Sarath K. BalachandranDownload PDFPatent Trials and Appeals BoardMay 11, 202014268357 - (D) (P.T.A.B. May. 11, 2020) Copy Citation 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. 14/268,357 05/02/2014 Sarath K. BALACHANDRAN 9610/12203 5627 32642 7590 05/11/2020 STOEL RIVES LLP - SLC 201 SOUTH MAIN STREET, SUITE 1100 ONE UTAH CENTER SALT LAKE CITY, UT 84111 EXAMINER SUBRAMANIAN, NARAYANSWAMY ART UNIT PAPER NUMBER 3695 NOTIFICATION DATE DELIVERY MODE 05/11/2020 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): patlaw@stoel.com PTOL-90A (Rev. 04/07) UNITED STATES PATENT AND TRADEMARK OFFICE ____________ BEFORE THE PATENT TRIAL AND APPEAL BOARD ____________ Ex parte SARATH K. BALACHANDRAN ____________ Appeal 2018-008329 Application 14/268,357 Technology Center 3600 ____________ Before ANTON W. FETTING, PHILIP J. HOFFMANN, and TARA L. HUTCHINGS, Administrative Patent Judges. FETTING, Administrative Patent Judge. DECISION ON APPEAL STATEMENT OF THE CASE1 Sarath K. Balachandran (Appellant2) seeks review under 35 U.S.C. § 134 of a final rejection of claims 2–11 and 18–27, the only 1 Our decision will make reference to the Appellant’s Appeal Brief (“Appeal Br.,” filed April 25, 2018) and Reply Brief (“Reply Br.,” filed August 22, 2018), and the Examiner’s Answer (“Ans.,” mailed June 26, 2018), and Final Action (“Final Act.,” mailed September 25, 2017). 2 We use the word “Appellant” to refer to “applicant” as defined in 37 C.F.R. § 1.42. Appellant identifies the real party in interest as ATS TOLLING LLC (Appeal Br. 1). Appeal 2018-008329 Application 14/268,357 2 claims pending in the application on appeal. We have jurisdiction over the appeal pursuant to 35 U.S.C. § 6(b). The Appellant invented a way of automating the processing of vehicular violations and, more particularly, automating the processing of vehicular violations involving vehicles operated, for example, by a fleet operator or a rental-car agency. Specification para. 2. An understanding of the invention can be derived from a reading of exemplary claim 2, which is reproduced below (bracketed matter and some paragraphing added). 2. A computing device of a violation processing entity, comprising: [0.1] a first communication interface configured to receive, from a device of a vehicle rental or lease entity, rental or lease agreement data including unique vehicle identifiers of rental or lease vehicles of the vehicle rental or lease entity and identifiers of responsible parties for the rental or lease vehicles; [0.2] one or more data storage devices configured to store the rental or lease agreement data; and [0.3] one or more processors operably coupled to the one or more data storage devices and configured to: [1] compare identification data identifying a violating vehicle from a violation notice to the unique vehicle identifiers of the rental or lease vehicles of the vehicle rental or lease entity; and [2] if the identification data matches one of the unique vehicle identifiers: [2.1] identify a responsible one of the responsible parties that is responsible for one of the rental or lease vehicles that corresponds to a matching one of the unique vehicle identifiers; and Appeal 2018-008329 Application 14/268,357 3 [2.2] charge the responsible one of the responsible parties for the violation notice, or cause the first communication interface to transmit violation data to the device of the vehicle rental or lease entity to enable the rental or lease entity to charge the responsible one of the responsible parties for the violation notice, the violation data identifying the responsible one of the responsible parties. Claims 2–11 and 18–27 stand rejected under 35 U.S.C. § 101 as directed to a judicial exception without significantly more.3 ISSUES The issues of eligible subject matter turn primarily on whether the claims recite more than abstract conceptual advice of results desired. ANALYSIS STEP 14 Claim 2, as a device claim, nominally recites one of the enumerated categories of eligible subject matter in 35 U.S.C. § 101. The issue before us is whether it is directed to a judicial exception without significantly more. Although claim 2 is nominally a device claim, the only structure recited is a preliminary context composed of three generic conventional computing system devices. The remaining bulk of claim 2 recites procedural steps typical of a method claim. Thus, the substantive parts of the claim are method steps and we will refer to claim 2 as a method claim from here on for that reason. 3 A non-statutory double patenting rejection (Final Act. 12) was withdrawn. Ans. 3. 4 For continuity of analysis, we adopt the steps nomenclature from 2019 Revised Patent Subject Matter Eligibility Guidance, 84 Fed. Reg. 50 (Jan. 7, 2019) (“Revised Guidance”). Appeal 2018-008329 Application 14/268,357 4 STEP 2 The Supreme Court set forth a framework for distinguishing patents that claim laws of nature, natural phenomena, and abstract ideas from those that claim patent-eligible applications of those concepts. First, . . . determine whether the claims at issue are directed to one of those patent-ineligible concepts. If so, we then ask, “[w]hat else is there in the claims before us? To answer that question, . . . consider the elements of each claim both individually and “as an ordered combination” to determine whether the additional elements “transform the nature of the claim” into a patent- eligible application. [The Court] described step two of this analysis as a search for an “‘inventive concept’”—i.e., an element or combination of elements that is “sufficient to ensure that the patent in practice amounts to significantly more than a patent upon the [ineligible concept] itself.” Alice Corp. v. CLS Bank Int’l, 573 U.S. 208, 217–18 (2014) (citations omitted) (citing Mayo Collaborative Servs. v. Prometheus Labs, Inc., 566 U.S. 66 (2012)). To perform this test, we must first determine what the claims are directed to. This begins by determining whether the claims recite one of the judicial exceptions (a law of nature, a natural phenomenon, or an abstract idea). Then, if the claims recite a judicial exception, determining whether the claims at issue are directed to the recited judicial exception, or whether the recited judicial exception is integrated into a practical application of that exception, i.e., that the claims “apply, rely on, or use the judicial exception in a manner that imposes a meaningful limit on the judicial exception, such that the claim is more than a drafting effort designed to monopolize the judicial exception.” Revised Guidance, 84 Fed. Reg. at 54. If the claims are directed to a judicial exception, then finally determining whether the claims provide an inventive concept because the Appeal 2018-008329 Application 14/268,357 5 additional elements recited in the claims provide significantly more than the recited judicial exception. STEP 2A Prong 1 At a high level, and for our preliminary analysis, we note that method claim 2 recites receiving data, comparing data, if data matches, then identifying a party, and charging the party directly or indirectly. Comparing data and identifying data are rudimentary data analysis. Charging a party is transmitting data regarding a charge. Thus, claim 2 recites receiving, analyzing, and transmitting data. None of the limitations recite technological implementation details for any of these steps, but instead recite only results desired by any and all possible means. There is an additional prefatory limitation of providing components of a computing apparatus, but this is no more than reciting the computer context for the steps recited. The limitations listed are high level functional descriptions of what modules and data the system would provide, and so only serve to recite labels for the hardware and software that perform the subsequent steps. From this we see that claim 2 does not recite the judicial exceptions of either natural phenomena or laws of nature. Under Supreme Court precedent, claims directed purely to an abstract idea are patent in-eligible. As set forth in the Revised Guidance, which extracts and synthesizes key concepts identified by the courts, abstract ideas include (1) mathematical concepts,5 (2) certain methods of organizing 5 See, e.g., Gottschalk v. Benson, 409 U.S. 63, 71–72 (1972); Bilski v. Kappos, 561 U.S. 593, 611 (2010); Mackay Radio & Telegraph Co. v. Radio Corp. of Am., 306 U.S. 86, 94 (1939); SAP America, Inc. v. InvestPic, LLC, 898 F.3d 1161, 1163 (Fed. Cir. 2018). Appeal 2018-008329 Application 14/268,357 6 human activity,6 and (3) mental processes.7 Among those certain methods of organizing human activity listed in the Revised Guidance are commercial or legal interactions. Like those concepts, claim 2 recites the concept of applying vehicle violation penalties. Specifically, claim 2 recites operations that would ordinarily take place in advising one to charge a penalty to a party identified on a rental or lease agreement. The advice to charge a penalty to a party identified on a rental or lease agreement involves charging the responsible one of the responsible parties for the violation notice, which is an economic act, and identifying a responsible one of the responsible parties, which is an act ordinarily performed in the stream of commerce. For example, claim 2 recites “charge the responsible one of the responsible parties for the violation notice,” which is an activity that would take place whenever one is applying a vehicular penalty. Similarly, claim 1 recites “identify a responsible one of the responsible parties,” which is also characteristic of applying a vehicular penalty. The Examiner determines the claims to be directed to processing violation notices. Final Act. 3. The preamble to claim 2 recites that it is a device of a violation processing entity. The steps in claim 2 result in charging someone for a 6 See, e.g., Bilski, 561 U.S. at 628; Alice, 573 U.S. at 219–20; Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709, 715 (Fed Cir. 2014); Smart Sys. Innovations, LLC v. Chicago Transit Auth., 873 F.3d 1364, 1383 (Fed. Cir. 2017); In re Marco Guldenaar Holding B.V., 911 F.3d 1157, 1160–61 (Fed. Cir. 2018). 7 See, e.g., Benson, 409 U.S. at 67; CyberSource Corp. v. Retail Decisions, Inc., 654 F.3d 1366, 1371–72 (Fed. Cir. 2011); Intellectual Ventures I LLC v. Symantec Corp., 838 F.3d 1307, 1318 (Fed. Cir. 2016). Appeal 2018-008329 Application 14/268,357 7 violation absent any technological mechanism other than a conventional computer for doing so. As to the specific limitations, limitation 0.1 recites receiving data. Limitations 1 and 2 recite generic and conventional analyzing and transmitting of vehicular violation data, which advise one to apply generic functions to get to these results. The limitations thus recite advice for charging a penalty to a party identified on a rental or lease agreement. To advocate charging a penalty to a party identified on a rental or lease agreement is conceptual advice for results desired and not technological operations. The Specification at paragraph 2 describes the invention as relating to automation of processing of vehicular violations and, more particularly, automation of processing of vehicular violations involving vehicles operated, for example, by a fleet operator or a rental-car agency. Thus, all this intrinsic evidence shows that claim 2 recites applying vehicle violation penalties. This is consistent with the Examiner’s determination. This in turn is an example of commercial or legal interactions as a certain method of organizing human activity because vehicular violations are legal penalties applied using commercial practices. The concept of applying vehicle violation penalties by charging a penalty to a party identified on a rental or lease agreement is one idea for charging a party. The steps recited in claim 2 are part of how this might conceptually be premised. Our reviewing court has found claims to be directed to abstract ideas when they recited similar subject matter. Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 1367 (2015) (tracking financial Appeal 2018-008329 Application 14/268,357 8 transactions); Credit Acceptance Corp. v. Westlake Services, 859 F.3d 1044, 1054 (2017) (processing a financial application). From this we conclude that at least to this degree, claim 2 recites applying vehicle violation penalties by charging a penalty to a party identified on a rental or lease agreement, which is a commercial and legal interaction, one of certain methods of organizing human activity identified in the Revised Guidance, and, thus, an abstract idea. STEP 2A Prong 2 The next issue is whether claim 2 not only recites, but is more precisely directed to this concept itself or whether it is instead directed to some technological implementation or application of, or improvement to, this concept i.e. integrated into a practical application.8 At the same time, we tread carefully in construing this exclusionary principle lest it swallow all of patent law. At some level, “all inventions ... embody, use, reflect, rest upon, or apply laws of nature, natural phenomena, or abstract ideas.” Thus, an invention is not rendered ineligible for patent simply because it involves an abstract concept. “[A]pplication[s]” of such concepts “‘to a new and useful end,’” we have said, remain eligible for patent protection. Accordingly, in applying the § 101 exception, we must distinguish between patents that claim the “‘buildin[g] block[s]’” of human ingenuity and those that integrate the building blocks into something more. Alice, 573 U.S. at 217 (citations omitted). Taking the claim elements separately, the operation performed by the computer at each step of the process is expressed purely in terms of results, devoid of implementation details. Limitation 0.2 recites a pure data 8 See, e.g., Alice, 573 U.S. at 223, discussing Diamond v. Diehr, 450 U.S. 175 (1981). Appeal 2018-008329 Application 14/268,357 9 gathering step. Limitations describing the nature of the data do not alter this. Limitation 0.1 recites conventional data transmission. Limitation 0.3 recites a generic processor to perform the steps. Steps 1 and 2 recite generic computer processing expressed in terms of results desired by any and all possible means and so present no more than conceptual advice. All purported inventive aspects reside in how the data is interpreted and the results desired, and not in how the process physically enforces such a data interpretation or in how the processing technologically achieves those results. Viewed as a whole, Appellant’s claim 2 simply recites the concept of applying vehicle violation penalties by charging a penalty to a party identified on a rental or lease agreement as performed by a generic computer. This is no more than conceptual advice on the parameters for this concept and the generic computer processes necessary to process those parameters, and do not recite any particular implementation. Claim 2 does not, for example, purport to improve the functioning of the computer itself. Nor does it effect an improvement in any other technology or technical field. The 10 pages of Specification do not bulge with disclosure, but only spell out different generic equipment9 and parameters that might be applied using this concept and the particular steps such conventional processing would entail based on the concept of applying vehicle violation penalties by charging a penalty to a party identified on a 9 The Specification does not describe requirements for a computer and does not recite the word “computer.” Claim 2 recites generic processors, although the original filed Specification and claims did not describe processors. Figure 6 portrays the Rental Reservation System as a conventional personal computer. Appeal 2018-008329 Application 14/268,357 10 rental or lease agreement under different scenarios. They do not describe any particular improvement in the manner a computer functions. Instead, claim 2 at issue amounts to nothing significantly more than an instruction to apply vehicle violation penalties by charging a penalty to a party identified on a rental or lease agreement using some unspecified, generic computer. Under our precedents, that is not enough to transform an abstract idea into a patent-eligible invention. See Alice, 573 U.S. at 225–26. None of the limitations reflect an improvement in the functioning of a computer, or an improvement to other technology or technical field, applies or uses a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition, implements a judicial exception with, or uses a judicial exception in conjunction with, a particular machine or manufacture that is integral to the claim, effects a transformation or reduction of a particular article to a different state or thing, or applies or uses the judicial exception in some other 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. We conclude that claim 2 is directed to achieving the result of applying vehicle violation penalties by advising one to charge a penalty to a party identified on a rental or lease agreement, as distinguished from a technological improvement for achieving or applying that result. This amounts to a commercial or legal interaction, which falls within certain methods of organizing human activity that constitute abstract ideas. The claim does not integrate the judicial exception into a practical application. Appeal 2018-008329 Application 14/268,357 11 STEP 2B The next issue is whether claim 2 provides an inventive concept because the additional elements recited in the claim provide significantly more than the recited judicial exception. The introduction of a computer into the claims does not generally alter the analysis at Mayo step two the mere recitation of a generic computer cannot transform a patent-ineligible abstract idea into a patent-eligible invention. Stating an abstract idea “while adding the words ‘apply it’” is not enough for patent eligibility. Nor is limiting the use of an abstract idea “‘to a particular technological environment.’” Stating an abstract idea while adding the words “apply it with a computer” simply combines those two steps, with the same deficient result. Thus, if a patent’s recitation of a computer amounts to a mere instruction to “implemen[t]” an abstract idea “on . . . a computer,” that addition cannot impart patent eligibility. This conclusion accords with the preemption concern that undergirds our § 101 jurisprudence. Given the ubiquity of computers, wholly generic computer implementation is not generally the sort of “additional featur[e]” that provides any “practical assurance that the process is more than a drafting effort designed to monopolize the [abstract idea] itself.” Alice, 573 U.S. at 223–24 (citations omitted). “[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.” Id. at 225. They do not. Taking the claim elements separately, the function performed by the computer at each step of the process is purely conventional. Using a computer for receiving, analyzing, and transmitting data amounts to electronic data query and retrieval—one of the most basic functions of a Appeal 2018-008329 Application 14/268,357 12 computer. All of these computer functions are generic, routine, conventional computer activities that are performed only for their conventional uses. See Elec. Power Grp. LLC v. Alstom S.A., 830 F.3d 1350, 1353 (Fed. Cir. 2016). See also In re Katz Interactive Call Processing Patent Litig., 639 F.3d 1303, 1316 (Fed. Cir. 2011) (“Absent a possible narrower construction of the terms ‘processing,’ ‘receiving,’ and ‘storing,’ . . . those functions can be achieved by any general purpose computer without special programming”). None of these activities is used in some unconventional manner nor does any produce some unexpected result. Appellant does not contend it invented any of these activities. In short, each step does no more than require a generic computer to perform generic computer functions. As to the data operated upon, “even if a process of collecting and analyzing information is ‘limited to particular content’ or a particular ‘source,’ that limitation does not make the collection and analysis other than abstract.” SAP America, Inc. v. InvestPic LLC, 898 F.3d 1161, 1168 (Fed. Cir. 2018). Considered as an ordered combination, the computer components of Appellant’s claim 2 add nothing that is not already present when the steps are considered separately. The sequence of data reception-analysis- transmission is equally generic and conventional. See Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709, 715 (Fed. Cir. 2014) (sequence of receiving, selecting, offering for exchange, display, allowing access, and receiving payment recited an abstraction), Inventor Holdings, LLC v. Bed Bath & Beyond, Inc., 876 F.3d 1372, 1378 (Fed. Cir. 2017) (sequence of data retrieval, analysis, modification, generation, display, and transmission), Two-Way Media Ltd. v. Comcast Cable Communications, LLC, 874 F.3d 1329, 1339 (Fed. Cir. 2017) (sequence of processing, routing, controlling, Appeal 2018-008329 Application 14/268,357 13 and monitoring). The ordering of the steps is therefore ordinary and conventional. We conclude that claim 2 does not provide an inventive concept because the additional elements recited in the claim do not provide significantly more than the recited judicial exception. REMAINING CLAIMS Claim 2 is representative. The other independent claims are substantially similar at least as regards this analysis. The remaining dependent claims merely describe process parameters. We conclude that the claims at issue are directed to a patent-ineligible concept itself, and not to the practical application of that concept. As to those remaining structural claims, they are no different from the method claims in substance. The method claims recite the abstract idea implemented on a generic computer; the system claims recite a handful of generic computer components configured to implement the same idea. This Court has long “warn[ed] . . . against” interpreting § 101“in ways that make patent eligibility ‘depend simply on the draftsman’s art.’” Alice, 573 U.S. at 226. As a corollary, the claims are not directed to any particular machine. LEGAL CONCLUSION From these determinations we further determine that the claims do not recite an improvement to the functioning of the computer itself or to any other technology or technical field, a particular machine, a particular transformation, or other meaningful limitations. From this we conclude the claims are directed to the judicial exception of the abstract idea of certain methods of organizing human activity as exemplified by the commercial and Appeal 2018-008329 Application 14/268,357 14 legal interaction of applying vehicle violation penalties by advising one to charge a penalty to a party identified on a rental or lease agreement, without significantly more. APPELLANT’S ARGUMENTS As to Appellant’s Appeal Brief arguments, we adopt the Examiner’s determinations and analysis from pages 2–11 of the Final Action and pages 3–12 of the Answer and reach similar legal conclusions. We now turn to the Reply Brief. We are not persuaded by Appellant’s argument that “[c]laim 2 is [s]imilar to [c]laim 1 of Example 34 [a]mounting to a [t]echnical [i]mprovement in the [t]echnical [f]ield of [a]utomatic [v]iolation [p]rocessing.” Reply Br. 24 (emphasis omitted). Appellant refers to the Examiner’s alleged failure to follow Office guidelines. See Reply Br. 29– 34. However, any failure by the Examiner to follow the Director’s guidance is appealable only to the extent that the Examiner has failed to follow the statutes or case law. That is, to the extent the Director’s guidance goes beyond the case law and is more restrictive on the Examiner than the case law, failure of the Examiner to follow those added restrictions is a matter for petition to the Director. We review Appellant’s particular arguments against the case law and find no requirement in the law that restricts “abstract ideas” to only those particular concepts that the courts have identified already as an abstract idea explicitly. As we determine supra, the claims are within the scope of what the courts have found to be abstract ideas. We further direct Appellant’s attention to the Office’s notation that Example 34 is based on the Federal Circuit's findings in BASCOM (BASCOM Global Internet v. AT&T Mobility LLC, 827 F.3d 1341 (Fed. Cir. Appeal 2018-008329 Application 14/268,357 15 2016)). Subject Matter Eligibility Examples: Business Methods, Example 34. Initially, we remind Appellant that BASCOM did not find claims eligible on the substance, but rather that the Appellees did not provide sufficient evidence to support a 12(b)(6) motion to dismiss in which facts are presumed in the non-movant’s favor. The key fact in BASCOM was the presence of a structural change in “installation of a filtering tool at a specific location, remote from the end- users, with customizable filtering features specific to each end user. This design gives the filtering tool both the benefits of a filter on a local computer and the benefits of a filter on the ISP server.” BASCOM, 827 F.3d at 1350. The instant claims have no analogous structural benefit. This structural change occurred in the context of the internet as it existed at filing in March 1997 when dial up internet service was still prevalent. It was not the idea of having user customizable filtering located separately from the user that was inventive, but the manner of accomplishing it in that context, as the relatively primitive internet architecture at that time did not readily lend itself to such filtering. Filtering located separately from the user was already performed. “To overcome some of the disadvantages of installing filtering software on each local computer, another prior art system relocated the filter to a local server.” Id. at 1344. But it was known that allowing user customization there was desirable. “However, the one-size-fits-all filter on the local server was not ideal.” Id. The BASCOM filter was invented prior to the now prevalent use of self-identifying devices with media access control (MAC) addresses. Thus, absent that, “BASCOM explains that the inventive concept rests on taking advantage of the ability of at least some ISPs to identify individual accounts that Appeal 2018-008329 Application 14/268,357 16 communicate with the ISP server, and to associate a request for Internet content with a specific individual account.” Id. Thus, BASCOM solved the problem of how to create the structural relationship known to be desired by finding a way to relate a user to a centrally located filter at a time when how to do so was unclear. It was not the structural relation per se, but how it was accomplished that was inventive. No analogous technological hurdle is described in the instant record. Indeed the whole point of Appellant’s claimed invention appears to be simply to use existing data communications technology to communcate vehicular violations information by automatically transmitting such information. We are not persuaded by Appellant’s argument that “claim 2 amounts to an improvement in the technology of automatic violation processing.” Reply Br. 26. Claim 2 presents an improvement in information flow, not computer technology. “[T]the claims are focused on providing information to traders in a way that helps them process information more quickly, not on improving computers or technology. . . . The “tool for presentation” here . . . is simply a generic computer.” Trading Techs. Int’l, Inc. v. IBG LLC, 921 F.3d 1378, 1384–85 (Fed. Cir. 2019) (citations omitted). We are not persuaded by Appellant’s argument that “the use of the computing device of the violation processing entity as a device that is separate from the device of the vehicle rental or lease entity removes the dependence on vehicle rental or lease entity devices.” Reply Br. 27. Simply distributing processes was conventional distributed processing, which inherently removed dependence among processes by such distribution.10 10 As an example of distributed processing being conventional, see e.g., Appeal 2018-008329 Application 14/268,357 17 We are not persuaded by Appellant’s argument that “the Examiner failed to meet the burden to show that the combination of elements of [c]laim 2 were well-known routine and conventional.” Reply Br. 29–30. Support for this determination is provided supra under Step 2B. CONCLUSIONS OF LAW The rejection of claims 2–11 and 18–27 under 35 U.S.C. § 101 as directed to a judicial exception without significantly more is proper. CONCLUSION The rejection of claims 2–11 and 18–27 is affirmed. In summary: Claims Rejected 35 U.S.C. § Basis Affirmed Reversed 2–11, 18–27 101 Eligibility 2–11, 18–27 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. § 1.136(a)(1)(iv) (2011). AFFIRMED Storp, S. Open Distributed Processing, II: Proceedings of the IFIP TC6/WG6.1 International Conference on Open Distributed Processsing, Berlin, Germany, 13–16 September, 1993. Netherlands: North-Holland. https://www.google.com/books/edition/Open_distributed_processing_II/NLI ZAQAAIAAJ Copy with citationCopy as parenthetical citation