PTAB

CBM2013-00008

MeridianLink Inc v. DH Holdings LLC

Title: System and method for interfacing a loan application with a plurality of lenders
Brief Description: The ’526 patent discloses a computer-based system for processing loan or credit applications. The system uses a "single-entry user interface" to receive application data once, formats it for various lenders, transmits it to their respective systems, and then receives and presents the lenders' responses to the user.

Prior Art Relied Upon: DeFrancesco (Patent 5,878,403).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that DeFrancesco discloses a "credit application clearinghouse" that performs the same functions as the system claimed in the ’526 patent. DeFrancesco’s system receives a single electronic credit application, which it then forwards to a plurality of credit providers (lenders) selected based on predetermined criteria. The system receives responses from these lenders and forwards them to the point of sale terminal. Petitioner contended this directly maps to the key limitations of independent claims 1, 8, and 15, including the "single-entry user interface," the "data processing system," and the steps of transmitting data to and receiving responses from multiple lender systems. Dependent claims were argued to be disclosed by DeFrancesco’s teaching of formatting data for different providers and using specific communication protocols like the internet.
- Motivation to Combine (for obviousness): Not applicable for anticipation. For the alternative obviousness argument, Petitioner asserted that any minor differences would have been obvious modifications to a person of ordinary skill in the art (POSITA).
- Expectation of Success (for obviousness): A POSITA would have a high expectation of success in implementing the claimed system, as DeFrancesco taught a functional, analogous system.

Prior Art Relied Upon: DeFrancesco (’403 patent) and Dykstra (Patent 6,029,149).
Core Argument for this Ground:
- Prior Art Mapping: This ground specifically addressed dependent claim 19, which adds the limitation of "electronically pre-populating at least a portion of the data fields of a loan application form." Petitioner argued that while DeFrancesco provides the base system for processing loan applications with multiple lenders, Dykstra explicitly teaches the benefit and method of pre-populating electronic forms. Dykstra discloses retrieving customer information from a database and using it to automatically fill in corresponding fields on an electronic form, such as an insurance application.
- Motivation to Combine: A POSITA would combine Dykstra's well-known pre-population technique with DeFrancesco’s clearinghouse system for a predictable and compelling reason: to improve efficiency and accuracy. Automating data entry by pre-populating known information would save time for the user and reduce the likelihood of typographical errors, a known problem in the art that Dykstra was designed to solve.
- Expectation of Success: The combination was argued to be straightforward. Applying the established technique of pre-populating forms (Dykstra) to an online loan application system (DeFrancesco) involved using known programming methods and would have yielded predictable results.

Prior Art Relied Upon: Not applicable. This ground is based on patent-ineligible subject matter.
Core Argument for this Ground:
- Abstract Idea: Petitioner asserted that the claims of the ’526 patent are directed to the abstract idea of "processing a credit application," a fundamental and long-standing economic practice. The core concept involves gathering information from an applicant, providing it to multiple lenders, and collecting their offers—a process analogous to the services of a loan broker.
- No Inventive Concept: Petitioner argued that the claims fail to add an "inventive concept" sufficient to transform the abstract idea into a patent-eligible application. The claims merely recite implementing the abstract idea using generic computer components, such as a user interface, a data processing system, a network (the internet), and databases. The petition contended that using a computer to automate a fundamental business practice, without more, does not confer patentability. The recited steps were argued to be conventional and routine data-gathering and communication activities performed on a general-purpose computer.
Additional Grounds: Petitioner asserted parallel anticipation and obviousness challenges based on Gutzmer (Patent 5,991,748) as the primary reference, both alone and in combination with Dykstra, arguing Gutzmer similarly disclosed a multi-lender credit application processing system.

"single-entry user interface": Petitioner argued this term should be given its plain and ordinary meaning: an interface that allows a user to enter their application information a single time for submission to multiple lenders. This construction was central to the argument that prior art systems, which receive one application and route it to many lenders, meet this limitation, countering any potential argument by the Patent Owner that the term requires a specific, novel interface structure not present in the prior art.

Petitioner requested institution of a Covered Business Method Patent Review and cancellation of claims 1-5, 8-12, and 15-20 of the ’526 patent as unpatentable.