Obviousness

US Patent 10121186, titled "System and method of using a browser application programming interface for making payments," concerns innovations aimed at simplifying online purchases, improving Internet navigation, and unifying search functionalities. The effective prior art date for this patent is March 31, 2014 [cite: "Priority date (The priority date is an assumption and is not a legal conclusion. Google has not performed a legal analysis and makes no representation as to the accuracy of the date listed.) 2014-03-31"]. A person having ordinary skill in the art (PHOSITA) in this field, at the time of the invention, would be a software engineer or developer knowledgeable in e-commerce, web browser technologies, and online payment systems.

The patent itself identifies several existing technologies and problems that its innovations seek to address, which serve as foundational implicit prior art for this obviousness analysis.

Identified Prior Art (from the patent's own description):

1. Amazon.com one-click purchasing: A system enabling users to make purchases without manually re-entering payment and address data within the Amazon.com ecosystem. [cite: "Some sites like Amazon.com provide a “one-click” purchasing option but those simplifications are only available in the controlled Amazon.com environment."]
2. Safari's omnikey feature: A browser functionality allowing users to type a query like "amazon headphones" into the browser's input field to directly search a specified third-party site (e.g., Amazon.com) for the given terms. [cite: "One effort to make this transition was provided by the omnikey feature of Safari."]
3. General browser input/search fields: Standard web browsers with input fields in the header for searching the Internet, often configurable with a default search engine (e.g., Google, Yahoo). [cite: "browsers often have input fields in the header portion which can be used for searching the Internet. Users can select whether a default search engine for that input field is google.com, yahoo.com or other search engine."]
4. Deep linking: The practice of linking to specific content within a website or application, rather than just the homepage. This was a known web development technique to improve user navigation.
5. Buy buttons on non-merchant sites: Features on social networking sites (e.g., Google, Facebook, Instagram) or other non-merchant platforms that allow users to initiate purchases directly from those sites. [cite: "buttons on such sites as google.com, facebook.com, instagram.com, say.com, bing.com, yahoo.com, youtube.com, amazon.com and twitter.com a specific challenge arises in terms of tracking purchases.", "the goal of buy buttons on various sites is to enable purchases in those “micro-moments” when a person using social media such as Facebook or Instagram, and see something they might want to buy."]
6. Online payment services (e.g., PayPal, Apple Pay): Established platforms for processing electronic payments, often providing APIs for integration with third-party merchants. [cite: "an interface with PayPal® or Apple Pay is provided such that purchases can be easily processed."]
7. Storage of user payment data by online entities: Sites like Google.com maintain user purchase information, including credit card details. [cite: "sites like google.com maintain purchase information such as credit card or payment account information."]
8. Contextual advertising and user intent determination: Search engines and ad platforms analyze user queries and behavior to infer whether the user has informational intent (e.g., "Paul Revere American revolution") or commercial/purchase intent (e.g., "iPhone 5S 32 GB silver") and deliver relevant content or advertisements.
9. Centralized purchase history: Services like Amazon.com provide users with an account to view and manage their purchase history, albeit limited to their own platform. [cite: "The ability to manage a user account and history of purchases on such a site is considerably easier."]

Obviousness Combinations

1. Browser Payment Request API for Generalized One-Click Purchasing via Deep Links

Claimed Invention (exemplary elements): A method including receiving an interaction from a user with an object (e.g., buy button) on a first site presented within a browser, transitioning the user from the first site to a destination merchant site in a deep link state, where the deep link state enables the user to purchase a product via an interaction with a purchase object without manually entering payment account data or user address data. The method further involves retrieving data from the browser automatically via a browser payment request application programming interface (API) between the destination merchant site and the browser. [cite: "a method aspect includes receiving an interaction from a user with an object associated with an advertisement for a product or any kind of notice, the advertisement or notice being presented via a first site presented within a browser, and transitioning the user from the first site to a destination merchant site in a deep link state.", "the transitioning process includes retrieving data from the browser and using the data from the browser to enable the user to transition from the first site to the destination merchant site in the deep link state.", "the deep link state enables the user to purchase the product via an interaction with a purchase object without manually entering payment account data or user address data.", "Retrieving data from the browser can occur automatically via a browser payment request application programming interface between the destination merchant site and the browser."]

Combination of Prior Art:

• Amazon.com one-click purchasing (Primary Reference): Teaches the core concept of purchasing with minimal interaction (e.g., one click) by leveraging stored user payment and address data. [cite: "Some sites like Amazon.com provide a “one-click” purchasing option but those simplifications are only available in the controlled Amazon.com environment."]
• Buy buttons on non-merchant sites (Secondary Reference 1): Teaches initiating a purchase intention from a "first site" (e.g., a social media ad or a search result with a buy option). [cite: "buttons on such sites as google.com, facebook.com, instagram.com, say.com, bing.com, yahoo.com, youtube.com, amazon.com and twitter.com a specific challenge arises in terms of tracking purchases."]
• Deep linking (Secondary Reference 2): A known technique for directing users to specific pages within a website, enabling a "deep link state" to a product page.
• Browser autofill/storage of user data (Secondary Reference 3): Browsers already had capabilities to store and autofill user information, including address and payment details, in web forms.
• Online payment services and their APIs (e.g., PayPal, Apple Pay) (Secondary Reference 4): These services demonstrated the use of APIs for secure transfer of payment information to facilitate online transactions. [cite: "an interface with PayPal® or Apple Pay is provided such that purchases can be easily processed."]

Motivation to Combine: A PHOSITA would be motivated to extend the convenience of Amazon's one-click purchasing beyond its proprietary ecosystem, as the patent itself highlights this limitation [cite: "Some sites like Amazon.com provide a “one-click” purchasing option but those simplifications are only available in the controlled Amazon.com environment."]. Recognizing that users frequently encounter purchase opportunities on "first sites" (e.g., social media feeds or search results) that are not the final merchant destination, a PHOSITA would seek to streamline the transition to a merchant site for purchase. It would be obvious to combine the initiation of a purchase from a "first site" (like a buy button on Facebook) with deep linking to take the user directly to the relevant product page on the merchant site. To achieve a true "one-click" experience on the destination site, it would be a predictable extension to leverage user data already stored or accessible by the browser (like autofill data or through a browser extension) and transfer this data securely using a browser payment request API. Such an API would be an obvious development given the existence of general web APIs for data exchange and specialized payment APIs (like PayPal's), aiming to standardize and simplify the process of populating payment fields or directly processing payments. This combination would predictably reduce user friction and improve conversion rates for online purchases initiated from various "first sites."

2. Unified Input Field with Purchase Intent Determination

Claimed Invention (exemplary elements): A method including presenting an input field on a user interface of a generalized search entity, receiving user input (a text-based query), correlating the query with a product database, determining if the user input is associated with a search intent or a purchase intent, and presenting a purchase-related search result comprising a buy option associated with the user input, or a search result including a non-merchant site. [cite: "a method includes presenting an input field on a user interface of a generalized search entity, such that the generalized search entity processes data using a generalized search engine.", "the search engine indexes and searches both merchant sites and non-merchant sites and receives user input in the input field", "the user input includes a text-based query", "the search engine correlates the text-based query with a product database of products for sale from merchants to produce a correlation.", "a determination is made that the user input is associated with one of a search intent and a purchase intent.", "a purchase-related search result comprising a buy option associated with the user input is presented."]

Combination of Prior Art:

• General browser input/search fields and search engines (Primary Reference): Teaches accepting user input for search queries and returning results (e.g., Google, Yahoo). [cite: "browsers often have input fields in the header portion which can be used for searching the Internet. Users can select whether a default search engine for that input field is google.com, yahoo.com or other search engine."]
• Safari's omnikey feature (Secondary Reference 1): Teaches using a single input field to target searches to specific third-party sites based on explicit user input (e.g., "amazon headphones"). [cite: "One effort to make this transition was provided by the omnikey feature of Safari."]
• Contextual advertising and user intent determination (Secondary Reference 2): Search engines and advertising platforms were already proficient at analyzing user queries to infer whether the user has informational intent (e.g., "Paul Revere American revolution") or commercial/purchase intent (e.g., "iPhone 5S 32 GB silver") and displaying relevant ads or product listings.
• Dynamic presentation of options/autocomplete (Secondary Reference 3): Autocomplete features in search bars and dynamic menus that appear as a user types were common, presenting suggestions or alternative actions.

Motivation to Combine: A PHOSITA would be motivated to enhance the efficiency and intelligence of generalized search fields, particularly in the context of e-commerce. Recognizing the limitations of existing browser search fields (e.g., needing explicit prefixes like in Safari's omnikey, or defaulting to a single search engine) [cite: "the problem with this approach is that it is likely easier to click on an amazon tab and type headphones in the Amazon search field than it is to type amazon at the beginning of the search."], it would be obvious to integrate advanced intent determination. By combining a general input field with the existing capability of search engines to determine user intent (search vs. purchase) based on query semantics, and the ability to present dynamic options (e.g., in a drop-down menu or autocomplete list) based on that intent, the system could directly link to either a general search result or a purchase-ready option on a merchant site (potentially using deep linking and one-click concepts). This combination would predictably provide a more user-friendly and efficient experience, allowing users to move from initial query to desired action (information retrieval or product purchase) with fewer steps and greater relevance.

3. Cross-Site Purchase Management Engine

Claimed Invention (exemplary elements): A purchase management engine receiving conversion data about purchases made through various buy buttons (e.g., Google Buy Button, Facebook Buy Button, Amazon.com purchases) and correlating this data into a single user account that spans multiple purchasing platforms. [cite: "an API that is designed to communicate information to and from multiple different types of sites that currently manage purchases individually.", "the API can receive conversion data about purchases made through the Google Buy Button (Purchases on Google), the Facebook Buy Button, the Pinterest Buy Button, Amazon.com purchases, and so forth.", "a purchase management engine receives the various pieces of data and correlates the data into a single user account that spans multiple purchasing platforms."]

Combination of Prior Art:

• Centralized purchase history (Amazon.com) (Primary Reference): Teaches the concept of a user account managing purchase history, returns, reorders, etc., but limited to a single merchant. [cite: "The ability to manage a user account and history of purchases on such a site is considerably easier."]
• Buy buttons on non-merchant sites (Secondary Reference 1): Teaches that purchases can originate from numerous distinct online platforms, leading to dispersed purchase records. [cite: "buttons on such sites as google.com, facebook.com, instagram.com, say.com, bing.com, yahoo.com, youtube.com, amazon.com and twitter.com a specific challenge arises in terms of tracking purchases.", "the goal of buy buttons on various sites is to enable purchases in those “micro-moments” when a person using social media such as Facebook or Instagram, and see something they might want to buy."]
• APIs for data sharing between services (Secondary Reference 2): Teaches that disparate online services can exchange data (e.g., user activity, transaction details) via application programming interfaces.
• Centralized user accounts for online services (Secondary Reference 3): Major online platforms (Google, Facebook) offer central user accounts that aggregate user data and activity across various affiliated services.

Motivation to Combine: A PHOSITA would be motivated to address the "difficulty of managing purchases spread across uncoordinated, disparate sites" [cite: "presenting buy options at non-merchant sites to take advantage of such micro-moments introduces the difficulty of managing purchases spread across uncoordinated, disparate sites."]. Recognizing the growing number of ways users can make purchases online (e.g., via buy buttons on social media, direct merchant sites), and the user frustration associated with fragmented purchase histories [cite: "A user may forget where a purchase was made and may feel frustrated when they cannot manage purchases or review their purchase history."], it would be obvious to develop a centralized management solution. This would involve extending the known concept of a single-merchant purchase history (like Amazon's) and leveraging existing APIs for data exchange to gather "conversion data" from various independent purchase sources (e.g., Google Buy Button, Facebook Buy Button, Amazon.com). Aggregating and correlating this data into a single, unified user account is a common pattern in data aggregation and dashboard development, making it a predictable application of known techniques to solve a well-identified problem in user experience. The patent explicitly states its aim to solve the problem of managing purchases across "uncoordinated, disparate sites" and creating a "single user account that spans multiple purchasing platforms." [cite: "the present approach differs from the amazon.com user account because it is maintained only for purchases made at amazon.com and not for purchases from different types of sites such as google.com or facebook.com."]