Ex Parte Siauw et al

Patent Trials and Appeals BoardMar 27, 2019

13460127 - (D) (P.T.A.B. Mar. 27, 2019)

UNITED STA TES p A TENT AND TRADEMARK OFFICE APPLICATION NO. FILING DATE 13/460, 127 04/30/2012 51206 7590 03/29/2019 Kilpatrick Townsend & Stockton LLP/Oracle Mailstop: IP Docketing - 22 1100 Peachtree Street Suite 2800 Atlanta, GA 30309 FIRST NAMED INVENTOR Djiao Mei Siauw 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. 88325-826624 (l 14000US) 4249 EXAMINER CRAWLEY, TALIAF ART UNIT PAPER NUMBER 3687 NOTIFICATION DATE DELIVERY MODE 03/29/2019 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 oraclepatentmail@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 DJIAO MEI SIAUW, ROBERT ZWIEBACH, and NEIL RAMSAY Appeal2017-010663 Application 13/460,127 Technology Center 3600 Before JOSEPH A. FISCHETTI, AMEE A. SHAH, and MATTHEWS. MEYERS, Administrative Patent Judges. SHAH, Administrative Patent Judge. DECISION ON APPEAL 1 The Appellants2 appeal under 35 U.S.C. Â§ 134(a) from the Examiner's decision rejecting claims 1-20 under 35 U.S.C. Â§ 101 as being directed to a judicial exception without significantly more. We have jurisdiction under 35 U.S.C. Â§ 6(b). We AFFIRM. 1 Throughout this Decision, we refer to the Appellants' Appeal Brief ("Appeal Br.," filed Nov. 11, 2016), Reply Brief ("Reply Br.," filed Aug. 15, 2017), and Specification ("Spec.," filed Apr. 30, 2012), and to the Examiner's Answer ("Ans.," mailed June 15, 2017) and Non-Final Office Action ("Non-Final Act.," mailed Mar. 11, 2016). 2 According to the Appellants, the real party in interest is Oracle International Corporation. Appeal Br. 3. Appeal2017-010663 Application 13/460, 127 STATEMENT OF THE CASE The Appellants' invention relates generally to "previewing projected balance impacts in an Enterprise Financial Accounting System" (Spec. ,r 4) and more specifically to "validating and/or previewing account journal entries in an Enterprise Financial Accounting System" (id. ,r 31 ). Claims 1, 12, and 1 7 are the independent claims on appeal. Claim 1 (Appeal Br. 11 (Claims App.)) is illustrative of the subject matter on appeal and is reproduced below (with added bracketing for reference): 1. A method of previewing projected balance impacts in an Enterprise Financial Accounting System, the method compnsmg: [(a)] receiving, by a computer system, one or more journal entries that have not been posted to an accounting ledger; [ (b)] displaying, by the computer system, the one or more journal entries in a journal portlet; [ ( c)] receiving, by a computer system, a selection of a first journal entry from the one or more journal entries, wherein the first journal entry comprises a first amount; [ ( d)] selecting, by a computer system, from among a plurality of ledgers in the Enterprise Financial Accounting System, a first ledger that is associated with the first amount; [ ( e)] receiving a start date; [(f)] receiving a beginning balance representing a balance of the first ledger on the start date; [(g)] receiving an activity total comprising a sum of journal entries posted to the first ledger between the start date and a current date; [(h)] determining, by a computer system, a projected balance representing a combination of the beginning balance, the activity total, and the first amount; and 2 Appeal2017-010663 Application 13/460, 127 [(i)] displaying, by a computer system, a projected balances portlet together with the journal portlet, wherein the projected balances portlet comprises: the beginning balance; the activity total; the first amount; and the projected balance. ANALYSIS An invention is patent-eligible if it claims a "new and useful process, machine, manufacture, or composition of matter." 35 U.S.C. Â§ 101. However, the Supreme Court has long interpreted 35 U.S.C. Â§ 101 to include implicit exceptions: "[l]aws of nature, natural phenomena, and abstract ideas" are not patentable. E.g., Alice Corp. v. CLS Bank Int 'l, 573 U.S. 208, 216 (2014). In determining whether a claim falls within an excluded category, we are guided by the Supreme Court's two-step framework, described in Mayo and Alice. Id. at 217-18 ( citing Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66, 75-77 (2012)). In accordance with that framework, we first determine what concept the claim is "directed to." See Alice, 573 U.S. at 219 ("On their face, the claims before us are drawn to the concept of intermediated settlement, i.e., the use of a third party to mitigate settlement risk."); see also Bilski v. Kappas, 561 U.S. 593, 611 (2010) ("Claims 1 and 4 in petitioners' application explain the basic concept of hedging, or protecting against risk."). Concepts determined to be abstract ideas, and thus patent ineligible, include certain methods of organizing human activity, such as fundamental economic practices (Alice, 573 U.S. at 219-20; Bilski, 561 U.S. at 611 ); 3 Appeal2017-010663 Application 13/460, 127 mathematical formulas (Parker v. Flook, 437 U.S. 584, 594--95 (1978)); and mental processes (Gottschalkv. Benson, 409 U.S. 63, 69 (1972)). Concepts determined to be patent eligible include physical and chemical processes, such as "molding rubber products" (Diamond v. Diehr, 450 U.S. 175, 191 ( 1981) ); "tanning, dyeing, making water-proof cloth, vulcanizing India rubber, smelting ores" (id. at 182 n.7 (quoting Corning v. Burden, 56 U.S. 252, 267---68 (1854))); and manufacturing flour (Benson, 409 U.S. at 69 (citing Cochrane v. Deener, 94 U.S. 780, 785 (1876))). In Diehr, the claim at issue recited a mathematical formula, but the Supreme Court held that "a claim drawn to subject matter otherwise statutory does not become nonstatutory simply because it uses a mathematical formula." Diehr, 450 U.S. at 187; see also id. at 191 ("We view respondents' claims as nothing more than a process for molding rubber products and not as an attempt to patent a mathematical formula."). Having said that, the Supreme Court also indicated that a claim "seeking patent protection for that formula in the abstract ... is not accorded the protection of our patent laws, ... and this principle cannot be circumvented by attempting to limit the use of the formula to a particular technological environment." Id. ( citing Benson and Flook); see, e.g., id. at 187 ("It is now commonplace that an application of a law of nature or mathematical formula to a known structure or process may well be deserving of patent protection."). If the claim is "directed to" an abstract idea, we tum to the second step of the Alice and Mayo framework, where "we must examine the elements of the claim to determine whether it contains an 'inventive concept' sufficient to 'transform' the claimed abstract idea into a patent- 4 Appeal2017-010663 Application 13/460, 127 eligible application." Alice, 573 U.S. at 221 (quotation marks omitted). "A claim that recites an abstract idea must include 'additional features' to ensure 'that the [claim] is more than a drafting effort designed to monopolize the [abstract idea]."' Id. (quoting Mayo, 566 U.S. at 77). "[M]erely requir[ing] generic computer implementation[] fail[ s] to transform that abstract idea into a patent-eligible invention." Id. The PTO recently published revised guidance on the application of Â§ 101. 2019 REVISED PATENT SUBJECT MATTER ELIGIBILITY GUIDANCE, 84 Fed. Reg. 50 (Jan. 7, 2019) ("2019 Revised Guidance"). Under the 2019 Revised Guidance, we first look to whether the claim recites: (1) any judicial exceptions, including certain groupings of abstract ideas (i.e., mathematical concepts, certain methods of organizing human activity such as a fundamental economic practice, or mental processes); and (2) additional elements that integrate the judicial exception into a practical application (see MPEP Â§ 2106.05(a}-(c), (e}-(h)). Only if a claim (1) recites a judicial exception and (2) does not integrate that exception into a practical application, do we then look to whether the claim: (3) adds a specific limitation beyond the judicial exception that is not "well-understood, routine, conventional" in the field (see MPEP Â§ 2106.05(d)); or (4) simply appends well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception. See 2019 Revised Guidance. Step One of the Mayo/Alice Framework Under the first step of the Mayol Alice framework and Step 2A, Prong 1 of the 2019 Revised Guidelines, 84 Fed. Reg. at 54, the Examiner determines that the claims are "directed to methods and systems for 5 Appeal2017-010663 Application 13/460, 127 previewing projected balance impacts in an enterprise financial accounting system wherein the method may include receiving one or more journal entries that have not been posted to an accounting ledger and displaying one or more journal entries in a journal portlet" (Non-Final Act. 4) and cites to judicial decisions as support that this falls into the category of "an idea of itself' (based on previous guidelines) of collecting, transmitting, and processing data and is, thus, an abstract idea. Id. at 5; Ans. 4---6. The Appellants contend that the Examiner's determination is in error because the Examiner "( 1) defin[ es] the idea to which the claims are directed too broadly, and (2) fail[s] to identify similar claims previously found to be abstract." Appeal Br. 5. Specifically, the Appellants argue that "the claims are not directed to just projected balance preview, but specifically to a particular user interface (UI) that includes two different UI elements: a 'journal portlet' and a 'projected balances portlet."' Id. The Appellants further argue that instead of a "general comparison" of the claims to previous decisions, the Examiner "has to produce similar claims directed to splitting a projected balance analysis between two different UI portlets that federal courts have previously found to be abstract," and the Appellants are "unaware of any current or previous cases involving splitting a projected balance analysis between two different UI portlets that were found to be abstract." Id. at 6; see also Reply Br. 2. An examination of the claims shows that independent claim 1 recites "[a] method of previewing projected balance impacts in an Enterprise Financial Accounting System ["EFAS"], the method comprising:" (a) a computer system receiving data of "one or more journal entries that have not been posted to an accounting ledger"; (b) a computer system 6 Appeal2017-010663 Application 13/460, 127 displaying "the one or more journal entries in a journal portlet"; ( c) a computer system receiving a selection of a first journal entry that comprises a first amount; ( d) a computer system selecting, "from among a plurality of ledgers in the [EFAS], a first ledger that is associated with the first amount"; ( e) receiving data of a start date; (f) receiving data of "a beginning balance representing a balance of the first ledger on the start date"; (g) receiving data of "an activity total comprising a sum of journal entries posted to the first ledger between the start date and a current date"; (h) by a computer system determining "a projected balance representing a combination of the beginning balance, the activity total, and the first amount"; and (i) a computer system displaying "a projected balances portlet together with the journal portlet, wherein the projected balances portlet comprises:" data of the beginning and projected balances, activity total, and the first amount. See Appeal Br. 11 (Claims. App). Independent claim 12 recites an apparatus of a medium with instructions to cause one or more processors to "preview projected balance impacts in an [EAFS] by:" performing the steps as recited in method claim 1. Id. at 14. Independent claim 17 similarly recites an apparatus of a system comprising one or more processors and a memory with instructions to cause one or more processors to "preview projected balance impacts in an [EAFS] by:" performing the steps as recited in method claim 1. Id. at 16. The computer system( s) that performs the steps can include one or more general purpose computing systems comprising central processing units, input devices ( such as a mouse or keyboard), output devices ( such as a display device or printer), storage device(s), storage media reader, communications system, and working memory. Spec. ,r,r 43--44; see also id. 7 Appeal2017-010663 Application 13/460, 127 ,r,r 37--42. "[T]he journal entry and preview interface may be provided on a computer screen, while other embodiments may use the screen on a mobile phone, a laptop computer, a projector, a tablet computer, a PDA, and/or the like." Id. ,r 35. No specific definitions for the journal and projected balances portlets are provided in the Specification. However, the Specification does provide that "[t]he journal portlet may be a window within the journal entry and preview interface[,] ... may also be displayed as a standalone application or applet in a web browser[, and] ... may be displayed on a display device of a computer system, such as the output devices 215 of computer system 200 in FIG. 2[, or] ... as an app on a smartphone or tablet computer." Id. ,r 61. 3 The projected balances portlet may be displayed "in the same window as the journal portlet" or "together with the journal portlet as a pop-up window, a modal window, or other form of indication displayed on a screen at the same time." Id. ,r 68. No further technical or structural limitations of the portlet are claimed or provided. As such, the broadest reasonable interpretation of the portlets, in light of the Specification, is that the portlets can be windows in an interface. The claims do not provide details on how, i.e., by what algorithm or on what basis/method, a computing system selects a first ledger, step ( d). The Appellants direct attention to paragraphs 63 and 66 as support for these limitations. Appeal Br. 3. Paragraph 63 provides for determining a first ledger based on it being "included as part of the journal entry," "based on the type of journal entry made," or "based on information read from the 3 The Appellants' definition from Wikipedia.org is similar in providing for software components that are displayed in a web portal, which is a page displayed as a collection of non-overlapping windows. Reply Br. 3. 8 Appeal2017-010663 Application 13/460, 127 source document," but does not provide any implementation details as to how the inclusion, type, or information is used to select the first ledger. For step (h) of determining a projected balance, the Appellants direct attention to paragraph 66 (id. at 4) that provides for determining the projected balance based on calculations, such as an arithmetic sum or other methods. Thus, these limitations, under the broadest reasonable interpretation of the claim limitations, recite previewing projected balance impacts in an accounting system based on reviews of ledgers. The limitations of (a) receiving journal entries not posted in a ledger, (c) receiving a selection of a journal entry comprising a first amount, ( d) selecting a ledger associated with that first amount, ( e) receiving a start date and ( f) beginning balance of the ledger on that start date, (g) receiving a total sum of entries posted in the ledger during a specific time frame, and (h) determining a projected balance based on arithmetic sum/calculations are all activities that can be performed mentally and are ordinarily performed in accounting when determining potential impacts of costs/amounts in ledgers. The limitations of (b) displaying journal entries/amounts in a first portlet and (i) displaying the beginning and projected balances, total, and first amount in a projected balances portlet together with the journal portlet are simply displaying the results of the determinations made, post-solution activities, and also ordinarily performed in accounting to view the ledger/amounts and projected impacts of amounts. Similar to the concepts of hedging in Bilski, of intermediated settlement in Alice, of budgeting in Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 1367 (Fed. Cir. 2015), of"personal management, resource planning, or forecasting" in In re Downing, No. 9 Appeal2017-010663 Application 13/460, 127 2018-1795, 2018 WL 6436437, at *4 (Fed. Cir. Dec. 7, 2018), and of bookkeeping in Finnavations LLC v. Payoneer, Inc., No. 1: 18-CV-00444- RGA, 2018 WL 6168618, at *3 (D. Del. Nov. 26, 2018), previewing projected balance impacts in an accounting system based on reviews of ledgers is a "fundamental economic practice long prevalent in our system of commerce and taught in any introductory" accounting class. Bilski, 561 U.S. at 611. Accordingly, we conclude the claims recite a fundamental economic practice, which is one of the certain methods of organizing human activities identified in the 2019 Revised Guidance, 84 Fed. Reg. at 52, and thus an abstract idea. As such, we disagree with the Appellants' contentions that the Examiner defines the claims too broadly and that the claims are directed to splitting a projected balance analysis between two different user-interface portlets. See Appeal Br. 5---6. Under Step 2A, Prong 2 of the 2019 Revised Guidance, 84 Fed. Reg. at 54, we look to whether the claims "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," i.e., "integrates a judicial exception into a practical application." Here, the Appellants contend that the claimed "UI portals solve a computer technology problem," (Appeal Br. 6) similar to DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d 1245 (Fed. Cir. 2015) (Appeal Br. 6-7; see also Reply Br. 4--5), i.e., "[a]n additional element [that] reflects an improvement in the functioning of a computer, or an improvement to other technology or technical field" as described in the 2019 Revised Guidance (84 Fed. Reg. at 55) as indicative that the elements may have integrated the judicial exception into a practical application. The 10 Appeal2017-010663 Application 13/460, 127 Appellants' allegations that prior to the invention, "[u]sers of the transaction software were simply incapable of designing and/or executing SQL statements, and transactional terminals did not have access to query the ledger database with custom queries," and "a computer technology problem existed in that erroneous journal entries had to be committed to a database before their impact could be realized" (Appeal Br. 7) are not supported by evidence, such as the Specification. The Specification provides that enterprise resource planning ("ERP") system may include many subsystems, such as a finance/accounting application with "various traditional accounting features, such as various ledgers, subledgers, journals, and a general ledger," that are distributed among many different departments and that have their own interfaces and applications. Spec. ,r 3. Although "improvements in the art may be desirable," (id.), the Specification does not elaborate precisely on what improvements are considered or claimed. The Specification does provide that prior to the invention, "entering transactions into an accounting journal was a process that was susceptible to many errors" and involved manually transcribing data. Id. ,r 33. "The only way to detect these errors was to manually examine the data as it is being entered." Id. Further, "in order to post a journal entry, the journal entry must be approved through a first workflow, and then posted through a second workflow. This required two separate transactions by an accountant" (id. ,r 34) and two processes that were often kept separate and sometimes "used separate computer systems and relied on messages passed between the two computer systems" (id. ,r 69). The invention thus combines the two processes/workflows into a single process/workflow (id. ,r 70) using conventional computer systems (id. Figs. 1, 2, ,r,r 37--47). 11 Appeal2017-010663 Application 13/460, 127 The problems at the time of the invention, as discussed in the Specification, of detecting errors in manual entries and having two separate processes/workflows are not problems "necessarily rooted in computer technology in order to overcome a problem specifically arising in the realm of computer networks." DDR Holdings, 773 F.3d at 1257. And, the purported solution requires one or more generic computer systems operating in their ordinary capacities. Id. The claims do not recite how the portlets themselves are technologically improved or improve the functioning of the computer. The Appellants do not adequately explain how displaying information in separate portlets/windows that "visually separate[] the journal entry information from the tentative effects of posting the journal entry, while maintaining the visual relationship between the input and output" (Appeal Br. 7; see also Reply Br. 4) is a technological improvement. And, that "the calculations can be performed in real time without affecting the live data in the ledger database" (Appeal Br. 7; see also Reply Br. 5) is simply attorney argument without support in the claims or Specification. To the extent the Appellants argue that the additional features are specific enough to not be abstract (Appeal Br. 7-8), 4 although there is a degree of particularity to the way the information displayed, i.e., in separate portlets/windows on one screen, the limitations describe only the functional result of displaying without any technological details and "provide[] only a result-oriented solution with insufficient detail for how a computer 4 We acknowledge that some of these considerations may be properly evaluated under Step 2 of Alice (Step 2B of Office guidance). Solely for purposes of maintaining consistent treatment within the Office, we evaluate it under Step 1 of Alice (Step 2A, Prong 2 of Office guidance). See 2019 Revised Guidance, 84 Fed. Reg. at 55. 12 Appeal2017-010663 Application 13/460, 127 accomplishes it. Our law demands more." Intellectual Ventures I LLC v. Capital One Fin. Corp., 850 F.3d 1332, 1342 (Fed. Cir. 2017). Further, the Appellants do not provide adequate evidence or reasoning, and the claims do not describe, how or in what way the portlets are causing or creating a technological improvement or causing a computer to behave in an unconventional manner. We disagree that the claims are similar to those of Trading Techs. Int'!., Inc. v. CQG, Inc., 675 F. App'x 1001 (Fed. Cir. 2017) because "the present claims bring to the user's immediate attention effects of posting a journal entry that previously would have been overlooked in prior art UI's." Appeal Br. 8; Reply Br. 3--4. In Trading Techs., under Step 1, the district court held that the claims were "directed to improvements in existing graphical user interface devices that have no 'pre-electronic trading analog,' and recite more than 'setting, displaying, and selecting' data or information that is visible on the [graphical user interface] device." Trading Techs. 675 F. App'x at 1004 (internal quotations omitted). The district court determined that the claims "solve problems of prior graphical user interface devices ... in the context of computerized trading[] relating to speed, accuracy and usability" and did not "simply claim displaying information on a graphical user interface." Id. Rather, the claims required "a specific, structured graphical user interface paired with a prescribed functionality directly related to the graphical user interface's structure that is addressed to and resolves a specifically identified problem in the prior state of the art." Id. Further, under Step 2, the district court held that "the specific structure and concordant functionality of the graphical user interface are removed from abstract ideas, as compared to conventional computer implementations 13 Appeal2017-010663 Application 13/460, 127 of known procedures." Id. The Circuit court agreed, holding that "the claimed subject matter is 'directed to a specific improvement to the way computers operate,' ... for the claimed graphical user interface method imparts a specific functionality to a trading system 'directed to a specific implementation of a solution to a problem in the software arts."' Id. at 1006 ( citations omitted). Here, the claims simply require displaying the data in two portlets, i.e., windows, at the same time without any specific functionality directly related to the portlet's structure that is addressed to and resolves a problem in the user interface art. No specific structure of the portlets is claimed that is not conventional. "[B]ring[ing] to the user's immediate attention effects of posting a journal entry" (Appeal Br. 7-8) is not a problem of previous user interfaces; at best, it is a business problem of previous methods of projecting impacts. And, the purported solution uses generic computer systems, including portlets, in their conventional and ordinary capacities. Step Two of the Mayo/Alice Framework Under the second step in the Mayo/Alice framework, we find supported the Examiner's determination that the claims' limitations, taken individually or as an ordered combination, do not amount to significantly more than the judicial exception "because the additional elements are generic computer components claimed to perform their basic functions (storing, retrieving, processing data and receiving or transmitting data over a network)," as courts have recognized to be "computer functions are well understood, routine, and conventional functions when they are claimed in a merely generic manner." Non-Final Act. 5; see also Ans. 4. 14 Appeal2017-010663 Application 13/460, 127 We are unpersuaded by the Appellants' arguments to the contrary. See Appeal Br. 7-9; Reply Br. 3--4. Regarding the Appellants' argument that the claims are patent-eligible under Alice because they "cannot preempt other specific implementations of the alleged abstract idea of 'previewing projected balance impacts in an ... accounting system"' (Appeal Br. 8), although the Supreme Court has described "the concern that drives this exclusionary principle[, i.e., the exclusion of abstract ideas from patent eligible subject matter,] as one of pre-emption" (see Alice, 134 S. Ct. at 2354), characterizing preemption as a driving concern for patent eligibility is not the same as characterizing preemption as the sole test for patent eligibility. "The Supreme Court has made clear that the principle of preemption is the basis for the judicial exceptions to patentability" and "[ fJor this reason, questions on preemption are inherent in and resolved by the Â§ 101 analysis." Ariosa Diagnostics, Inc. v. Sequenom, Inc., 788 F.3d 1371, 1379 (Fed. Cir. 2015) (citing Alice, 134 S. Ct. at 2354) (emphasis added); cf Reply Br. 2-3. Although "preemption may signal patent ineligible subject matter, the absence of complete preemption does not demonstrate patent eligibility." Id. Thus, we sustain the Examiner's rejection of independent claims 1, 12, and 17 under 35 U.S.C. Â§ 101. Dependent claims Regarding the dependent claims, the Appellants contend that the Examiner fails to meet the burden required by Office guidelines to examine each claim individually, and thus the dependent claims "are in condition for Allowance." Appeal Br. 9; Reply Br. 5. Here, the Examiner determines that the dependent claims "fail to cure the deficiencies as recited in the claims 15 Appeal2017-010663 Application 13/460, 127 from which they depend, and are therefore rejected for the same reasoning as was applied to the claims from which they depend." Non-Final Act. 5. Although we agree with Appellants that the Examiner addressed the dependent claims in an abbreviated manner, we note that "Failure ofUSPTO personnel to follow the guidance, however, is not, in itself, a proper basis for either an appeal or a petition." 2019 Revised Guidance, 84 Fed. Reg. at 51. Moreover, we agree with the Examiner's conclusion that the dependent claims are directed to a judicial exception without significantly more. For example, dependent claims 2--4, 13, and 16 provide further limitations of receiving indication data to post an amount, determining that the post requires authorization (without details on how such a determination is made), sending a request for authorization, receiving authorization, posting in response to the authorization, and displaying an indication of requiring authorization, wherein the request to authorize and the posting are part of the same workflow. See Appeal Br. 11-12, 15, 16 (Claims App.). These are all activities that can be performed mentally or are post-solution (such as posting), are not directed to an improvement in technology but add limitations to obtain authorization that merely elaborate on the abstract idea of a fundamental economic practice (here, previewing projected balance impacts in an accounting system based on reviews of ledgers), and do not amount to significantly more. Similarly, claims 5-7, 14, 15, and 18 (see id. at 12-13, 15-17) recite further limitations of determining or receiving a second amount, determining a ledger associated with the amount, receiving balance and total/sum data, determining a second projected balance, and displaying the projected and beginning balances (without details on how any of the determinations are 16 Appeal2017-010663 Application 13/460, 127 accomplished), that merely elaborate on the abstract idea of a fundamental economic practice, and do not amount to significantly more. Claims 8 and 10 (id. at 13-14) further define the start date and a sum that add nothing to the abstract idea. Claims 9 and 19 (id. at 13, 17) add a limitation of the displaying being performed automatically, without implementation or technological details on how, and simply elaborate on the abstract idea without adding more. Claims 11 and 20 (id. at 14, 17) add a limitation of converting a first amount of a first currency into a second currency. This is an activity that can be performed mentally, is ordinarily performed in accounting, simply elaborates on the abstract idea, and does not amount to significantly more. The Appellants do not identify how any of the limitations of the dependent claims amount to significantly more than the abstract idea of a fundamental economic practice (i.e., previewing projected balance impacts in an accounting system based on reviews of ledgers), or transform the nature of the claim into patent-eligible subject matter. Thus, we sustain the Examiner's rejection of dependent claims 2-11, 13-16, and 18-20 under 35 U.S.C. Â§ 101. DECISION The Examiner's rejection of claims 1-20 under 35 U.S.C. Â§ 101 is AFFIRMED. 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