-43, and 45-50 stand rejected under 35 U.S.C. Â§ 101 as directed to a judicial exception (i.e., an abstract idea) without reciting significantly more. Final Act. 3-6. Claims 21, 23-30, 32-34, 36-43, and 45-50 stand rejected under pre- AIA 35 U.S.C. Â§ I02(e) as anticipated by Wong (US 2010/0138344 Al; June 3, 2010). Final Act. 7-37. ANALYSIS TheÂ§ 1 OJ Rejection We use a two-step framework for determining whether claimed subject matter is judicially excepted from patent eligibility under 35 U.S.C. Â§ 101. In the first step, we "determine whether the claims at issue are directed to a patent-ineligible concept." Alice Corp. Pty. Ltd. v. CLS Bank International, 134 S. Ct. 2347, 2355 (2014). If so, then in the second step, we "consider the elements of each claim both individually and 'as an ordered combination' to determine whether the additional elements 'transform the nature of the claim' into a patent-eligible application." Id. at 2355 (quoting Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66, 78-79 (2012)). In considering whether a claim is directed to an abstract idea, we keep in mind that "all inventions at some level embody, use, reflect, rest upon, or apply laws of nature, natural phenomena, or abstract ideas." Mayo, 566 U.S. at 71. Accordingly, we look to whether the claim focuses on a specific means or method that improves the relevant technology or is instead directed to a result or effect that itself is the abstract idea and otherwise merely 4 Appeal2016-007100 Application 12/842,927 invokes generic processes and machinery. See Enfish, LLC v. Microsoft Corp., 822 F.3d 1327, 1336 (Fed. Cir. 2016). We note the two steps of the Alice analysis "involve overlapping scrutiny of the content of the claims," and the Federal Circuit has described "the first-stage inquiry" as "looking at the 'focus' of the claims, their 'character as a whole,"' and "the second-stage inquiry (where reached)" as "looking more precisely at what the claim elements add-specifically, whether, in the Supreme Court's terms, they identify an 'inventive concept' in the application of the ineligible matter to which (by assumption at stage two) the claim is directed." Electric Power Grp., LLC v. Alstom S.A., 830 F.3d 1350, 1353 (Fed. Cir. 2016) (citations omitted). The following analysis under the Alice framework first addresses independent claim 21, which Appellants argue together with independent claim 34. See App. Br. 10-22. We then address dependent claims 29, 32, 33, 42, 45, and 46, which Appellants separately argue. See id. at 22-24. Step One The Examiner determines the focus of the claims is "directed to transaction authorization and settlement processing, which is considered to be an abstract idea inasmuch as such activity is considered a fundamental economic practice." Final Act. 3. Appellants argue the Examiner errs, contending the Examiner's identified idea "is a gross mischaracterization of the subject matter recited" because "each independent claim recites 18 steps directed to the generation and the use of an electronic coupon containing a one-time-use identifier based on user-specified parameters and global parameters for transaction(s)." App. Br. 12. Appellants' argument is unpersuasive. 5 Appeal2016-007100 Application 12/842,927 In step one, we determine the claims are directed to transaction authorization and settlement processing for transactions that use coupons, which constitutes an abstract idea because it is a fundamental economic practice. Although we agree with Appellants insofar as the Examiner wrongly omits the idea of using coupons from the identified idea to which the claims are directed, the Examiner's omission of this from the identified idea is a harmless error. The idea of using coupons as part of a transaction is an old, well-known, and a fundamental economic practice. "Adding one abstract idea ... to another abstract idea ... does not render the claim non- abstract. "). See RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327 (Fed. Cir. 2017); see also FairWarning IP, LLC v. Iatric Sys., Inc., 839 F.3d 1089, 1093-94 (Fed. Cir. 2016) (patent-ineligible claims were directed to a combination of abstract ideas). We also note that in response to Appellants' arguments, the Examiner specifically identifies that using coupons as part of transactions is an old idea. Ans. 10 (finding the coupon-related claim limitations directed to the same idea as using paper coupons, i.e., a "pre- computer business practice"). Appellants further argue the claims "address problems that arise in the use of mobile devices ( e.g. computers), and thus are not directed to an abstract idea, in a similar manner as DDR Holdings, LLC v. Hotels.com, L.P., [773 F.3d 1245] (Fed. Cir. 2014)." App. Br. 13. "Similar to DDR, embodiments of the invention solve technical problems rooted in computer technology." App. Br. 14. We disagree with Appellants. The recitation of a mobile device does not mean that the recited mobile device is a necessary component of the idea to which the claims are directed. Bilski v. Kappas, 561 U.S. 593, 612 (2010) 6 Appeal2016-007100 Application 12/842,927 ( explaining that "limiting an abstract idea to one field of use ... does not make the concept patentable"). Here, Appellants' Specification describes that the invention addresses problems with security- and budget-type issues that may or may not implicate any particular technology. See Spec. ,r,r 2-5. Although Appellants state that "[ w ]ith the advent of new technology, also comes the demand for increased security for payment transactions" (i-f 3), this general statement does not describe a technical problem "rooted in computer technology" akin to DDR. Furthermore, Appellants' claims are not similar to those at issue in DDR, in which the claims "recite[ d] a specific way to automate the creation of a composite web page by an 'outsource provider' that incorporates elements from multiple sources in order to solve a problem faced by websites on the Internet." 773 F.3d at 1259. The DDR claims were not ineligibly directed to an abstract idea because they were directed to "an inventive concept for resolving this particular Internet-centric problem." Id. Here, while the limitations of Appellants' claims recite the use of computer technology, the problems or issues addressed by the claims do not address a particular computer-centric problem. Instead, they address security- and budget-type issues. Those issues are not Internet-centric or focused on any particular computer technology. The mobile device and computer-related limitations of Appellants' claims are appropriately considered in step two of the Alice analysis. Appellants further argue "the claims are not directed to a fundamental practice" because they "recite a specific way to generate and send an electronic coupon to a mobile device, thereby enabling the mobile device to conduct transactions using the electronic coupon." App. Br. 15; see also id. 7 Appeal2016-007100 Application 12/842,927 at 16 ( contending that "' generating ... the electronic coupon containing a one-time-use identifier ... based on ... user-specified parameters and ... global parameters' is neither 'long-prevalent' nor 'fundamental"'). As the Examiner responds by finding, however, and we agree, "most certainly the traditional implementation of paper coupons, [] which were used to complete transactions and were associated with various parameters controlling the use and validation thereof, is evidence of a 'pre-computer business practice directly analogous to generating an electronic coupon ... ' contrary to Appellant's assertions." Ans. 10. In reply, Appellants contend the recited electronic coupon is unlike "a conventional paper coupon ( similar to those provided in newspapers) merely provided in an electronic format" because "the electronic coupon includes an identifier that replaces the user's actual account identifier (e.g. account number)." Reply Br. 7. This argument is unpersuasive. Newspaper coupons are not the only type of conventional paper coupons. Sending targeted coupons directly to individuals by mail at individual addresses is another longstanding marketing or advertising practice. Similar marketing or advertising practices have been determined to be directed to abstract ideas. See, e.g., Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709, 714--17 (Fed. Cir. 2014). We have considered all of Appellants' arguments challenging the characterization of their claims as being directed to abstract ideas, see App. Br. 12-16; Reply Br. 2-7, but we do not find them to be persuasive of error. Rather, we agree with the Examiner, at step one of the Alice analysis, that the claims are directed to one or more abstract ideas. Accordingly, we tum to the second step of the Alice analysis, in which we determine whether the 8 Appeal2016-007100 Application 12/842,927 additional elements of the claims transform them into patent-eligible subject matter. Step Two The question in step two is not whether an additional computer- implemented feature is novel, but whether its implementation of the abstract idea "involve[s] more than the performance of 'well-understood, routine, [and] conventional activities previously known to the industry.'" Content Extraction and Transmission LLC v. Wells Fargo Bank, Nat. Ass 'n, 776 F.3d 1343, 1347--48 (quoting Alice, 134 S. Ct. at 2359) (second set of brackets in original). In applying step two of the Alice analysis, we must "determine whether the claims do significantly more than simply describe [an] abstract method" and thus transform the abstract idea into patentable subject matter. ... We look to see whether there are any "additional features" in the claims that constitute an "inventive concept," thereby rendering the claims eligible for patenting even if they are directed to an abstract idea .... Those "additional features" must be more than "well- understood, routine, conventional activity." Intellectual Ventures I LLC v. Erie Indemnity Company, 850 F.3d 1315, 1328 (Fed. Cir. 2017) (internal citations omitted). Appellants argue claims 21 and 34 recite significantly more than an abstract idea due to many features, including reciting [ 1] receiving a request for an electronic coupon including user-specified parameters, [2] determining global parameters, [3] generating the electronic coupon including a one-time-use identifier, [ 4] sending the electronic coupon to a mobile device, [5] receiving an authorization request message containing the one-time-use identifier, [ 6] comparing transaction information in the authorization request message with the one or more user-specified parameters 9 Appeal2016-007100 Application 12/842,927 and the one or more global parameters, and [7] validating the transaction when the transaction does not violate any of the one or more user-specified parameters or the one or more global parameters upon comparison. Thus, the claims clearly apply any alleged abstract idea in a very meaningful way through these significant recited features, and thus in no way are able to "monopolize" the general ability of others to perform transaction authorization and settlement processing. App. Br. 16-17 (bracketed numbers added); see also id. at 18-21. Appellants' argument is unpersuasive that the Examiner errs in finding these features do not amount to an "improvement to the machine itself or to an[o]ther technology/technical field." Ans. 15 (emphasis omitted). We instead agree with the Examiner that these features are directed to the abstract idea itself. Id. For example, "receiving a request for an electronic coupon including user-specified parameters" and "determining global parameters" are analogous to claim limitations at issue in CyberSource Corp. v. Retail Decisions, Inc., where steps for obtaining, analyzing, and then using transaction-specific credit card numbers were determined to constitute "obtain[ing] and compar[ing] intangible data" that did not save the patent-eligibility of an otherwise abstract claim. 654 F.3d 1366, 1370 (Fed. Cir. 2011). The step of "generating the electronic coupon including a one-time-use identifier" only adds "electronic" to the idea of a single-use paper coupon. Nothing about making the coupon "electronic" and reciting "a one-time-use identifier" adds significantly more than the underlying abstract idea. See Alice, 134 S. Ct. at 2358. The step of "sending ... the electronic coupon to a mobile device" is analogous to the abstract idea of sending targeted coupons in the mail, and merely limits the step to a particular field of use with mobile devices, which is an insignificant limitation, i.e., not significantly more. Bilski, 561 U.S. at 10 Appeal2016-007100 Application 12/842,927 612 ("limiting an abstract idea to one field of use or adding token postsolution components [does] not make the concept patentable"). Because the "one-time-use identifier" does not add anything significant to the idea of a targeted coupon, the claim limitation "receiving an authorization request message containing the one-time-use identifier" does not add anything significant to the idea of transaction authorization. Finally, similar to the receiving and determining steps, discussed supra, "comparing transaction information in the authorization request message with the one or more user-specified parameters and the one or more global parameters" does not add significantly more. This limitation amounts to comparing intangible data, which repeatedly has been found not to constitute "significantly more," because such comparing is itself an abstract idea. Cybersource, 654 F.3d at 1370; see also Blue Spike, LLC v. Google Inc., No. 14-CV-01650-YGR, 2015 WL 5260506 *5 (N.D. Cal. 2015), ajf'd, No. 2016-1054, 2016 WL 5956746 (mem) (Fed. Cir. 2016) (clarifying that "comparing one thing to another" is an abstract idea). Thus, each of the argued claim limitations does not add significantly more to the abstract idea of transaction authorization and settlement processing for transactions that use coupons. Also, taken as a whole, the combination of limitations in claim 21 does not "transform" the claimed subject matter into a patent-eligible application of the underlying idea(s). Claim 21 is akin to the claim at issue in Ultramercial, where detailed recitations in eleven steps of a method directed to distributing information over the Internet in exchange for viewing of advertisements "add[ ed] nothing of practical significance to the underlying abstract idea." 772 F.3d at 716. It is instructive that the underlying business method of claim 21 is 11 Appeal2016-007100 Application 12/842,927 tied only to generic hardware components and does not recite any limitations that transform any article. Ultramercial, 772 F.3d at 716-17. Accordingly, because claim 21 recites only limitations relating to the abstract idea of using coupons for transaction authorization and settlement, and because the limitations additionally recite only conventional computer functions, Appellants do not persuade us the Examiner errs in determining claim 21 does not recite significantly more than the identified abstract idea. Finally, Appellants argue that claim 21 is patent-eligible because the "recited claim elements do not 'tie' up the entire alleged abstract idea of a 'transaction authorization and settlement processing" and "it is instantly recognizable that there are a multitude of ways to perform transaction authorization and settlement processing that can occur without utilizing that which is recited." App. Br. 22. This argument is unpersuasive. To be sure, the Supreme Court has described "the concern that drives [the exclusion of abstract ideas from patent eligible subject matter] as one of pre-emption." See Alice, 134 S. Ct. at 2354. However, characterizing preemption as a driving concern for patent eligibility is not the same as characterizing preemption as the test for patent eligibility. As our reviewing court has explained: "The Supreme Court has made clear that the principle of preemption is the basis for the judicial exceptions to patentability" and "[f]or this reason, questions on preemption are inherent in and resolved by theÂ§ 101 analysis." Ariosa Diagnostics, Inc. v. Sequenom, Inc., 788 F.3d 1371, 1379 (Fed. Cir. 2015) (citing Alice, 134 S. Ct. at 2354). Thus, although "preemption may signal patent ineligible subject matter, the absence of complete preemption does not demonstrate patent eligibility." Id. 12 Appeal2016-007100 Application 12/842,927 Accordingly, having considered all of Appellants' Â§ 101 arguments for claims 21 and 34, see App. Br. 10-22; Reply Br. 2-7, we are unpersuaded of Examiner error, and we sustain theÂ§ 101 rejection of claims 21 and 34. Dependent Claims Appellants argue that dependent claims 29 and 42, which recite "wherein the one or more user-specified parameters include a personal identification number (PIN) to be utilized to complete the transaction," "are especially patentable under Section 101" because "requiring the PIN to be utilized to complete the transaction provides an added level of security when conducting a transaction with the electronic coupon." App. Br. 22, 23 ( explaining why "the primary account number of the user will be protected from the fraudsters"). This argument is unpersuasive. We agree with the Examiner this limitation is "directed to the abstract idea or business method itself." Ans. 16 ( emphasis omitted). We also agree with the Examiner that it does not amount to significantly more because, vis-a-vis the parent claim, discussed supra, the limitation "is not one resulting from programming a generic processor to perform a different ( or even improved) function." Ans. 17 ( emphasis omitted). Appellants argue that dependent claims 32 and 45, which recite "wherein the authorization request message comprises an indicator which identifies the transaction as an electronic coupon transaction," "are especially patentable under Section 101" because when an indicator is included in the authorization request message sent to the issuer to identify the transaction as an alternate mobile payment service transaction ( e.g., barcode) through a service provider, the issuer knows how to process the 13 Appeal2016-007100 Application 12/842,927 transaction request message. Accordingly, when the authorization message is received, the payment processing network can handle the transaction more efficiently. App. Br. 23, 24. This argument is unpersuasive. The recited authorization request message is for a transaction that, as required by the parent independent claim, involves an electronic coupon. In other words, these dependent claims are directed to the idea of indicating that a transaction involving an electronic coupon is a transaction involving an electronic coupon-we agree with the Examiner that this does not add significantly more. Ans. 16-17. We also agree with the Examiner that Appellants' argument is not commensurate with the scope of claims 32 and 45. Id. at 17. Appellants also argue that dependent claims 33 and 46, which recite "transmitting an advice message to the issuer of the user account indicating a transaction initialization process," "are especially patentable under Section 101" because the advice message "allows for issuer to know about the future use of the electronic coupon for payment and may allow the issuer to place a temporary hold onto the user's account for the amount of electronic coupon value, similar to how it is done for credit authorizations." App. Br. 24. Appellants contend these claims amount to significantly more than an abstract idea because "this is clearly a 'meaningful limitation beyond linking the use of the judicial exception to a particular technological environment,' an 'unconventional step,' and an 'improvement' to existing systems that could generate electronic coupons." Id. This argument is also unpersuasive. These dependent claims essentially recite the idea of advising a party to the transaction about the transaction. Thus, the "advice message to the issuer ... indicating a 14 Appeal2016-007100 Application 12/842,927 transaction initialization process" essentially recites nothing significantly more than an abstract idea. Further, as with claims 32 and 45, we agree with the Examiner that Appellants' argument is not commensurate with the scope of these claims. Ans. 17. Thus, Appellants do not persuade us the Examiner errs in determining these claims do not recite significantly more than an abstract idea. Accordingly, we sustain the Examiner'sÂ§ 101 rejection of claims 29, 32, 33, 42, 45, and 46, and also of claims 23-30, 36-41, 43, and 47-50, for which Appellants offer no separate arguments. The Â§ 102 Rejections In rejecting claims 21 and 34 as anticipated, the Examiner finds Wong discloses "substituting, by the server computer, the one-time-use identifier with the associated user account identifier in the authorization request message" and "transmitting, from the server computer, the authorization request message comprising the user account identifier to an issuer of the user account, the issuer being separate and distinct from the server computer" as recited. Final Act. 15-19 (citing Wong ,r,r 5-10, 20-29, 32- 33, 43; Figs. 2A-B, 3B, 4). Appellants argue the Examiner errs because Wong is silent with regard to these limitations and does not inherently disclose them. App. Br. 25-29. With regard to inherency, Appellants specifically contend the processing system embodiment discussed in Wong-PayPal-has no need to perform these limitations. App. Br. 27-29. Anticipation is a strict standard that requires finding each and every element as set forth in the claim, either expressly or inherently, in a single prior art reference, arranged as required by the claim. Verdegaal Bros., Inc. 15 Appeal2016-007100 Application 12/842,927 v. Union Oil. Co. of Cal., 814 F.2d 628,631 (Fed. Cir. 1987). The fact that a certain result or characteristic may occur or be present in the prior art is not sufficient to establish the inherency of that result or characteristic. In re Rijckaert, 9 F.3d 1531, 1534 (Fed. Cir. 1993); see also In re Oelrich, 666 F.2d 578, 581-82 (CCPA 1981). To rely upon the theory of inherency, the Examiner must provide a basis in fact and/ or technical reasoning to reasonably support the determination that the allegedly inherent characteristic necessarily flows from the teachings of the applied prior art. In re King, 801 F.2d 1324, 1327 (Fed. Cir. 1986); Ex parte Levy, 17 USPQ2d 1461, 1464 (BP AI 1990). Here, the Examiner presumes PayPal would have operated in a particular way- [T]he Examiner understands that in order for the user's "issuer" account to fund their payment provider account and even know what account should be funded, the previously used one-time- identifier used on the [point of sale (POS)] side would be substituted in the authorization request with the user's actual account information, thus allowing for proper account reconciliation and transfer of funds. This is fully supported by the disclosure of at least [0027-28], in which the barcode is used during the transaction and a determination is made as to whether the transfer will be funded by the payment provider. Ans. 20-21. Appellants reply that "[t]he Examiner appears to draw conclusions based on his knowledge of how PayPal generally works today. However, in the context of Wong, the barcode is considered with respect to funds that are stored on a user's PayPal account." Reply Br. 9 (explaining "[t]his is clearly supported by the paragraph [0025] cited by the Examiner[,] which provides that ' [ t ]he barcode may allow access to all the funds in a user's account, only 16 Appeal2016-007100 Application 12/842,927 a portion set aside by the user, or be restricted to certain merchants or products/services'"). Appellants' argument is persuasive. Wong discusses that PayPal is an exemplary payment provider that performs payment processing and accesses the user's account to handle payments directly with a merchant, without any reference to a separate and distinct issuer, as recited. See Wong ,r,r 20-29. The limitations in claims 21 and 34 for transmitting an authorization request message to the separate and distinct issuer, where the request message includes a user account identifier that has been substituted for the one-time-use identifier, is unnecessary for the embodiments discussed in Wong. Thus, we agree with Appellants that the Examiner errs in finding Wong inherently discloses these limitations, as recited in claims 21 and 34. Accordingly, we do not sustain theÂ§ 102 anticipation rejection of claims 21 and 34. We, likewise, do not sustain the Â§ 102 rejection of dependent claims 23-30, 32, 33, 36-43, and 45-50. DECISION We affirm the 35 U.S.C. Â§ 101 rejection and reverse theÂ§ 102(e) rejection of claims 21, 23-30, 32-34, 36-43, and 45-50. Because we affirm the Â§ 101 rejection of all pending claims, we designate our decision as an affirmance. No time period for taking any subsequent action in connection with this appeal may be extended under 37 C.F.R. Â§ 1.136(a)(l )(iv). AFFIRMED 17