PTAB

CBM2016-00088

Plaid Technologies, Inc. v. Yodlee, Inc.

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1. Case Identification

2. Patent Overview

  • Title: Categorization of Summarized Information
  • Brief Description: The ’535 patent describes computer-implemented systems and methods for automatically collecting, categorizing, and summarizing a user's transaction information from third-party websites. The system uses past transaction history to predict future statistical information.

3. Grounds for Unpatentability

Ground 1: Patent Ineligibility under §101 - Claims 1-10 are ineligible under 35 U.S.C. §101.

  • Core Argument for this Ground: Petitioner argued the claims are directed to patent-ineligible subject matter under the two-step framework from Alice Corp. v. CLS Bank.
    • Alice Step 1 (Abstract Idea): Petitioner asserted that the claims are directed to the abstract idea of (1) categorizing and summarizing past financial transactions, and (2) using that information to predict future transactions. This was characterized as a longstanding and fundamental economic practice, analogous to concepts found unpatentable in cases like Intellectual Ventures v. Capital One. Petitioner contended that limiting the abstract idea to the context of the internet or financial data does not make it patent-eligible.
    • Alice Step 2 (Inventive Concept): Petitioner argued the claims lack an inventive concept, merely adding instructions to implement the abstract idea using generic and conventional computer components. The claims recite functional elements like a "collection function" and "processing function" on a generic "computer system" or "computer-readable medium" without specifying any novel technological improvement. Petitioner maintained that automating these well-known business practices on a general-purpose computer does not transform the abstract idea into a patentable invention.

Ground 2: Obviousness over Schutzer, Knoblock, and Lazarus - Claims 1, 5, 6, and 10 are obvious over the combination of references.

  • Prior Art Relied Upon: Schutzer (Patent 5,920,848), Knoblock (a 1998 publication titled “Modeling Web Sources for Information Integration”), and Lazarus (Patent 6,430,539).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that the combination of Schutzer, Knoblock, and Lazarus teaches all limitations of the challenged claims. Schutzer taught an integrated financial system with "intelligent agents" that collect, categorize, and report a user's financial data from multiple bank servers, allowing queries by date and expense category. To supply elements Schutzer arguably lacks, Petitioner argued Knoblock taught an information-agent system that automatically navigates to and parses data from multiple third-party web sources, while Lazarus taught a system for analyzing historical transaction data to predict future spending using probability-based algorithms to create and update merchant categories ("description characteristics").
    • Motivation to Combine: A POSITA would combine Schutzer's financial aggregation system with Knoblock's automated web-scraping technology to improve the efficiency and scope of data collection, which is a known technique to improve a similar system. Further, a POSITA would be motivated to enhance Schutzer's system with Lazarus's predictive analytics and probabilistic categorization to provide more advanced, automated financial insights, fulfilling Schutzer's stated goal of "automated classification."
    • Expectation of Success: A POSITA would have a reasonable expectation of success in combining these references, as it involved applying known data extraction and predictive analysis techniques to a well-understood financial aggregation framework to achieve predictable improvements.
    • Key Aspects: Petitioner argued that dependent claims 5 and 10, which add the limitation of reporting transactions "through the Internet network," are taught by Schutzer, which describes its system operating on a network like the internet and communicating with bank servers.

4. Key Claim Construction Positions

  • "collection function automatically navigating to and retrieving...": Petitioner proposed this term should be construed as "software that collects a natural person's transaction information from two or more websites, where for each website it parses a web page rendered by a browser." This construction was argued to be consistent with the specification and prosecution history, and it facilitates mapping the automated parsing taught by Knoblock onto Schutzer's system.
  • "a definition of purpose of transaction including at least expenditure types": Petitioner proposed this term means "a definition of a payee, account or other identifier associated with a transaction." This construction allows Schutzer's user-defined expense categories and query functions to satisfy this limitation.

5. Arguments Regarding CBM Qualification

(This petition was for CBM Review, which has specific qualification requirements distinct from standard IPR. This section summarizes Petitioner's arguments on that threshold issue.)

  • Financial Product or Service: Petitioner argued the ’535 patent qualifies as a covered business method (CBM) patent because its claims are directed to the practice, administration, or management of a financial product or service. The claims explicitly recite collecting and reporting "transactions" based on "expenditure types," and the specification describes applications like tracking checking accounts and credit cards, which are financial in nature.
  • Not a "Technological Invention": Petitioner contended the patent is not exempt from CBM review as a "technological invention." The argument was that the claims only recite generic computer hardware (e.g., "computer system") to perform non-technical business methods (categorizing and predicting spending). Petitioner asserted the claims do not solve a technical problem with a technical solution but rather use conventional technology as a tool to automate a fundamental economic practice.

6. Relief Requested

  • Petitioner requested the institution of a Covered Business Method review, the cancellation of claims 1-10 as unpatentable under 35 U.S.C. §101, and the cancellation of claims 1, 5, 6, and 10 as unpatentable under 35 U.S.C. §103.