Obviousness

The US patent 8083137, titled "Administration of financial accounts," concerns a system and method that enables users to establish self-imposed, category-based spending limits for financial transactions and to receive notifications or view summary data related to these limits. The patent also describes features for managing sub-users and customizing categories.

An analysis under 35 U.S.C. § 103 for obviousness requires identifying prior art references that, individually or in combination, teach all the limitations of the claimed invention, and demonstrating a motivation for a person having ordinary skill in the art (POSA) to combine these references. The priority date for US8083137B2 is 2002-07-09.

Key Elements of the Independent Claims (Claims 1, 5, 12, 19) of US8083137B2:

1. Storing a profile keyed to a user identity.
2. One or more user-selected categories to track transactions associated with said user identity.
3. Individual user-selected categories include a user pre-set limit.
4. Presenting/causing communication of transaction summary data for at least one category, containing said at least one user-selected category's user pre-set limit.
5. (Claim 12 specific) Transaction summary data configured to be presented in a table.
6. (Claim 19 specific) Listing financial transactions for a last accounting period in accordance with user-selected categories, and presenting the amount of financial transactions in an individual user-selected category together with a user-identified category limit.

Prior Art References and Relevant Disclosures (Prior to 2002-07-09):

1. US6353811B1 (Weissman): "Credit card billing system for identifying expenditures on a credit card account."

   • Priority Date: 1998-11-18
   • Relevant Disclosure: Teaches a credit card billing system that identifies expenditures by category and provides a categorized statement of expenditures to the cardholder. This directly addresses the concept of tracking transactions by category and presenting summary data.

2. US5914472A (At&T Corp): "Credit card spending authorization control system."

   • Priority Date: 1997-09-23
   • Relevant Disclosure: Discloses a credit card spending authorization control system that stores a credit card number and an authorized spending limit associated with the credit card number. This teaches the concept of pre-set spending limits.

3. US5953710A (Fleming): "Children's credit or debit card system."

   • Priority Date: 1996-10-09
   • Relevant Disclosure: Describes a system for children's credit/debit cards where an account profile for each child specifies a spending limit and a list of permitted merchants. Permitted merchants represent a form of category control, and the system involves sub-users with specific limits.

4. US5845260A (Sony Corporation): "System and method for parent-controlled charging for on-line services."

   • Priority Date: 1995-02-06
   • Relevant Disclosure: Teaches a system where a main user (e.g., parent) can set a limit on online services for a sub-user. This is relevant to sub-user management and setting limits for specific types of services (categories).

5. US5991750A (Ge Capital): "System and method for pre-authorization of individual account transactions."

   • Priority Date: 1997-10-24
   • Relevant Disclosure: Discusses a system for pre-authorization of individual account transactions, where a user can pre-authorize transactions for a specific amount or category. This explicitly mentions category-specific limits.

6. US5999596A (Walker Asset Management Limited): "Method and system for controlling authorization of credit card transactions."

   • Priority Date: 1998-03-06
   • Relevant Disclosure: Describes a system where a cardholder can set spending limits for specific types of transactions or merchants. This also shows category-based spending controls.

Obviousness Combinations and Rationale:

A person having ordinary skill in the art (POSA) in financial systems would have been motivated to combine elements from these prior art references to create a system as claimed in US8083137B2, to address the known problem of users needing more granular control and better real-time information about their spending. The motivation stems from a predictable desire to enhance financial management tools.

Combination 1: US6353811B1 (Weissman) + US5914472A (At&T Corp)

• Rationale: Weissman teaches the categorization of expenditures and the presentation of categorized statements to a user. At&T Corp teaches setting a general spending limit for a credit card. A POSA would have found it obvious to combine these two known functionalities. Once expenditures are categorized (Weissman), it would be a predictable and logical step to apply the existing concept of spending limits (At&T Corp) to these individual categories. This would allow users to set "user pre-set limits" on "user-selected categories" (or system-defined categories that can be adopted by the user) and then view their spending against these limits in transaction summary data. This combination directly anticipates the core features of claims 1, 5, 12, and 19. The presentation of data "in a table" (Claim 12) is a common way to display financial summaries, and a POSA would readily implement this.

Combination 2: US6353811B1 (Weissman) + US5991750A (Ge Capital) / US5999596A (Walker Asset Management Limited)

• Rationale: Weissman provides the capability to categorize and present financial transactions. Ge Capital explicitly describes setting transaction limits by category, and Walker also teaches setting spending limits for specific types of transactions or merchants. Combining the detailed categorization and reporting from Weissman with the explicit category-based limit-setting mechanisms of Ge Capital or Walker would be an obvious improvement. The motivation would be to provide a comprehensive financial management system where users can not only see their spending broken down by category but also actively control it with pre-set, category-specific limits. This combination would clearly lead to a system that stores user-selected categories with pre-set limits and presents summary data including these limits.

Combination 3: US6353811B1 (Weissman) + US5953710A (Fleming) / US5845260A (Sony Corporation)

• Rationale: To address the aspects of US8083137B2 related to sub-users (Claims 4, 8, 15, 22, 23), a POSA would combine the categorical expenditure tracking of Weissman with systems designed for sub-user control, such as Fleming's children's credit card system (with spending limits and permitted merchants) or Sony's parent-controlled online service charging (with limits for sub-users). The motivation would be to extend existing sub-account management, which already includes overall spending limits or merchant restrictions, to allow for more precise control based on item or transaction categories. For example, a parent using Fleming's system might want to not just limit a child's spending to certain merchants, but to also limit spending on specific types of goods within those merchants (e.g., food but not electronics).

Motivation for User-Selected/Customized Categories (e.g., Claim 24):

Even if initial systems offered pre-defined categories (as implied by Weissman), the desire for user customization in financial tools was well-understood. The detailed description of US8083137B2 itself highlights this motivation: "a user could decide that clothes from certain stores, or certain types of clothing, such as sporting clothes, would go under a sporting category," and "a user could switch the natural category for, say ice cream... to a profile category of snack, if desired." This shows a clear recognition in the art of the desirability of user-configurable categories. Granting users the ability to modify default category assignments (Claim 24) is a natural evolution for personalized budgeting.

Overall Conclusion:

The various claims of US8083137B2, concerning the administration of financial accounts through user-defined, category-based spending limits and the presentation of associated summary data, including for sub-users, would have been obvious to a person having ordinary skill in the art by combining existing prior art. References such as US6353811B1 (Weissman) taught transaction categorization and reporting, while patents like US5914472A (At&T Corp), US5991750A (Ge Capital), US5999596A (Walker Asset Management Limited), US5953710A (Fleming), and US5845260A (Sony Corporation) taught various forms of spending limits and controls, including category-specific limitations and sub-user management. The motivation to combine these elements would have been to provide consumers with more granular, user-friendly financial management tools, which was a clear trend in the financial services industry at the time.