Is Patent Application Subject Matter Eligible?: No

 

Target Claim:

1. A method for replenishing a stored-value card by a multicard transaction computer system, the multicard transaction computer system comprising at least one processor and one or more computer programs executable by the at least one processor which causes the multicard transaction computer system to perform the method, the method comprising:
receiving a stored-value card activation request associated with the stored-value card which is already activated, wherein the request is received from an access point;
and generating a replenish request based on receipt of the stored-value card activation request.

 

Analysis

Step 2a:

Here, the Examiner does not determine separately that the claim is directed to stored-value card processing and account funding and to a fundamental economic practice. Rather, the Examiner compares the concept stored-value card processing and account funding to a fundamental economic practice (Final Act. 3), which, as Appellant acknowledges, the Supreme Court has held to be an abstract idea (Reply Br. 8 (citing Alice, 134 S. Ct. at 2350)). Moreover, we see no meaningful distinction between the concept of stored-value card processing and account funding and other types of fundamental economic practices, such as “local processing of payments for remotely purchased goods” in Inventor Holdings, LLC v. Bed Bath & Beyond, Inc., 876 F.3d 1372, 1378 (Fed. Cir. 2017). Accordingly, Appellant does not apprise us of error in the Examiner’s determination that independent claim 1 is directed to an abstract idea.

Step 2b:

Contrary to Appellant’s argument, the expense of changing each access point to send a replenishment request instead of an activation request is not a problem unique to computerized access points. For example, if each access point is a person, there would be an expense associated with training each person to send a replenishment request instead of an activation request. Similarly, generating, at the back end, a replenishment request based on the receipt of an activation request does not require the use of a computer, as it could be done by a person. Thus, unlike DDR Holdings, independent claim 1 does not solve a problem specifically arising in the realm of computer systems with a solution necessarily rooted in computer technology. Said differently, we fail to see how the claimed invention is something other than the generic computer implementation of a business practice that generates, at the back end, a replenishment request based on the receipt of an activation request to avoid the cost of updating every access point to send a replenishment request, which is insufficient for patent eligibility. Ans. 3; see also DDR Holdings, 773 F.3d at 1256 (“[T]hese claims [of prior cases] in substance were directed to nothing more than the performance of an abstract business practice on the Internet or using a conventional computer. Such claims are not patent-eligible.”).


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