Richard Love

Patent Trials and Appeals Board

Aug 19, 2019

13573795 - (D) (P.T.A.B. Aug. 19, 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.
13/573,795 10/03/2012 Richard Love 453.02 6375
55409 7590 08/19/2019
TEMMERMAN LAW OFFICE
MATHEW J. TEMMERMAN
ONE MARKET STREET
SPEAR TOWER, 36TH FLOOR
SAN FRANCISCO, CA 94105
EXAMINER
CAMPEN, KELLY SCAGGS
ART UNIT PAPER NUMBER
3691
NOTIFICATION DATE DELIVERY MODE
08/19/2019 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):
MATHEW@TEMMERMANLAW.COM
PTOL-90A (Rev. 04/07)
UNITED STATES PATENT AND TRADEMARK OFFICE
____________

BEFORE THE PATENT TRIAL AND APPEAL BOARD
____________

Ex parte RICHARD LOVE1
____________

Appeal 2018-006552
Application 13/573,795
Technology Center 3600
____________

Before JOHNNY A. KUMAR, DAVID C. McKONE,
and NORMAN H. BEAMER, Administrative Patent Judges.

McKONE, Administrative Patent Judge.

DECISION ON APPEAL
Appellant appeals under 35 U.S.C. § 134(a) from the Examiner’s final
rejection of claims 1–24 which constitute all the claims pending in this
application. Final Act. 1; Br. 6.2 We have jurisdiction under 35 U.S.C.
§ 6(b).
We AFFIRM.

1 The real party in interest is AP Technology, LLC.
2 In this Decision, we refer to the November 16, 2016, Final Action, the
September 15, 2017, Appeal Brief, and the January 8, 2018, Examiner’s
Answer. Appellant did not file a Reply Brief.
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THE INVENTION
Appellant’s invention relates to “systems and methods for providing
electronic check payments without the use of paper checks.” Spec. ¶ 2.
Figure 3 is reproduced below:

Figure 3 is a pair of flow diagrams depicting a traditional method for check
payment processing 200 and a method for electronic virtual check payment
processing 300 corresponding to the invention. Id. ¶¶ 14, 38.
In conventional method 200, a paper check is created in operation
210, delivered to the payee via the mail in operation 220, and deposited in
operation 230. Id. ¶¶ 38–39. The check is cleared in operation 240, which
involves converting the check into images and transferring the images
between banks and clearing houses. Id. ¶ 40.
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In electronic virtual check payment processing 300, corresponding to
the invention, operation 310 creates a check as an image containing key
payment fields such as payee name, amount, payment date, and signature,
and prepares it for presentment to the payee or the payee’s bank. Id. ¶ 41.
The check is delivered electronically to the payee in operation 320. Id. ¶ 42.
The check is deposited in operation 330 and cleared in operation 340. Id.
As part of the process, information from bank check 500 having a generic
check background is merged with payor information to create electronic
virtual check 700. Id. ¶ 53, Figs. 5–7.
Claim 1, reproduced below (additional formatting supplied), is
illustrative of the invention:
1. A system for creating and delivering a business-to-
business electronic virtual check payments, comprising:
a computing device electronically coupled to a non-
transitory computer readable medium having computer
executable program code embodied thereon, the computer
executable program code configured to cause a computing
device to:
upload check payment information from a Payor to an
electronic virtual check Payment Platform, the
check payment information comprising key check
payment data fields, wherein the Payment Platform
is an Internet-cloud application and is accessible
by both the Payor and a Payee;
obtain check payment data by parsing out key check
payment data fields of the check payment
information;
obtain an authorization signature from the Payor’s
computing device;
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create a digitally signed electronic virtual check image
containing secure image technology using check
payment data and the authorized signature; and
send a link to the electronic virtual check Payment
Platform to the Payee to allow the Payee access to
the electronic virtual check image.

THE REJECTION
Claims 1–24 stand rejected under 35 U.S.C. § 101 as directed to
patent-ineligible subject matter. Final Act. 2–6.

ANALYSIS
I. Principles of Law
An invention is patent-eligible if it claims a “new and useful process,
machine, manufacture, or composition of matter.” 35 U.S.C. § 101.
However, the Supreme Court has long interpreted § 101 to include implicit
exceptions: “[l]aws of nature, natural phenomena, and abstract ideas” are
not patentable. 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 Alice
and Mayo. See 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.”
Id. 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.”).
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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);
mathematical formulas (Parker v. Flook, 437 U.S. 584, 594–95 (1978)); and
mental processes (Gottschalk v. Benson, 409 U.S. 63, 67–68 (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 183 n.7 (quoting Corning v. Burden, 56
U.S. 252, 267–68 (1853))); 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.”). 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 turn to the second
step of the Alice and Mayo framework, where “we must examine the
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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. “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. (alterations in original) (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
§ 101. See USPTO, 2019 Revised Patent Subject Matter Eligibility
Guidance, 84 Fed. Reg. 50 (Jan. 7, 2019) (“Guidance”).3 Under that
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 activities such as a fundamental economic practice, or mental
processes); and
(2) additional elements that integrate the judicial exception into a
practical application (see MPEP §§ 2106.05(a)–(c), (e)–(h) (9th ed.
Rev. 08.2017, Jan. 2018)).
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
§ 2106.05(d)); or

3 We note that the Guidance was not available to the Examiner and
Appellant during the prosecution of the instant Application.
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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.
See Guidance, 84 Fed. Reg. at 56.

II. The Examiner’s Rejection
The Examiner finds that “[t]he claims are directed to the abstract idea
of check payments (electronic payment),” which the Examiner finds is a
fundamental economic practice. Final Act. 3–5. The Examiner further finds
that the additional elements in the claims “are simply a generic recitation of
a computer and a computer network performing their generic computer
functions” and “amount[] to no more than stating make a payment with a
virtual check on a computer and send it over a network.” Id. at 5.
Accordingly, the Examiner finds, the claims do no amount to significantly
more than the abstract idea itself. Id. at 6.
Appellant argues that the claims are similar to those found by a panel
of the Board to be eligible in the Institution Decision in U.S. Bancorp v.
Solutran, Inc., Case CBM2014-00076 (PTAB Aug. 7, 2014) (Paper 16).
Br. 8. According to Appellant, “the claims in the present application do not
recite an abstract idea but are instead directed to a concept inextricably tied
to computer technology and distinct from the types of concepts found to be
abstract.” Id. at 9. Appellant further argues that the claims recite additional
elements that amount to significantly more than the abstract idea found by
the Examiner. Id. at 10–12.

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III. Judicial Exception (Step 2A, Prong 14)
Viewing the Examiner’s rejection through the lens of the Guidance,
we first consider whether the claim recites a judicial exception. Guidance,
84 Fed. Reg. at 51. The PTO has synthesized the key concepts identified by
the courts as abstract ideas into three primary subject-matter groupings:
mathematical concepts, certain methods of organizing human activities (e.g.,
a fundamental economic practice), and mental processes. Id. at 52. As
explained below, claim 1 recites a certain method of organizing human
activity (a fundamental economic practice), which is a concept identified by
the Guidance as an abstract idea. Id.
The Examiner finds that “[t]he claims are directed to the abstract idea
of check payments (electronic payment),” which the Examiner finds is a
fundamental economic practice. Final Act. 3–5. According to the
Examiner, “[w]hile the claims do not explicitly recite ‘making an electronic
payment,’ the concept of ‘making an electronic payment,’ is described by
the ‘obtaining check payment data by . . . data fields of the check payment
information; obtaining an authorization signature from the Payor . . . ;
creating . . . the . . . check image . . . ; . . . allow the Payee access to the . . .
check . . . ’ steps.” Id. at 4. The Examiner finds that “[t]he creation of a
payment on a financial relationship as recited in the claim is a commercial
arrangement involving relations similar to the fundamental economic

4 The Guidance refers to “Step One” as determining whether the claimed
subject matter falls within the four statutory categories identified by
35 U.S.C. § 101: process, machine, manufacture, or composition of matter.
This step is not at issue here, as Appellant’s claims recite systems
(machines), methods (processes), and non-transitory, computer-readable
media (articles of manufacture).
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practices, certain methods of organizing human activity and idea itself as
found by the courts to be abstract ideas” in various cases such as buySAFE,
Inc. v. Google, Inc., 765 F.3d 1350 (Fed. Cir. 2014), Bilski v. Kappos, 130
S.Ct. 3218 (2010), and Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709 (Fed.
Cir. 2014). Id.
Claim 1 recites a computing device executing program code to
perform 1) uploading check payment information, with key check payment
data fields, from a Payor to a Payment Platform on the cloud; 2) obtaining
check information by parsing the data fields; 3) obtaining an authorization
signature from the Payor’s computer; 4) creating a digitally signed check
image with the check information and signature; and 5) sending a link to the
Payment Platform to the Payee of the check so that the Payee can access the
check image. Here, claim 1 recites generating electronic check payments,
along with steps of gathering input data and providing a way to view the
results. Appellant himself characterizes the invention similarly, arguing
that:
Similar to the claims in US. Bancorp v. Solutran, Inc. for
processing a physical check, the present claims are directed to
creating and delivering electronic virtual check payments. As
such, at its core, the basic concept behind the present claims is a
method for processing electronic virtual check payments,
which, as PTAB concluded, does not have any indication that
“it is directed to an abstract idea at all.”
Br. 8 (quoting U.S. Bancorp, Case CBM2014-00076, Paper 16, slip op. at
13).
We agree with Appellant that the claims recite creating and delivering
electronic virtual check payments. We find that this is a fundamental
economic practice, one of the examples of certain methods of organizing
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human activity enumerated in the Guidance. We disagree with Appellant,
however, that the case law shows this concept to be not abstract.
Although the panel decision in U.S. Bancorp declined to institute a
trial as to the eligibility of certain claims dealing with electronic checks, a
district court and the Federal Circuit later addressed the eligibility of those
same claims. Specifically, the District Court followed the reasoning of the
Board (PTAB) panel and the Federal Circuit reversed, holding that the
claims were nonstatutory. See Solutran, Inc. v. Elavon, Inc., 2019-1345,
2019 WL 3418471, *2, *6 (Fed. Cir. July 30, 2019). In particular, the
Federal Circuit determined that “[c]rediting a merchant’s account as early as
possible while electronically processing a check is a concept similar to those
determined to be abstract by the Supreme Court in Bilski . . . and Alice” and
that “[t]he desire to credit a merchant’s account as soon as possible is an
equally long-standing commercial practice.” Id. at *4. The Federal Circuit
compared those claims to the claims in Content Extraction & Transmission
LLC v. Wells Fargo Bank, National Association, 776 F.3d 1343 (Fed. Cir.
2014), stating that the Content Extraction court “held that a method of
extracting and then processing information from hard copy documents,
including paper checks, was drawn to the abstract idea of collecting data,
recognizing certain data within the collected data set, and storing that
recognized data in a memory.” Id.
As Appellant acknowledges (Br. 8), claim 1 is similar to those in
Solutran determined to recite an abstract idea. It also is similar to those
claims in Content Extraction determined to be abstract. See 776 F.3d at
1347 (“The concept of data collection, recognition, and storage is
undisputedly well-known. Indeed, humans have always performed these
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functions. And banks have, for some time, reviewed checks, recognized
relevant data such as the amount, account number, and identity of account
holder, and stored that information in their records.”).
Accordingly, we find that claim 1 recites an abstract idea, namely a
certain method of organizing human activity (a fundamental economic
practice).

IV. “Directed to” the Judicial Exception (Step 2A, Prong 2)
Because the claims recite an abstract idea, we now proceed to
determine whether the recited judicial exception is integrated into a practical
application. See Guidance, 84 Fed. Reg. at 51. Specifically, we look to
“whether the claim recites additional elements that integrate the exception
into a practical application of that exception.” Id. at 54. Limitations that are
indicative of integration into a practical application include additional
elements that reflect an improvement in the functioning of a computer, or an
improvement to other technology or technical field. Id. at 55. When a claim
recites a judicial exception and fails to integrate the exception into a
practical application, the claim is “directed to” the judicial exception. Id. at
51.
The Examiner finds that the additional elements of claim 1 recite “a
computing device with a program code configured to perform the receiving,
converting and sending steps,” and that the computing device “is recited at a
high level of generality and only performs generic functions of manipulating
payment information and transmitting that information as a payment to a
Payee.” Final Act. 5. According to the Examiner, “[t]he payment platform
limitations and web server limitations are simply a field of use that attempt
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to limit the abstract idea to a particular technological environment,” and
“[t]he type of information being manipulated does not impose meaningful
limitations or render the idea less abstract.” Id. The Examiner further finds
that “[t]he instant claimed invention is a computer technology solution to a
financial/business problem (fraud control),” and that “Appellant is using the
digitization of signatures in creating a digital check to attempt to circumvent
fraud,” i.e., “[a]utomating a manual process.” Ans. 11.
Appellant argues that the claims “are . . . directed to a concept
inextricably tied to computer technology and distinct from the types of
concepts found to be abstract.” Br. 9. Rather, Appellant contends, “the
solutions presented by the claimed systems and methods are necessarily
rooted in computer technology to address a problem specifically pertaining
to check payments.” Id. In particular, Appellant argues:
The claimed systems and methods remove the need for a
business to manually issue a check and sign it live by allowing
retailers to upload check payment information to an electronic
virtual check Payment Platform, obtaining check payment data,
obtaining retailer’s authorization signature, creating a digitally
signed electronic virtual check image, and sending a link to the
electronic virtual check Payment Platform to the Payee to allow
the Payee access to the electronic virtual check image.
Id.
The Federal Circuit, however, evaluating admittedly similar claims,
held that using computers to speed up the crediting of a merchant’s account
did not constitute an improvement to the way computers operate. See
Solutran, 2019 WL 3418471, at *4 (distinguishing the claims from those in
Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016)). This is
consistent with the Examiner’s finding that “[t]he instant specification
appears to be trying to solve the problem of sharing banking information
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with the Payor and to make the set up on the process faster by using a
digitally signed electronic version of a check.” Ans. 11. Similarly, the
claims in Content Extraction were directed to the “basic concept of data
recognition and storage” despite being recited as implemented using generic
computer components. 776 F.3d at 1347. See also buySAFE, 765 F.3d at
1354 (“Neither ‘attempting to limit the use of [the idea] to a particular
technological environment’ nor a ‘wholly generic computer implementation’
is sufficient.” (quoting Alice, 134 S.Ct. at 2358)); Ultramercial, 772 F.3d at
716 (“Narrowing the abstract idea of using advertising as a currency to the
Internet is an ‘attempt[ ] to limit the use’ of the abstract idea ‘to a particular
technological environment,’ which is insufficient to save a claim.” (quoting
Alice, 134 S.Ct. at 2358)). In claim 1, “a computing device,” “computer
readable medium,” and “computer executable program code” are recited
generically. The Specification confirms that the invention can be
implemented on a wide variety of generic computers. Spec. ¶ 69 (desktops,
laptops, PDAs, palmtops, mainframes, servers, etc.). As the comparison
reflected in Figure 3 (reproduced above) shows, the invention is directed to
using generic computers simply to automate an existing check clearing
process. Id. ¶ 38. Appellant does not point to anything in the claims or the
Specification that suggests an improvement to the employed computers or to
check-clearing or other technology.
We agree with the Examiner that, rather than integrating the abstract
idea into a practical application, “the additional elements are simply a
generic recitation of a computer and a computer network preforming their
generic computer functions,” and that “[t]his amounts to no more than
receiving check payment information electronically by sending across a
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network and exchanging for payment.” Ans. 8. Thus, claim 1 merely recites
computers that function as tools to carry out the abstract idea. Nothing in
the claim recites an improvement in the functioning of a computer, or an
improvement to other technology or a technical field. Accordingly, claim 1
does not integrate the recited abstract idea into a practical application.

V. Inventive Concept (Step 2B)
To determine whether a claim provides an inventive concept, the
additional elements are considered—individually and in combination—to
determine whether they (1) add a specific limitation beyond the judicial
exception that is not “well-understood, routine, conventional” in the field or
(2) simply append well-understood, routine, conventional activities
previously known to the industry, specified at a high level of generality, to
the judicial exception. Guidance, 84 Fed. Reg. at 56. Also, we reevaluate
our conclusions about the additional elements discussed in the previous step.
Id.
As explained above, the Examiner finds that the additional limitations
recited in claim 1 do not amount to significantly more than the abstract idea.
Final Act. 5. The Examiner further finds that the recitations of data
transmission, reception, and manipulation are via generic computer
equipment performing generic computing functions. Id.
Appellant contends that the Examiner “overgeneralizes” the features
of the claims and that, when viewed at the proper level of specificity, the
claims recite additional features that improve the technical field of check
payment. Br. 11–12. In particular, the aspects Appellant contends are
unconventional and/or meaningful limitations include “uploading check
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payment information, obtaining check payment data, obtaining an authorized
signature, creating a digitally signed electronic virtual check using payment
data and the authorized signature, and sending an access link to the
electronic virtual check a Payee.” Id. at 12. Appellant argues that these
aspects make the claims much more limited than the abstract idea articulated
by the Examiner. Id. (citing Ex Parte Barous, Appeal No. 2016-003320,
(PTAB, Aug. 1, 2016)).
The Specification, however, describes these aspects as conventional.
Figure 3, for example, shows creating, delivering, depositing, and clearing a
check to be a routine and conventional activity. Spec. ¶¶ 38–40. The
Specification describes automating that conventional process using generic
computer equipment. Id. ¶¶ 41–42. The Specification describes “an
electronic virtual check payment system” that includes a web based
application, a database, a file processing engine, printer drivers, a Web
services interface, an imaging interface, an email notification manager, and a
print engine, all described generically and at a high level. Id. ¶¶ 50–51.
Payment data and check images are captured and merged, at an eVC
Payment Platform, using generically described “eVC Software” and “Cloud
eVC application.” Id. ¶¶ 54–60. The Specification is clear that the
invention can be implemented with a wide variety of conventional computer
equipment used in a conventional manner. Id. ¶¶ 67–75. Like the claims in
Solutran, “the steps of the claim are conventional processes for processing
checks electronically.” 2019 WL 3418471 at *5; see also id. (“Any
remaining elements in the claims, including use of a scanner and computer
and ‘routine data-gathering steps’ (i.e., receipt of the data file), have been
deemed insufficient by this court in the past to constitute an inventive
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concept.” (quoting Content Extraction, 776 F.3d at 1349)); Ultramercial,
772 F.2d at 716 (“[T]he use of the Internet is not sufficient to save otherwise
abstract claims from ineligibility under § 101. . . . Narrowing the abstract
idea of using advertising as a currency to the Internet is an ‘attempt[ ] to
limit the use’ of the abstract idea ‘to a particular technological environment,’
which is insufficient to save a claim.” (quoting Alice, 134 S.Ct. at 2358)).
Appellant also argues that the novelty of the instant claims, reflected
in the lack of art-based rejections, evidences that they are not conventional.
Br. 12. However, the Federal Circuit has “previously explained that merely
reciting an abstract idea by itself in a claim—even if the idea is novel and
non-obvious—is not enough to save it from ineligibility.” Solutran, 2019
WL 3418471 at *6; see also Ultramercial, 772 F.3d at 716 (“That some of
the eleven steps were not previously employed in this art is not enough—
standing alone—to confer patent eligibility upon the claims at issue.”).
Thus, this argument is not persuasive.
On this record, the limitations of claim 1, considered individually and
in combination, do not provide an inventive concept.

VI. Claims 2–24
The Examiner rejects independent claims 5, 9, 13, 17, and 21 for the
same reasons as claim 1, noting that “claims 1, 5, 9, 13, 17 and 21 are
parallel claims and have been treated as such with the explanations relevant
for the independent claims as the methods claims do not add significant
structure and are further processes being performed by/ the
method/medium.” Final Act. 6.
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Claim 5 recites uploading check payment information using a mobile
phone application, claim 9 recites uploading information generated by a
computer accounting system, and claims 17 and 21 are method claims
reciting steps similar to the functions provided by the computer-readable
media of claims 1 and 9, respectively. Otherwise, we agree that all of the
independent claims recite substantially the same subject matter. Appellant
acknowledges that “[i]ndependent Claims 5, 9, 13, 17, and 21 recite similar
limitations.” Br. 11. For the same reasons as given for claim 1, we agree
with the Examiner that claims 5, 9, 13, 17, and 21 do not recite statutory
subject matter.
The Examiner finds that dependent claims 2–4, 6–8, 10–12, 14–16,
18–20, and 22–24 do not add any limitations that would render the claims
eligible. Final Act. 6. Indeed, these claims merely add insignificant pre-
and post-solution activity such as logging into the Payment Platform,
downloading a printing check images, and authorizing the Payment Platform
to deposit the electronic virtual check payment. Appellant does not present
separate argument for the dependent claims. For the same reasons as given
for claim 1, we agree with the Examiner that claims 2–4, 6–8, 10–12, 14–16,
18–20, and 22–24 do not recite statutory subject matter.

VII. Conclusion
We sustain the rejection of claims 1–24 under 35 U.S.C. § 101.

DECISION
We affirm the Examiner’s decision to reject claims 1–24 under 35
U.S.C. § 101.
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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