Marcia Keld et al.

Patent Trials and Appeals Board

Sep 3, 2019

14010711 - (D) (P.T.A.B. Sep. 3, 2019)

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.
14/010,711 08/27/2013 Marcia Keld P55939 3527
157693 7590 09/03/2019
JPMorgan Chase / Greenblum & Bernstein
1950 Roland Clarke Place
Reston, VA 20191
EXAMINER
GOYEA, OLUSEGUN
ART UNIT PAPER NUMBER
3687
NOTIFICATION DATE DELIVERY MODE
09/03/2019 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):
gbpatent@gbpatent.com
PTOL-90A (Rev. 04/07)

UNITED STATES PATENT AND TRADEMARK OFFICE
____________

BEFORE THE PATENT TRIAL AND APPEAL BOARD
____________

Ex parte MARCIA KELD and SATYAN AVATARA
____________

Appeal 2018-001178
Application 14/010,711
Technology Center 3600
____________

Before JOHN A. EVANS, JOHN D. HAMANN, and ALEX S. YAP,
Administrative Patent Judges.

EVANS, Administrative Patent Judge.

DECISION ON APPEAL
Appellants1 seek our review under 35 U.S.C. § 134(a) of the
Examiner’s final rejection of Claims 1–6, 9–17, and 20–24. App. Br. 4.
Claims 7, 8, 18, and 19 are canceled. Id. We have jurisdiction under
35 U.S.C. § 6(b).
We AFFIRM.2

1 Appellants state the real party in interest is JPMorgan Chase Bank, N.A.
App. Br. 2.
2 Rather than reiterate the arguments of Appellants and the Examiner, we
refer to the Appeal Brief (filed May 30, 2017, “App. Br.”), the Reply Brief
(filed November 15, 2017, “Reply. Br.”), the Examiner’s Answer (mailed
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STATEMENT OF THE CASE
The claims relate to an accounting connection and reconciliation
system which facilitates integration of accounting data with expense
reporting data stored in an expense reporting system linked to financial
account records. See Abstract.
Invention
Claims 1, 12, and 23 are independent. An understanding of the
invention can be derived from a reading of Claim 1, which is reproduced
below.
1. An accounting connection and reconciliation system for
facilitating integration of accounting data from an accounting
system with expense reporting data stored in an expense
reporting system linked to financial account records, the system
comprising:
at least one computer memory storing instructions and
financial transaction data, wherein the memory is addressable
on a network, and accessible by a remote user on a remote user
interface unit having a user input means and a display; and
at least one computer processor accessing the memory
and executing the stored instructions to:
provide a user interface for importation of an accounting
data file including the accounting data from the accounting
system into the expense reporting system linked to financial
account records, wherein the accounting system is hosted on an
accounting system server accessible over the network;
import the accounting data file in QIF format;

September 21, 2017, “Ans.”), the Final Action (mailed November 28, 2016,
“Final Act.”), and the Specification (filed August 6, 2014, “Spec.”) for their
respective details.
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automatically modify the accounting data file with a
prefix including account information;
integrate the modified accounting data file with the
expense reporting system, wherein the expense reporting
system comprises a user defined project category for classifying
the modified accounting data file;
present the user defined project category as a graphical
arrangement capable of being modified by the user;
compare the data in the modified accounting data file
with data stored in the expense reporting system;
highlight, on the user interface, discrepancies found
through the comparison of the expense reporting data with the
accounting data;
provide options to the user on the user interface for
resolving the discrepancies;
receive user input through the user interface;
process the user input to resolve the discrepancies;
display the resolution;
transform the graphical arrangement of the user defined
project category into a data record; and
export the data record to a personal finance management
application.
App. Br. (Claims Appendix, A-1–A-2).
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Rejections
Claims 1–6, 9–17, and 20–24 stand rejected under 35 U.S.C. § 101 as
directed to non-statutory subject matter without significantly more.3 Final
Act. 2–8.
ANALYSIS
CLAIMS 1–6, 9–17, AND 20–24: INELIGIBLE SUBJECT MATTER.
We have reviewed the rejection of Claims 1–6, 9–17, and 20–24 in
light of Appellants’ arguments. We have considered in this decision only
those arguments Appellants actually raised in the Briefs. Any other
arguments which Appellants could have made but chose not to make in the
Briefs are deemed to be waived. See 37 C.F.R. § 41.37(c)(1)(iv). We adopt
as our own the findings and reasons set forth in the rejection from which this
appeal is taken and in the Examiner’s Answer, to the extent consistent with
our analysis below. We provide the following explanation to highlight and
address specific arguments and findings primarily for emphasis. We
consider Appellants’ arguments seriatim, as they are presented in the Appeal
Brief, pages 12–29.
Based upon our de novo review of the record in light of recent
Director Policy Guidance4 with respect to patent-eligible subject matter

3 Claims 1–6, 9–17, and 20–22 stand rejected under a first header. Final
Act. 2. Claims 23 and 24 stand rejected under a separate header, but for
substantially the same reasons as given for the first group of claims. Id. 5.
Therefore, we analyze all claims as a group.
4 USPTO, 2019 Revised Patent Subject Matter Eligibility Guidance, 84(4)
Fed. Reg. 50–57 (Jan. 7, 2019) (“Revised Guidance”).
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rejections under 35 U.S.C. § 101, we sustain the rejection of 1–6, 9–17, and
20–24. “Whether a claim is drawn to patent-eligible subject matter is an
issue of law that we review de novo.” SiRF Tech., Inc. v. Int’l Trade
Comm’n, 601 F.3d 1319, 1331 (Fed. Cir. 2010).
Appellants’ arguments regarding Claims 1–6, 9–17, and 20–24 are
generally presented with reference to “the claims,” but without specific
reference to the limitations of any claim. See App. Br. 7–24. Therefore, we
decide the appeal of the § 101 rejections with reference to Claim 1 and refer
to the rejected claims collectively herein as “the claims.” See 37 C.F.R.
§ 41.37(c)(1)(iv); In re King, 801 F.2d 1324, 1325 (Fed. Cir. 1986).
PRINCIPLES OF LAW
A. 35 U.S.C. § 101
An invention is patent-eligible if it claims a “new and useful process,
machine, manufacture, or composition of matter.” 35 U.S.C. § 101.5
However, the Supreme Court has long interpreted 35 U.S.C. § 101 to include
implicit exceptions: “[l]aws of nature, natural phenomena, and abstract
ideas” are not patentable. Mayo Collaborative Servs. v. Prometheus Labs.,
Inc., 566 U.S. 66, 72–78 (2012) (citing Diamond v. Diehr, 450 U.S. 175,
185 (1981)).
In determining whether a claim falls within an excluded category, we
are guided by the Supreme Court’s two-step framework, described in Mayo

5 This threshold analysis of whether a claim is directed to one of the four
statutory categories of invention, i.e., process, machine, manufacture, or
composition of matter, is referred to as “Step 1” in the patent-eligibility
inquiry under 35 U.S.C. § 101.
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and Alice Corp. v. CLS Bank Int’l, 573 U.S. 208, 217–18 (2014) (citing
Mayo, 566 U.S. at 75–77). 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. Kappos, 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 interactions
such as a fundamental economic practices (Alice, 573 U.S. at 219–20; see
also Bilski v. Kappos, 561 U.S. at 611); mathematical formulas (Parker v.
Flook, 573 U.S. 584, 594–95 (1978)); and mental processes (Gottschalk v.
Benson, 409 U.S. 63, 69 (1972)). Concepts determined to be patent eligible
include physical and chemical processes, such as “molding rubber products”
(Diehr, 450 U.S. at 191); “tanning, dyeing, making water-proof cloth,
vulcanizing India rubber, smelting ores” (id. at 182 n.7 (quoting Corning v.
Burden, 56 (15 How.) 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 “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, 191 (“We view respondents' claims as
nothing more than a process for molding rubber products and not as an
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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. at 191 (citing
Benson and Flook), 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.”).
Abstract ideas may include, but are not limited to, fundamental
economic practices, methods of organizing human activities, and
mathematical formulas or relationships. Alice, 573 U.S. at 217–21. Under
this guidance, we must therefore ensure at step one that we articulate what
the claims are directed to with enough specificity to ensure the step one
inquiry is meaningful. Id. at 217 (“[W]e tread carefully in construing this
exclusionary principle lest it swallow all of patent law.”).
If the claim is “directed to” an abstract idea, we turn 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-
eligible application.” Alice, 573 U.S. at 221 (citation 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.
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B. USPTO Revised Guidance
The USPTO recently published revised guidance in the Federal
Register concerning the application of § 101.
Under the 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);6 and
(2) additional elements that integrate the judicial exception into
a practical application (see Manual for Patent Examining
Procedure (“MPEP”) §§ 2106.05(a)–(c), (e)–(h))7.
Only if a claim (l) 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
are not “well-understood, routine, conventional” in the field
(see MPEP § 2106.05(d)); or

6 Referred to as “Revised Step 2A, Prong 1” in the Revised Guidance
(hereinafter “Step 2A(i) ”).
7 Referred to as “Revised Step 2A, Prong 2" in the Revised Guidance
(hereinafter “Step 2A(ii)”).
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(4) simply appends well-understood, routine, conventional
activities previously known to the industry, specified at a high
level of generality, to the judicial exception.8
See Revised Guidance.
Step 2A(i): Does the Claim Recite a Judicial Exception?
Informed by our judicial precedent, the Revised Guidance extracts and
synthesizes key concepts identified by the courts as abstract ideas to explain
that the abstract idea exception includes the following groupings of subject
matter, when recited as such in a claim limitation:
(a) Mathematical concepts- mathematical relationships,
mathematical formulas or equations, mathematical calculations;
(b) Certain methods of organizing human activity - fundamental
economic principles or practices (including hedging, insurance,
mitigating risk); commercial or legal interactions (including
agreements in the form of contracts; legal obligations;
advertising, marketing or sales activities or behaviors; business
relations); managing personal behavior or relationships or
interactions between people (including social activities,
teaching, and following rules or instructions); and
(c) Mental processes-concepts performed in the human mind
(including an observation, evaluation, judgment, opinion).

8 Items (3) and (4) continue to be collectively referred to as “Step 2B” of the
Supreme Court's two-step framework, described in Mayo and Alice.

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Under the Revised Guidance, if the claim does not recite a judicial
exception (a law of nature, natural phenomenon, or subject matter within the
enumerated groupings of abstract ideas above), then the claim is patent-
eligible at Step 2A(i). This determination concludes the eligibility analysis,
except in rare situations identified in the Revised Guidance.9
Improper Examination.
Throughout the Brief, Appellants argue the Examiner has improperly
applied various USPTO examination guidance documents. See App. Br. 13–
15, 18–22, 24, and 26. For example, Appellants argue: “[i]n the analysis set
forth in the Office Action, the Examiner has also failed to evaluate the claim
as a whole. According to the Interim Eligibility Guidance, the claim should
be evaluated as a whole.” App. Br. 18.
The Director of the United States Patent and Trademark Office, not
the Board, supervises examination and examiners. If an examiner has
procedurally erred, the remedy lies exclusively in petitioning the Director for
supervisory review. The Director has not delegated this supervisory
authority to the Board.
Preemption.
Appellants contend the claims do not seek to preempt or monopolize a
fundamental economic practice. App. Br. 21–24.

9 In the rare circumstance in which an examiner believes a claim limitation
that does not fall within the enumerated groupings of abstract ideas should
nonetheless be treated as reciting an abstract idea, the procedure described in
the Guidance for analyzing the claim should be followed. See Guidance,
Section 111.C.
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While preemption may denote patent ineligibility, its absence does not
demonstrate patent eligibility. See FairWarning, IP, LLC v. Iatric Sys., Inc.,
839 F.3d 1089, 1098 (Fed. Cir. 2016). For claims covering a patent-
ineligible concept, preemption concerns “are fully addressed and made
moot” by an analysis under the Mayo/Alice framework. Ariosa Diagnostics,
Inc. v. Sequenom, Inc., 788 F.3d 1371, 1379 (Fed. Cir. 2015). We conduct
such an analysis below. In response to Supreme Court and Federal Circuit
opinions, the USPTO has issued updated guidance. We review this appeal
within the framework of the Revised Guidance which specifies and
particularizes the Mayo/Alice framework.
Analysis under Revised Guidance.
In accordance with the Revised Guidance, we determine whether
under Step 2A(i) the steps recited in independent Claim 1 is directed to a
judicial exception.
The preamble to Claim 1 recites: “An accounting connection and
reconciliation system for facilitating integration of accounting data from an
accounting system with expense reporting data stored in an expense
reporting system linked to financial account records, the system
comprising.” Claim 1 further recites the following limitations as set forth in
the left column of Table I below. Table I applies the further limitation of
Claim 1 to the category of abstract idea as set forth in the Revised Guidance.
Table I
Claim 1 Revised Guidance
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[a]10 at least one computer memory
storing instructions and financial
transaction data, wherein the
memory is addressable on a
network, and accessible by a remote
user on a remote user interface unit
having a user input means and a
display;
A hardware limitation to which the
Guidance is not applicable.
[b] at least one computer processor
accessing the memory and
executing the stored instructions to:

A hardware limitation to which the
Guidance is not applicable.
[c] provide a user interface for
importation of an accounting data
file including the accounting data
from the accounting system into the
expense reporting system linked to
financial account records, wherein
the accounting system is hosted on
an accounting system server
accessible over the network;
A hardware limitation to which the
Guidance is not applicable.
[d] import the accounting data file
in QIF format;
“Mere data gathering.” Additional
element adds insignificant extra-
solution activity to the judicial
exception. Rev. Guid. 55, n.31.
[e] automatically modify the
accounting data file with a prefix
including account information;
Mental processes: concepts
performed in the human mind.11

10 Indicia, e.g., “[a],” added to facilitate discussion of individual limitations.
11 If a claim, under its broadest reasonable interpretation, covers
performance in the mind but for the recitation of generic computer
components, then it is still in the mental processes category unless the claim
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[f] integrate the modified
accounting data file with the
expense reporting system, wherein
the expense reporting system
comprises a user defined project
category for classifying the
modified accounting data file;
Mental processes: concepts
performed in the human mind.
[g] present the user defined project
category as a graphical arrangement
capable of being modified by the
user;
Mental processes: concepts
performed in the human mind.
[h] compare the data in the modified
accounting data file with data stored
in the expense reporting system;
Mental processes: concepts
performed in the human mind.
[i] highlight, on the user interface,
discrepancies found through the
comparison of the expense reporting
data with the accounting data;
Mental processes: concepts
performed in the human mind.
[j] provide options to the user on the
user interface for resolving the
discrepancies;
Mental processes: concepts
performed in the human mind.
[k] receive user input through the
user interface;
“Mere data gathering.” Additional
element adds insignificant extra-
solution activity to the judicial
exception. Rev. Guid. 55, n.31.

cannot practically be performed in the mind. See Intellectual Ventures I
LLC v. Symantec Corp., 838 F.3d 1307, 1318 (Fed. Cir. 2016) (‘‘[W]ith the
exception of generic computer-implemented steps, there is nothing in the
claims themselves that foreclose them from being performed by a human,
mentally or with pen and paper.’’). Rev. Guid. 52, n.31.
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[l] process the user input to resolve
the discrepancies;
Mental processes: concepts
performed in the human mind.
[m] display the resolution; “Mere data gathering.” Additional
element adds insignificant extra-
solution activity to the judicial
exception. Rev. Guid. 55 & n.31.
[n] transform the graphical
arrangement of the user defined
project category into a data record;
and
Mental processes: concepts
performed in the human mind.
[o] export the data record to a
personal finance management
application.
Computer operations such as
‘‘output of data analysis . . . can be
abstract,’’ Credit Acceptance Corp.
v. Westlake Servs., 859 F.3d 1044,
1056 (Fed. Cir. 2017).12

Under Step 2A(i) and based on the analysis in Table I, we determine
that limitations [e]–[j], [l], [n], and [o] each recite a judicial exception.
Step 2A(ii): Judicial Exception Integrated into a Practical Application?
If the claims recite a patent-ineligible concept, as we conclude above,
we proceed to the “practical application” Step 2A(ii) in which we determine
whether the recited judicial exception is integrated into a practical
application of that exception by: (a) identifying whether there are any
additional elements recited in the claim beyond the judicial exception(s); and
(b) evaluating those additional elements individually and in combination to

12 We find nothing in this limitation to suggest other than a conventional I/O
operation is involved.
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determine whether they integrate the exception into a practical application.
The Revised Guidance is “designed to more accurately and consistently
identify claims that recite a practical application of a judicial exception []
and thus are not ‘directed to’ a judicial exception.” Revised Guidance, 53.
For the reasons which follow, we conclude that Appellants’ claims are
not patent eligible because they do not integrate the judicial exceptions into
a practical application.

MPEP § 2106.05(a) “Improvements to the Functioning of a Computer
or To Any Other Technology or Technical Field.”
“In determining patent eligibility, examiners should consider whether
the claim ‘purport(s) to improve the functioning of the computer itself’” or
“any other technology or technical field.” MPEP § 2106.05(a).
Citing Trading Technologies13 and DDR Holdings,14 Appellants
contend the claims represent an improvement:
The claims are directed to an improved system and method that
provide tools for transporting an accounting file, such as a QIF
file from an accounting system, so that the accounting system
information can be integrated with the information in the
expense reporting system without connection fees or repetitive
data entry steps. Furthermore, given that the operator of the
disparate systems is able to integrate them, the system is more
inclusive than previous systems as it will include purchases that
are not made through a host financial institution.

13 Trading Technologies International Inc., v. CQG, Inc., 2017 WL 192716
(Fed. Cir. Jan. 18, 2017).
14 DDR Holdings LLC v. Hotels.com. L.P., 773 F.3d 1234 (Fed Cir. 2014)
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App. Br. 20.
Appellants correctly note the Federal Circuit held the Trading
Technology claims to recite patent-eligible subject matter because the claims
“solve problems of prior graphical user interface devices . . . in the context
of computerized trading[] relating to speed, accuracy, and usability. Id.
(quoting Trading Technologies, at 2). However, whereas the Trading
Technology claims “solve problems of prior graphical user interface
devices,” Appellants do not relate their claims to problems of prior art
devices, but argue the improvement is to an accounting system. Limitation
[f] recites, inter alia, “integrate the modified accounting data file with the
expense reporting system,” but Appellants’ Appeal Brief cites neither their
Specification, nor, the claim language, to show specifically how such
“integration” is accomplished.
Appellants’ Reply contends the “claimed invention provides a
comprehensive system and method that address a unique algorithm to solve
a problem in conventional industry practice, with the limitations of the prior
art systems being clearly set forth in the Specification.” Reply Br. 3 (citing
Spec., ¶¶ 3–9). This argument has been made for the first time in the Reply
Brief. “[T]he reply brief [is not] an opportunity to make arguments that
could have been made in the principal brief on appeal to rebut the
Examiner’s rejections, but were not.” Ex parte Borden, 93 USPQ2d 1473,
1474 (BPAI 2010) (informative) (“Any bases for asserting error, whether
factual or legal, that are not raised in the principal brief are waived.”);
Optivus Tech., Inc. v. Ion Beam Appl’ns. S.A., 469 F.3d 978, 989 (Fed. Cir.
2006) (citations and quotations marks omitted) (“[A]n issue not raised by an
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appellant in its opening brief . . . is waived.”).
We conclude an alleged improvement to an accounting system is not
an improvement to the functioning of a computer, nor of any other
technology.

MPEP § 2106.05(b) Particular Machine.
At the outset, we note that the Bilski machine-or-transformation test is
only applicable to the method (process) claims on appeal. This section of
the MPEP guides: “When determining whether a claim recites significantly
more than a judicial exception, examiners should consider whether the
judicial exception is applied with, or by use of, a particular machine.” See
Bilski v. Kappos, 561 U.S. 593, 604 (2010) (“[T]he machine-or-
transformation test is a useful an important clue, and investigative tool” for
determining whether a claim is patent eligible under § 101). MPEP
§ 2106.05(b).
MPEP § 2106.05(b) provides further guidance regarding what
constitutes a particular machine:
[A]s described in MPEP §2106.05(f), additional elements that
invoke computers or other machinery merely as a tool to
perform an existing process will generally not amount to
significantly more than a judicial exception. See, e.g., Versata
Development Group v. SAP America, 793 F.3d 1306, 1335
(Fed. Cir. 2015) (explaining that in order for a machine to add
significantly more, it must “play a significant part in permitting
the claimed method to be performed, rather than function solely
as an obvious mechanism for permitting a solution to be
achieved more quickly”).

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We find the claims on appeal are silent regarding specific limitations
directed to an improved computer system, processor, memory, network,
database, or Internet, nor do Appellants direct our attention to such specific
limitations. “[T]he mere recitation of a generic computer cannot transform a
patent-ineligible abstract idea into a patent-eligible invention.” Alice, 573
U.S. at 223; see also BASCOM Glob. Internet Servs., Inc. v. AT&T Mobility
LLC, 827 F.3d 1341, 1348 (Fed. Cir. 2016) (“An abstract idea on ‘an
Internet computer network’ or on a generic computer is still an abstract
idea”). Applying this reasoning here, we conclude Appellants’ claims are
not directed to a particular machine, but rather merely implement an abstract
idea using generic computer components. Thus, we conclude Appellants’
method claims fail to satisfy the “tied to a particular machine” prong of the
Bilski machine-or-transformation test.

MPEP § 2106.05(c) Particular Transformation.
This section of the MPEP guides: “Another consideration when
determining whether a claim recites significantly more is whether the claim
effects a transformation or reduction of a particular article to a different state
or thing.” “[T]ransformation and reduction of an article ‘to a different state
or thing’ is the clue to patentability of a process claim that does not include
particular machines.” Bilski, 561 U.S. at 658 (quoting Benson, 409 U.S. at
70).
The claims operate to select and analyze certain electronic data, i.e.,
accounting data files in QIF format. The selection of electronic data is not a
“transformation or reduction of an article into a different state or thing
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constituting patent-eligible subject matter[.]” See In re Bilski, 545 F.3d 943,
962 (Fed. Cir. 2008) (emphasis added). See also CyberSource Corp. v.
Retail Decisions, Inc., 654 F.3d 1366, 1375 (Fed. Cir. 2011) (“The mere
manipulation or reorganization of data . . . does not satisfy the
transformation prong.”). Applying this guidance here, we conclude
Appellants’ method claims fail to satisfy the transformation prong of the
Bilski machine-or-transformation test.

MPEP § 2106.05(e) Other Meaningful Limitations.

This section of the MPEP guides:

Diamond v. Diehr provides an example of a claim that recited
meaningful limitations beyond generally linking the use of the
judicial exception to a particular technological environment.
450 U.S. 175 (1981). In Diehr, the claim was directed to the
use of the Arrhenius equation (an abstract idea or law of nature)
in an automated process for operating a rubber-molding press.
450 U.S. at 177-78. The Court evaluated additional elements
such as the steps of installing rubber in a press, closing the
mold, constantly measuring the temperature in the mold, and
automatically opening the press at the proper time, and found
them to be meaningful because they sufficiently limited the use
of the mathematical equation to the practical application of
molding rubber products. 450 U.S. at 184. In contrast, the
claims in Alice Corp. v. CLS Bank International did not
meaningfully limit the abstract idea of mitigating settlement
risk. 573 U.S. __,134 S. Ct. 2347, 110 USPQ2d 1976 (2014). In
particular, the Court concluded that the additional elements
such as the data processing system and communications
controllers recited in the system claims did not meaningfully
limit the abstract idea because they merely linked the use of the
abstract idea to a particular technological environment (i.e.,
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“implementation via computers”) or were well-understood,
routine, conventional activity.
MPEP § 2106.05(e).
“[T]he relevant question is whether the claims here do more than
simply instruct the practitioner to implement the abstract idea . . . on a
generic computer.” Alice, 573 U.S. at 225. Similarly as for Alice, we find
that “[t]aking the claim elements separately, the function performed by the
computer at each step of the process is ‘[p]urely conventional.’” Id. “In
short, each step does no more than require a generic computer to perform
generic computer functions.” Id.

MPEP § 2106.05(f) Mere Instructions To Apply An Exception.
Appellants do not persuasively argue that their claims do any more
than to merely invoke generic computer components merely as a tool in
which the computer instructions apply the judicial exception.

MPEP § 2106.05(g) Insignificant Extra-Solution Activity.
Following various data-manipulation steps, there is “extra-solution
activity,” i.e., “export[ing] the data record to a personal finance management
application.” We find exporting data to be a classic example of insignificant
extra-solution activity. See, e.g., Bilski, 545 F.3d at 963 (en banc), aff’d sub
nom, Bilski v. Kappos, 561 U.S. 593 (2010).

MPEP § 2106.05(h) Field of Use and Technological Environment.

Appeal 2018-001178
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[T]he Supreme Court has stated that, even if a claim does not
wholly pre-empt an abstract idea, it still will not be limited
meaningfully if it contains only insignificant or token pre- or
post-solution activity—such as identifying a relevant audience,
a category of use, field of use, or technological environment.
Ultramercial, Inc. v. Hulu, LLC, 722 F.3d 1335, 1346 (Fed. Cir. 2013).
We find the “computer” and “server” limitations are simply a field of
use that attempts to limit the abstract idea to a particular technological
environment. We do not find Appellants’ argument to be persuasive
because “[t]he courts have also identified examples in which a judicial
exception has not been integrated into a practical application.” Revised
Guidance, at 55. The claims fail to recite a practical application where the
additional element does no more than generally link the use of a judicial
exception to a particular technological environment or field of use. Id. The
mere application of an abstract idea in a particular field is not sufficient to
integrate the judicial exception into a practical application. See id. at n. 32.
In view of the foregoing, we conclude the claims are “directed to” a judicial
exception.

3. Well-understood, routine, conventional.
Because the claims recite a judicial exception and does not integrate
that exception into a practical application, we must then reach the issue of
whether the claims add a specific limitation beyond the judicial exception
that is not “well-understood, routine, conventional” in the field. Revised
Guidance, at 56.
The Examiner finds the claimed “computer memory,” “computer
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processor,” “network,” “user input means,” and “display” are recited at a
high level of generality and are recited as performing generic computer
functions routinely used in computer applications. Generic computer
components recited as performing generic computer functions that are well-
understood, routine and conventional activities amount to no more than
implementing the abstract idea with a computerized system. Final Act. 4;
Ans. 13 (citing Spec. ¶ 23).
Appellants cite Enfish for the proposition that: “we are not persuaded
that the invention’s ability to run on a general-purpose computer dooms the
claims.” App. Br. 16 (quoting Enfish at 1691). Appellants further argue:
“the claims provide meaningful limitations beyond generally linking the use
of an allegedly abstract idea to a particular technological environment.”
Reply Br. 9. R. 20.
We do not find the claims to be “doomed” because they run on
general-purpose computers. Rather, we find Appellants’ arguments not to
be persuasive because Appellants fail to argue with particularity which
limitations are “meaningful beyond generally linking the use of an allegedly
abstract idea to a particular technological environment.” We find the
limitations to be “well-understood, routine, [and] conventional” and as such,
fail to indicate the presence of an inventive concept.
4. Specified at a high level of generality.
It is indicative of the absence of an inventive concept where the
claims simply append well-understood, routine, conventional activities
previously known to the industry, specified at a high level of generality, to
the judicial exception. Revised Guidance, at 56.
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Appellants contend that at least the following limitations of Claim 1
(and the commensurate limitations of Claims 12 and 23) are meaningful
limitations providing significantly more than an abstract idea:
provide a user interface for importation of an accounting data
file including the accounting data from the accounting system
into the expense reporting system linked to financial account
records, wherein the accounting system is hosted on an
accounting system server accessible over the network; import
the accounting data file in QIF format; automatically modify
the accounting data file with a prefix including account
information; integrate the modified accounting data file with the
expense reporting system, wherein the expense reporting
system comprises a user defined project category for classifying
the modified accounting data file; present the user defined
project category as a graphical arrangement capable of being
modified by the user; compare the data in the modified
accounting data file with data stored in the expense reporting
system; highlight, on the user interface, discrepancies found
through the comparison of the expense reporting data with the
accounting data; [and] provide options to the user on the user
interface for resolving the discrepancies.
Reply Br. 9.
We find the cited limitations are specified at such a high level of
generality consistent with the absence of an inventive concept. Therefore,
we conclude that none of the claim limitations, viewed “both individually
and as an ordered combination,” amount to significantly more than the
judicial exception in order to sufficiently transform the nature of the claims
into patent-eligible subject matter. See Alice, 573 U.S. at 217 (internal
quotations omitted) (quoting Mayo, 566 U.S. at 79).
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In view of the foregoing, we sustain the rejection of Claims 1–6, 9–
17, and 20–24 under 35 U.S.C. § 101.

DECISION
The rejection of Claims 1–6, 9–17, and 20–24 under 35 U.S.C. § 101
is AFFIRMED.
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.
§ 41.50(f).

AFFIRMED