Brian Frey et al.

Patent Trials and Appeals Board

Jul 18, 2019

13004595 - (D) (P.T.A.B. Jul. 18, 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.
13/004,595 01/11/2011 Brian Frey 87188-794744 (097400US) 1829
20350 7590 07/18/2019
KILPATRICK TOWNSEND & STOCKTON LLP
Mailstop: IP Docketing - 22
1100 Peachtree Street
Suite 2800
Atlanta, GA 30309
EXAMINER
CAMPEN, KELLY SCAGGS
ART UNIT PAPER NUMBER
3691
NOTIFICATION DATE DELIVERY MODE
07/18/2019 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):
KTSDocketing2@kilpatrick.foundationip.com
ipefiling@kilpatricktownsend.com
PTOL-90A (Rev. 04/07)
UNITED STATES PATENT AND TRADEMARK OFFICE
____________________

BEFORE THE PATENT TRIAL AND APPEAL BOARD
____________________

Ex parte BRIAN FREY and OGHIE SHEEHY
____________________

Appeal 2017-008674
Application 13/004,5951
Technology Center 3600
____________________

Before JON M. JURGOVAN, ADAM J. PYONIN and NABEEL U. KHAN,
Administrative Patent Judges.

JURGOVAN, Administrative Patent Judge.

DECISION ON APPEAL

Appellants seek review under 35 U.S.C. § 134(a) from a Non-Final
Rejection of claims 1–20, which are all the claims pending in the
application. We have jurisdiction under 35 U.S.C. § 6(b).
We affirm.2

1 Appellants identify First Data Corporation and FEXCO Merchant Services
as the real parties in interest. App. Br. 2.
2 Our Decision refers to the Specification (“Spec.”) filed January 11, 2011,
the Non-Final Office Action (“Non-Final Act.”) mailed September 7, 2016,
the Appeal Brief (“App. Br.”) filed January 20, 2017, the Examiner’s
Answer (“Ans.”) mailed March 23, 2017, and the Reply Brief (“Reply Br.”)
filed May 19, 2017.
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CLAIMED INVENTION
In the claimed invention, a host computer system transmits to a client
(purchaser) computer system a web page with prices of goods and services
offered by a merchant computer system. Spec. ¶ 2. The host computer
system also transmits a currency conversion plug-in received and used by a
client (purchaser) computer system to convert prices in the base currency of
the web page into prices in the purchaser’s currency for display. Id. The
client computer system transmits purchase information to the host computer
system, which responds by transmitting a purchase identifier linked to the
purchase information. Id. The client computer system then sends the
merchant computer system the purchase identifier in order to guarantee an
equivalence of a purchase value between the purchaser’s currency and the
base currency. Spec. ¶ 63. The price guarantee is between an entity
operating the host computer system and the merchant. Id.
Claims 1, 12, and 17 are independent. Claim 1, reproduced below, is
illustrative of the claimed subject matter:
1. A method for conducting an online payment using a
currency other than a base currency of a webpage, the method
comprising:
providing a currency conversion plug-in to a client
computer system;
detecting a location preference of a user with the
currency conversion plug-in using internet protocol (IP)
detection;
storing the location preference of the user with the
currency conversion plug-in;
receiving, by the client computer system from a merchant
computer system, the webpage, wherein
the client computer system is operated by a
purchaser conducting an online purchase transaction; and
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a merchant associated with the merchant computer
system is offering goods and/or services for sale via the
webpage;
receiving, by the client computer system, an indication of
a purchaser’s currency;
identifying, by the client computer system, a plurality of
prices on the webpage, wherein:
the plurality of prices on the webpage are in the
base currency of the webpage; and
the base currency of the webpage is different from
the purchaser’s currency;
transmitting, by a host computer system a conversion rate
between the base currency of the webpage and the purchaser’s
currency;
receiving, by the client computer system from the host
computer system, the conversion rate between the base
currency and the purchaser’s currency;
converting, by the client computer system, the identified
plurality of prices on the webpage listed in the base currency to
a plurality of prices in the purchaser’s currency using the
conversion rate received from the host computer system such
that the webpage, as displayed by the client computer system,
contains the plurality of prices in the purchaser’s currency;
transmitting, by the client computer system to the host
computer system, purchase information;
receiving, by the client computer system from the host
computer system, in response to the purchase information, a
purchase identifier linked to the purchase information wherein
the purchase identifier is used to guarantee an equivalence of a
purchase value in the purchaser’s currency and the base
currency between an entity operating the host computer system
and the merchant; and
transmitting, by the client computer system to the
merchant computer system, the purchase identifier linked to the
purchase information.

App. Br. 13–14 (Claims App’x).

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REJECTION
(1) Claims 1–20 stand rejected under 35 U.S.C. § 101 as directed to
non-statutory subject matter. Non-Final Act. 2–7.

ANALYSIS
§ 101 Rejection
Patent eligibility is a question of law that is reviewable de novo.
Dealertrack, Inc. v. Huber, 674 F.3d 1315, 1333 (Fed. Cir. 2012).
Accordingly, we review the Examiner’s § 101 determinations concerning
patent eligibility under this standard.
Patentable subject matter is defined by 35 U.S.C. § 101, as follows:
[w]hoever invents or discovers any new and useful process,
machine, manufacture, or composition of matter, or any new
and useful improvement thereof, may obtain a patent therefor,
subject to the conditions and requirements of this title.
In interpreting this statute, the Supreme Court emphasizes that patent
protection should not preempt “the basic tools of scientific and technological
work.” Gottschalk v. Benson, 409 U.S. 63, 67 (1972) (“Benson”); Mayo
Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66, 71 (2012)
(“Mayo”); Alice Corp. v. CLS Bank Int’l, 573 U.S. 208, 216 (2014)
(“Alice”). The rationale is that patents directed to basic building blocks of
technology would not “promote the [p]rogress of [s]cience” under the U.S.
Constitution, Article I, Section 8, Clause 8, but instead would impede it.
Accordingly, laws of nature, natural phenomena, and abstract ideas, are not
patent-eligible subject matter. Thales Visionix Inc. v. U.S., 850 F.3d 1343,
1346 (Fed. Cir. 2017) (citing Alice, 573 U.S. at 216).
The Supreme Court reiterated the Mayo two-part test for subject
matter eligibility in Alice (573 U.S. at 217–218). The first step is to
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determine whether the claim is directed to a patent-ineligible concept. Id.
(citing Mayo, 566 U.S. at 76–77). If so, then the eligibility analysis
proceeds to the second step of the Alice/Mayo test in which we “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 (quoting Mayo, 566 U.S. at 72,
79). There is no need to proceed to the second step, however, if the first step
of the Alice/Mayo test yields a determination that the claim is directed to
patent eligible subject matter.
The Patent Office has recently revised its guidance for how to apply
the Alice/Mayo test in the 2019 Revised Patent Subject Matter Eligibility
Guidance, 84 Fed. Reg. 50–57 (January 7, 2019) (“the Revised Guidance”).
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, mental processes, or
certain methods of organizing human activity such as a
fundamental economic practice or managing personal behavior
or relationships or interactions between people); and
(2) additional elements that integrate the judicial exception into
a practical application (see Manual of Patent Examining
Procedure (“MPEP”) § 2106.05(a)–(c), (e)–(h)). 84 Fed. Reg. at
51–52, 55.
A claim that integrates a judicial exception into a practical application
applies, relies on, or uses 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. 84 Fed. Reg.
at 54. When the judicial exception is so integrated, then the claim is not
directed to a judicial exception and is patent-eligible under § 101. 84 Fed.
Reg. at 54. Only if a claim (1) recites a judicial exception and (2) does not
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integrate that exception into a practical application, do we then evaluate
whether the claim provides an inventive concept. 84 Fed. Reg. at 56; Alice,
573 U.S. at 221. We proceed with applying the patent eligibility framework
in the following sections of this decision to the claims presented here on
appeal.
USPTO Step 1–Categories of Invention in 35 U.S.C. § 101
Step 1 of the patent eligibility analysis is to review the claims to
ensure they fall within one of the enumerated categories of invention under
§ 101. Claims 1–11 recite “methods” which qualify as “processes” under
§ 101. Claims 12–20 recites “systems” which qualify as “machines” under
§ 101. Thus, the claims satisfy Step 1 of the subject matter eligibility
analysis, and we proceed to Step 2A to determine whether the claims recite
abstract ideas.
Alice/Mayo—Step 1 (Abstract Idea)
USPTO Step 2A–Prongs 1 and 2 identified in the Revised Guidance

USPTO Step 2A—Prong 1 (Does the Claim Recite a Judicial Exception?)
Turning to the first step of the Alice inquiry (Step 2A, Prong 1 of the
Revised Guidance), the Examiner finds the claims recite the abstract idea of
converting currency in a financial transaction. Non-Final Act. 7–8. We
agree with the Examiner the claims recite this abstract idea and others,
namely, conducting a financial transaction, and providing a price guarantee.
In each of independent claims 1, 12, and 17, the recited steps or
functions are connected to currency conversion. For example, the claim 1
limitations include providing a currency conversion plug-in, detecting and
storing a user’s location preference, receiving an indication of a purchaser’s
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currency, identifying prices on a web page in a base currency, transmitting
and receiving a conversion rate, and converting the prices on the web page
from the base currency to the purchaser’s currency using the conversion rate
for display to the purchaser. Thus, as the Examiner finds, these claims recite
converting currency in a financial transaction, which, in the Revised
Guidance, falls within the category of abstract idea of “certain methods of
organizing human activity” as a “fundamental economic principle or
practice,” including “hedging, insurance, mitigating risk” and “commercial
or legal interactions” including “agreements in the form of contracts; legal
obligations; advertising, marketing or sales activities or behaviors; business
relations.” Non-Final Act. 7–8; Revised Guidance, 84 Fed. Reg. at 52.
These activities also fall under the category of a “mental process” under the
Revised Guidance because currency conversion can be carried out in the
human mind or using pencil and paper as steps of observation, evaluation,
judgment, and opinion.
In addition, each of independent claims 1, 12, and 17 recites a method
of conducting payment involving transmitting and receiving purchase
information. Thus, the claims recite the abstract idea of conducting a
financial transaction, which also falls under the judicial exception of “certain
methods of organizing human activity” as a “fundamental economic
principle or practice,” including “hedging, insurance, mitigating risk” and
“commercial or legal interactions” including “agreements in the form of
contracts; legal obligations; advertising, marketing or sales activities or
behaviors; business relations.” A financial transaction may also be carried
out in the human mind or with pen and paper as steps of observation,
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evaluation, judgment, and opinion, and thus qualifies as a “mental process”
as well.
Independent claims 1, 12, and 17 further recite receiving and
transmitting a purchase identifier used to guarantee an equivalence of a
purchase value in the purchaser’s currency and the base currency. Thus, the
claims further recite providing a price guarantee, which falls under the
abstract idea of “certain methods of organizing human activity” as a
“fundamental economic principle or practice” including “hedging, insurance,
mitigating risk.” A price guarantee can also be carried out in the human
mind using a pen and paper, and thus also qualifies as a “mental process”
including steps of observation, evaluation, judgment, and opinion.
In many similar cases, our reviewing courts have found the kinds of
activities recited in the claims presented here to constitute abstract ideas.
Examples of these cases include Alice, 573 U.S. 208 (intermediated
settlement); Bilski v. Kappos, 561 U.S. 593, 598 (2010) (hedging against the
financial risk of price fluctuations); CyberSource Corp. v. Retail Decisions,
Inc., 654 F.3d 1366, 1370 (Fed. Cir. 2011) (verifying a credit-card
transaction); buySAFE, Inc. v. Google, Inc., 765 F.3d 1350 (Fed. Cir. 2014)
(guaranteeing online transactions); OIP Technologies, Inc. v. Amazon.com,
Inc., 788 F.3d 1359 (Fed. Cir. 2015) (offer-based price optimization); Smart
Systems Innovations, LLC v. Chicago Transit Authority, 873 F.3d 1364 (Fed.
Cir. 2017) (collecting financial data); Credit Acceptance Corp. v. Westlake
Services, 859 F.3d 1044 (Fed. Cir. 2017) (processing an application for
financing a purchase); Inventor Holdings, LLC v. Bed Bath & Beyond, Inc.,
876 F.3d 1372 (Fed. Cir. 2017) (local processing of payments for remotely
purchased goods). The parallels between these cases and the present claims
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are apparent. Specifically, these cases involve online purchases and
guarantees similar to the claims presented here. All were determined to
recite abstract ideas. These cases overwhelmingly lead us to the conclusion
that the claims at issue here also recite abstract ideas.
We thus proceed to Step 2A, Prong Two of the subject matter
eligibility analysis to determine whether the abstract ideas embodied in the
claims are integrated into a practical application.
USPTO Step 2A—Prong 2 (Integration into Practical Application)
Under Step 2A, Prong 2 of the Revised Guidance, we discern no
additional element (or combination of elements) recited in claims 1–20 that
integrates the judicial exception into a practical application. See Revised
Guidance, 84 Fed. Reg. at 54–55 (“Prong Two”). For example, Appellants’
claimed additional elements (e.g., “client (purchaser) computer system,”
“host computer system,” “merchant computer system,” “plug-in,” and “web
page”) do not: (1) improve the functioning of a computer or other
technology; (2) are not applied with any particular machine (except for a
generic computer system); (3) do not effect a transformation of a particular
article to a different state; and (4) are not applied in any meaningful way
beyond generally linking the use of the judicial exception to a particular
technological environment, such that the claim as a whole is more than a
drafting effort designed to monopolize the exception. See MPEP
§§ 2106.05(a)–(c), (e)–(h).
In claims 1–20, the computer systems, plug-in, and web page merely
assist the human purchaser, merchant, and host entity in doing what they
could do, mentally or physically, by themselves, by implementing the recited
abstract idea on a computer. The claims here do not focus on a specific
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improvement of computer capabilities, but instead merely invoke computers
as a tool. This is insufficient to integrate the abstract idea into a practical
application. Enfish, LLC v. Microsoft Corp., 822 F.3d 1327, 1335–1336
(Fed. Cir. 2016) (“the Alice inquiry [] asks whether the focus of the claims is
on the specific asserted improvement in computer capabilities [] or, instead,
on a process that qualifies as an ‘abstract idea’ for which computers are
invoked merely as a tool.”); SiRF Tech., Inc. v. Int’l Trade Comm’n, 601
F.3d 1319, 1333 (Fed. Cir. 2010) (“In order for the addition of a machine to
impose a meaningful limit on the scope of a claim, 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, i.e., through the utilization of a computer for performing
calculations.”). The claims do not recite any specifics of the computer
systems, plug-in, or web page unique to carrying out the invention. Instead,
they recite, at a high level of generality, components that merely assist in
carrying out various financial tasks. Thus, the claims do no more than
generally link the abstract ideas of currency conversion, purchase
transaction, and price guarantee, to well-known computer system, plug-in,
and web page technologies. This constitutes mere linking of the judicial
exception to a particular technological environment or field of use, which is
not sufficient to establish a practical application. Bilski, 561 U.S. at 612,
and Parker v. Flook, 437 U.S. at 584, 588–590 (1978).
Thus, the claims, when viewed as a whole, recite no additional
elements or combinations thereof that amount to integration of the abstract
ideas recited in these claims into a practical application. We conclude that
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claims 1–20 recite the abstract ideas of currency conversion, purchase
transaction, and price guarantee.
We next proceed to Step 2B of the subject matter eligibility test where
we determine whether the claims recite an inventive concept that is
significantly more than the abstract ideas embodied therein.

Alice/Mayo—Step 2 (Inventive Concept)
Step 2B identified in the Revised Guidance

Under Federal Circuit precedent, an “inventive concept” under Alice
step 2 can be established by showing, for example, that the patent claims:
(1) provide a technical solution to a technical problem unique
to the Internet, e.g., a “solution . . . necessarily rooted in
computer technology in order to overcome a problem
specifically arising in the realm of computer networks”
(see DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d
1245, 1257 (Fed. Cir. 2014));
(2) transform the abstract idea into “a particular, practical
application of that abstract idea,” e.g., “installation of a
filtering tool at a specific location, remote from the end-
users, with customizable filtering features specific to each
end user” (see BASCOM Glob. Internet Servs., Inc. v.
AT&T Mobility LLC, 827 F.3d 1341, 1352, 1350
(Fed. Cir. 2016)); or
(3) “entail[] an unconventional technological solution ([e.g.,]
enhancing data in a distributed fashion) to a technological
problem ([e.g.,] massive record flows [that] previously
required massive databases)” and “improve the
performance of the system itself” (see Amdocs (Israel)
Limited v. Openet Telecom, Inc., 841 F.3d 1288, 1300,
1302 (Fed. Cir. 2016)).
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Similarly, as recognized by the Revised Guidance, an “inventive
concept” under Step 2B can be evaluated based on whether an additional
element or combination of elements:
(1) “[a]dds a specific limitation or combination of limitations
that are not well-understood, routine, conventional activity
in the field, which is indicative that an inventive concept
may be present;” or
(2) “simply appends well-understood, routine, conventional
activities previously known to the industry, specified at a
high level of generality, to the judicial exception, which is
indicative that an inventive concept may not be present.”
See Revised Guidance, 84 Fed. Reg. at 56.
The Specification mentions various problems the claimed invention is
intended to overcome, namely, inconvenience in conducting a transaction in
a different currency, not knowing the conversion rate, and the need to
manually convert from the merchant’s to the purchaser’s currency. Spec.
¶ 1. The Specification also mentions the problem of covering the merchant
for lost funds due to price discrepancies or incorrect or outdated conversion
rates. Spec. ¶ 63. Although presented in the context of e-commerce, these
problems are not technical in nature and existed long before e-commerce.
Currency conversion, purchase transactions, and price guarantees are not
modern phenomena, but instead have existed since ancient times.
As mentioned, the claims recite technology including various
computer systems, a plug-in, and a web page. We note that computer
systems, plug-ins, and web pages, at a general level, are conventional
technologies well-known before the claimed invention. See, e.g., Spec.
¶¶ 66, 81–92. Computer systems and web pages have been used for
currency conversion, financial transactions, and transaction guarantees. This
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is demonstrated by prior art documents of record in this case, including
US 2004/0167854 A1, published August 26, 2004 (e-commerce financial
transaction/currency conversion/websites); US 2008/0109321 A1, published
May 8, 2008 (e-commerce financial transaction/web pages/transaction
guarantee); US 2003/0144922 A1, published July 31, 2003 (web sites and
web pages/currency conversion); US 2003/0187792 A1, published October
2, 2003 (e-commerce financial transaction/currency conversion/web pages);
US 2004/0024697 A1, published February 5, 2004 (e-commerce web
sites/currency conversion/transaction guarantee). Plug-ins were also known
in this art before the invention. See, e.g.,
https://www.britannica.com/technology/plug-in (last viewed 6/28/19).
Accordingly, we conclude that claims 1–20 fail to recite an inventive
concept sufficient to transform into patent-eligible subject matter the recited
abstract ideas. We, therefore, sustain the Examiner’s rejection of claims 1–
20 under 35 U.S.C. § 101.
Appellants’ Arguments
Appellants argue that the Examiner overgeneralizes the claims. App.
Br. 6. We do not agree with Appellants’ contention. Patent eligibility
analysis requires the Examiner initially to consider the claims at a level of
abstraction by extracting elements from the claims to determine the abstract
ideas that are recited therein. The remaining steps of the eligibility analysis
consider the additional elements that were not considered in the first part of
the analysis. Thus, we do not agree the Examiner errs by initially
generalizing the claims when applying the Alice/Mayo framework. Further,
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such argument is rendered moot by our analysis pursuant to the Revised
Guidance, above.
Appellants argue the claims solve an Internet-centric problem and are
rooted in computer technology. App. Br. 6. For reasons explained in the
previous sections of this decision, we do not agree. The problems the
claimed invention overcomes have been known since ancient times.
Appellants contend the present claims do not preempt all currency
conversions or online business transactions. In the patent eligibility analysis
under Alice/Mayo, however, “preemption concerns are fully addressed and
made moot.” Ariosa Diagnostics, Inc. v. Sequenom, Inc., 788 F.3d 1371,
1379 (Fed. Cir. 2015). In any case, “the absence of complete preemption
does not demonstrate patent eligibility.” Id.
Appellants contend the Examiner gave little weight to the recited
computer components and software elements of the claims (i.e., the plug-in).
App. Br. 8, 10. As discussed in previous sections of this decision, we have
given the claimed plug-in, web page, and computer systems due
consideration in the patent eligibility analysis. We determine these
components are not sufficiently detailed in the claims to define additional
elements that implement the abstract ideas in the claims into a practical
application, nor do they define a transformative “inventive concept.”
Appellants argue that independent claims 1, 12, and 17 recite subject
matter similar to Example 21 of Appendix 1 of the July 2015 Update:
Subject Matter Eligibility. App. Br. 10–11. See
https://www.uspto.gov/sites/default/files/documents/ieg-july-2015-app1.pdf
(last viewed 6/28/19). Appellants do not explain, however, why they
consider the allowable claim of Example 21 to be similar to the independent
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claims 1, 12, and 17 at issue here. Appellants also contend the claims
address an Internet-centric problem by enabling potential customers to
compare prices of and purchase products and services from merchant
webpages around the world. Independent claims 1, 12, and 17 do not recite
anything about price comparisons of goods or services of different
merchants, and thus, Appellants’ arguments are not commensurate in scope
with the claims. Limitations not appearing in the claims cannot be relied
upon for patentability. In re Self, 671 F.2d 1344, 1348 (CCPA 1982).
Furthermore, Appellants’ paraphrasing of the allowed claim in Example 21
leaves out much of what was recited in the actual example, which was not
nearly as broad as Appellants’ paraphrasing would suggest. For all of these
reasons, we find Appellants’ arguments unpersuasive to show Examiner
error.
Appellants’ Reply Brief arguments are largely redundant to those
presented in the Appeal Brief. Appellants do present a new argument,
however, without a showing of good cause. We do not consider new
arguments made in a reply brief without a showing of good cause why they
were not earlier presented because the examiner has not had an opportunity
to consider and respond to the argument. 37 C.F.R. § 41.41(b)(2).
Even if we could consider the new argument, however, we would find
it unpersuasive. In particular, Appellants rely on McRO, Inc. v. Bandai
Namco Games America Inc., 837 F.3d 1299 (Fed. Cir. 2016) as supporting
patentability of the claims. Reply Br. 3–4. We do not find McRO apposite
to the facts of this case. In McRO, the claims improved the functioning of a
computer or technical field by automatically animating lip synchronization
and facial expression of three-dimensional characters using complex
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processing involving morph weight streams, timed data files of phonemes,
transition parameters, and other data. See Revised Guidance, 84 Fed. Reg. at
53, fn. 18. McRO is very different from this case, where the claims involve
known computer systems, web pages, and plug-ins claimed at a high level of
generality to carry out the abstract ideas recited in the claims, namely,
currency conversions, financial transactions, and price guarantees. Mayo,
566 U.S. at 82 (“simply appending conventional steps, specified at a high
level of generality, to laws of nature, natural phenomena, and abstract ideas
cannot make those laws, phenomena, and ideas patentable.”).
Thus, we do not find Appellants’ arguments persuasive to show the
Examiner errs in the conclusion that the claims are directed to patent-
ineligible subject matter as presented on appeal.

DECISION
The Examiner’s rejections of claims 1–20 under 35 U.S.C. § 101 are
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)(1)(iv).

AFFIRMED