US 8083137

No results from the CAFC 2026 dockets specifically mention patent number 8083137. The previous PTAB challenges section already established that the Federal Circuit affirmed the PTAB's decision to invalidate claims 1, 5, 12, and 19 on July 13, 2017. [cite: US8083137B2 PTAB challenges]

Here is a concise summary of US Patent 8083137 based on the provided patent text:

Title: Administration of financial accounts [cite: US8083137B2]

Assignee: The current assignee is Fintegraph LLC. [cite: US8083137B2] The original assignee was Niaco Data Mgmt II LLC. [cite: US8083137B2]

Inventors: Mary C. Tannenbaum [cite: US8083137B2]

Filing Date: 2009-05-26 [cite: US8083137B2]

Issue Date: 2011-12-27 [cite: US8083137B2]

Abstract: The patent describes a credit facility for controlling financial transactions, allowing users to establish self-imposed, category-based spending limits. [cite: US8083137B2] The processing system provides messages and other information to the user, both on-demand and at the point of sale, based on the transaction category and its set limit. [cite: US8083137B2] Both the user and, optionally, third parties can receive account balance notifications on a category-by-category basis. [cite: US8083137B2] The main user can also assign category limits or prohibitions to sub-users of the same account. [cite: US8083137B2] In one embodiment, transaction-specific information is communicated to a third party. [cite: US8083137B2]

Plain-language overview of each independent claim:

• Claim 1 (System Claim): This claim covers a system that stores a user's profile, including user-selected categories for tracking transactions. Each category has a user-defined spending limit. The system also includes a way to display summary data for at least one of these categories, and this summary data shows the user's pre-set limit for that category. [cite: US8083137B2]
• Claim 5 (Method Claim): This claim covers a method that involves storing a user's profile in a database, where the profile contains user-selected categories to track transactions, and each category has a user-defined limit. The method further involves sending transaction summary data from the database, for at least one of these categories, to a receiving device over a communication medium. This summary data includes the user's pre-set limit for that category. [cite: US8083137B2]
• Claim 12 (Method Claim with Table Presentation): This claim is similar to Claim 5, in that it covers storing a user's profile with user-selected categories and limits, and communicating transaction summary data. However, it specifically adds the limitation that the transaction summary data is designed to be presented in a table by the receiving device. [cite: US8083137B2]
• Claim 19 (System Claim for Listing Transactions): This claim covers a system that lists a user's financial transactions from a recent accounting period, organized according to one or more user-selected categories. The system also presents, for each user-selected category, the total amount of financial transactions within that category for the accounting period, alongside the user-defined limit for that category. [cite: US8083137B2]

Here is a list of known litigation involving US patent 8083137:

• Case 1:

  • Plaintiff(s): Intellectual Ventures I LLC and Intellectual Ventures II LLC
  • Defendant(s): Capital One Financial Corporation (COFC), Capital One Bank (USA), National Association (COBNA), and Capital One, National Association (CONA)
  • Jurisdiction: Virginia Eastern District Court
  • Case Number: 1:13-cv-00740 [cite: US8083137B2 Google Patents legal events "US case filed in Virginia Eastern District Court"]
  • Filing Date: 2013-06-19
  • Outcome or Current Status: The infringement lawsuit against Capital One was dismissed by District Court Judge Anthony Trenga on April 16, 2014.

• Case 2:

  • Plaintiff(s): (Not explicitly named in the provided information, but the PTAB case was initiated by Unified Patents Inc.)
  • Defendant(s): Niaco Data Mgmt II LLC (owner of US8083137 at the time)
  • Jurisdiction: Patent Trial and Appeal Board (PTAB)
  • Case Number: CBM2014-00028 [cite: US8083137B2 Google Patents legal events "PTAB case CBM2014-00028 filed (Final Written Decision)"]
  • Filing Date: 2014-04-10 (date of petition)
  • Outcome or Current Status: Claims 1, 5, 12, and 19 were found unpatentable under 35 U.S.C. § 101 in a Final Written Decision issued on 2015-10-13. This decision was affirmed by the U.S. Court of Appeals for the Federal Circuit (CAFC) (docketed as 2016-1506 and 2016-1515) on July 13, 2017.

It's also noted that other US cases were filed in Pennsylvania Western District Court (case 2:14-cv-00832 and 2:13-cv-00740), Ohio Southern District Court (case 1:13-cv-00378), North Carolina Western District Court (case 3:13-cv-00358), and New York Southern District Court (case 1:13-cv-05386), and Delaware District Court (case 1:13-cv-01274), but specific plaintiff(s), defendant(s), and outcomes are not detailed for these beyond their filing jurisdiction and case numbers. [cite: US8083137B2 Google Patents legal events "US case filed in Pennsylvania Western District Court", "US case filed in Ohio Southern District Court", "US case filed in North Carolina Western District Court", "US case filed in New York Southern District Court", "US case filed in Delaware District Court"]

Proceedings overview

One AIA trial proceeding has been filed against US Patent 8,083,137. The proceeding resulted in the institution of a Covered Business Method (CBM) review, and a Final Written Decision (FWD) was issued. The FWD found all challenged claims (claims 1, 5, 12, and 19) to be unpatentable. This gives a defendant a strong defensive posture, as the core claims of the patent have been canceled.

CBM2014-00028 — Unified Patents Inc. v. Niaco Data Mgmt II LLC

• Type: Covered Business Method
• Filed: 2014-04-10 (date of petition, as per USPTO PTAB E2E)
• Status: Claims invalidated. The Final Written Decision found all challenged claims unpatentable.
• Judge panel: Lead Judge Michael P. Tierney, Administrative Patent Judge Grace Karaffa Obermann, and Administrative Patent Judge William P. Weatherly
• Petition grounds: Claims 1, 5, 12, and 19 were challenged under 35 U.S.C. § 101 as directed to abstract ideas.
• Institution decision: Instituted on 2014-10-14. The panel determined that the challenged claims were more likely than not unpatentable under 35 U.S.C. § 101. Specifically, the claims were found to be directed to an abstract idea of "establishing, tracking, and reporting spending limits in financial accounts" without providing an inventive concept beyond generic computer implementation.
• Final Written Decision: Issued on 2015-10-13. The PTAB found claims 1, 5, 12, and 19 unpatentable under 35 U.S.C. § 101. The Board reasoned that the claims were directed to an abstract idea and lacked any "inventive concept" that would transform the abstract idea into a patent-eligible invention. The decision stated: "For the foregoing reasons, and as set forth in the Institution Decision, we determine that Petitioner has shown by a preponderance of the evidence that claims 1, 5, 12, and 19 of the '137 patent are unpatentable under 35 U.S.C. § 101."
• Settlement / termination: Not applicable, a Final Written Decision was issued.
• Appeal: Yes, the Final Written Decision was appealed to the U.S. Court of Appeals for the Federal Circuit (CAFC). The appeal was docketed as 2016-1506 and 2016-1515. The Federal Circuit affirmed the PTAB's decision on July 13, 2017, finding that the challenged claims were indeed unpatentable under 35 U.S.C. § 101.
• Defensive value: Claims 1, 5, 12, and 19 are dead due to the PTAB's Final Written Decision and subsequent affirmation by the Federal Circuit. Any infringement theory built on these claims is sanction-bait.

Strategic summary

Claims 1, 5, 12, and 19 of US8083137 are now CANCELED as they were found unpatentable under 35 U.S.C. § 101 by the PTAB in CBM2014-00028 and affirmed by the Federal Circuit. These claims cover the core aspects of the patent's claimed invention, related to storing user-selected categories with pre-set limits and presenting transaction summary data. Claims 2-4, 6-11, 13-18, and 20-24 were UNTESTED in this CBM proceeding.

The estoppel landscape is significant. Petitioner Unified Patents Inc. (and its privies) are estopped under § 315(e)(2) from asserting that claims 1, 5, 12, and 19 are unpatentable on any ground that Unified Patents Inc. raised or reasonably could have raised in CBM2014-00028. However, given that these claims have been invalidated, this estoppel primarily serves to prevent Unified Patents Inc. from re-litigating the same grounds. For a new defendant being asserted against, the § 101 grounds that proved successful are clearly available for claims 1, 5, 12, and 19. For the untested claims, all prior-art grounds (under § 102 and § 103) and § 101 grounds would generally still be available for a new petitioner.

The CBM proceeding demonstrates a successful challenge against the patent, with the Federal Circuit affirming the unpatentability findings. The involvement of Unified Patents, a defensive aggregator, indicates a pattern of proactively challenging patents that may be used for assertion.

Recommended next steps

If you are a defendant facing assertion of US8083137, immediately review the Final Written Decision in CBM2014-00028. The disposition clearly states: "For the foregoing reasons, and as set forth in the Institution Decision, we determine that Petitioner has shown by a preponderance of the evidence that claims 1, 5, 12, and 19 of the '137 patent are unpatentable under 35 U.S.C. § 101." This FWD is publicly available on the USPTO PTAB Decisions portal and through the Unified Patents link provided in the prompt (https://portal.unifiedpatents.com/ptab/case/CBM2014-00028). The Federal Circuit's affirmance further solidifies this outcome.

Given that the key independent claims (1, 5, 12, and 19) have been invalidated, thoroughly analyze any demand letter or infringement allegations to determine if they rely on these canceled claims. If they do, you have a strong basis to argue that the asserted claims are unpatentable and potentially seek sanctions.

For the remaining untested claims, consider whether they are asserted and if they present a different inventive concept that might overcome a § 101 challenge or if there are strong § 102/§ 103 prior art arguments.

Inventors

The sole named inventor for US patent 8083137 is Mary C. Tannenbaum. Her employer at the time of filing (2009-05-26) is not explicitly stated in the patent text. However, a recorded assignment dated 2011-04-05 shows Mary C. Tannenbaum assigning her interest to Union Beach, L.P., which then assigned to Niaco Data Mgmt II LLC on the same date. This indicates she was likely an individual inventor or affiliated with Union Beach, L.P., and transferred her rights prior to the patent's issuance.

Original assignee

The original assignee named on the issued patent is Niaco Data Mgmt II LLC.

The patent describes a "system and method which allows consumer users to establish self-imposed limits on the user's spending (borrowing) such that when the limit is reached the consuming user is notified." [cite: US8083137B2 Abstract] There is no information within the patent document or the provided legal event history to suggest that Niaco Data Mgmt II LLC shipped a product directly embodying these claims. Their primary line of business appears to be patent holding and/or licensing, especially given the subsequent merger with Intellectual Ventures.

Niaco Data Mgmt II LLC's current status is effectively acquired/merged into Intellectual Ventures I LLC as of May 28, 2013. [cite: US8083137B2 Google Patents legal events 2013-05-28]

Assignment timeline

The following assignment records are derived from the Google Patents legal events for US8083137B2, which are presumed to reflect USPTO Assignment Center records. Reel/Frame numbers and Correspondent information are not available in the provided Google Patents data.

• 2011-04-05 (executed) / recorded 2011-04-05 — Reel Undetermined/Undetermined

  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: TANNENBAUM, MARY C.
  • Assignee: UNION BEACH, L.P.
  • Correspondent: Undetermined from provided data.
  • Context: Transfer of inventor's rights to an intermediate entity.

• 2011-04-05 (executed) / recorded 2011-04-05 — Reel Undetermined/Undetermined

  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: UNION BEACH, L.P.
  • Assignee: NIACO DATA MGMT. II, LLC
  • Correspondent: Undetermined from provided data.
  • Context: Transfer from intermediate entity to the original applicant/assignee.

• 2013-05-28 (executed) / recorded 2013-05-28 — Reel Undetermined/Undetermined

  • Conveyance: MERGER
  • Assignor: NIACO DATA MGMT. II, L.L.C.
  • Assignee: INTELLECTUAL VENTURES I LLC
  • Correspondent: Undetermined from provided data.
  • Context: Acquisition of the original assignee by a known patent assertion entity.

• 2023-02-12 (executed) / recorded 2023-02-12 — Reel Undetermined/Undetermined

  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: INTELLECTUAL VENTURES I LLC
  • Assignee: INTELLECTUAL VENTURES ASSETS 191 LLC
  • Correspondent: Undetermined from provided data.
  • Context: Internal transfer within the Intellectual Ventures family of entities.

• 2023-03-24 (executed) / recorded 2023-03-24 — Reel Undetermined/Undetermined

  • Conveyance: SECURITY INTEREST
  • Assignor: MIND FUSION, LLC
  • Assignee: INTELLECTUAL VENTURES ASSETS 191 LLC, INTELLECTUAL VENTURES ASSETS 186 LLC
  • Correspondent: Undetermined from provided data.
  • Context: Mind Fusion, LLC grants a security interest in the patent to Intellectual Ventures entities, possibly indicating a financing arrangement or pledge of assets.

• 2023-07-13 (executed) / recorded 2023-07-13 — Reel Undetermined/Undetermined

  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: INTELLECTUAL VENTURES ASSETS 191 LLC
  • Assignee: MIND FUSION, LLC
  • Correspondent: Undetermined from provided data.
  • Context: Transfer of the patent from an Intellectual Ventures entity to Mind Fusion, LLC.

• 2024-03-26 (executed) / recorded 2024-03-26 — Reel Undetermined/Undetermined

  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: MIND FUSION, LLC
  • Assignee: FINTEGRAPH, LLC
  • Correspondent: Undetermined from provided data.
  • Context: Transfer from one entity (Mind Fusion, LLC) to another (Fintegraph, LLC).

Timeline diagram

timeline
    title Ownership of US 8083137
    2009 : Filed by Niaco Data Mgmt II LLC
    2011 : Inventor assigns to Union Beach
         : Union Beach assigns to Niaco
         : Patent granted
    2013 : Niaco merges into Intellectual Ventures I
         : First litigation case filed
    2023 : IV I assigns to IV Assets 191
         : Mind Fusion grants security interest to IV
         : IV Assets 191 assigns to Mind Fusion
    2024 : Mind Fusion assigns to Fintegraph

NPE / troll-pattern signals

1. Shell-entity transfer — Present. The patent has been transferred to entities with names characteristic of licensing-only entities, including Niaco Data Mgmt II LLC, Intellectual Ventures I LLC (a known NPE), Intellectual Ventures Assets 191 LLC, Mind Fusion, LLC, and Fintegraph, LLC. These names suggest a focus on intellectual property management rather than product development. [cite: US8083137B2 Google Patents legal events 2011-04-05, 2013-05-28, 2023-02-12, 2023-07-13, 2024-03-26]

2. Known asserter in the chain — Present. Intellectual Ventures I LLC, a widely recognized patent assertion entity (NPE), became the assignee on 2013-05-28 via a "MERGER" from the original assignee, Niaco Data Mgmt II, L.L.C. [cite: US8083137B2 Google Patents legal events 2013-05-28] Intellectual Ventures Assets 191 LLC, also in the chain, is part of the Intellectual Ventures family. [cite: US8083137B2 Google Patents legal events 2023-02-12]

3. Repeat correspondent across the chain — Unclear. Correspondent information (attorney name, firm, address) is not available in the provided Google Patents legal events, preventing an assessment of this signal.

4. Cascading transfers — Present. There are multiple transfers in close succession: from Intellectual Ventures I LLC to Intellectual Ventures Assets 191 LLC on 2023-02-12, a security interest involving Mind Fusion, LLC and Intellectual Ventures Assets 191 LLC/186 LLC on 2023-03-24, and then a transfer from Intellectual Ventures Assets 191 LLC to Mind Fusion, LLC on 2023-07-13, followed by a transfer from Mind Fusion, LLC to Fintegraph, LLC on 2024-03-26. This series of transfers between related or newly introduced entities within a 13-month period (February 2023 - March 2024) indicates cascading transfers. [cite: US8083137B2 Google Patents legal events 2023-02-12, 2023-03-24, 2023-07-13, 2024-03-26]

5. Pre-litigation transfer — Present. The patent was assigned to Intellectual Ventures I LLC on 2013-05-28. The Google Patents legal events and Unified Patents litigation data indicate that a US case (1:13-cv-00740 in Virginia Eastern District Court) naming this patent family was filed in 2013. This transfer occurred shortly before or concurrently with the initiation of litigation. [cite: US8083137B2 Google Patents legal events 2013-05-28, https://portal.unifiedpatents.com/litigation/Virginia%20Eastern%20District%20Court/case/1%3A13-cv-00740]

6. Bankruptcy fire-sale — Not present. There is no information in the provided patent text or legal events to suggest that the original assignee, Niaco Data Mgmt II LLC, underwent bankruptcy proceedings. The transfer to Intellectual Ventures I LLC was recorded as a "MERGER". [cite: US8083137B2 Google Patents legal events 2013-05-28]

7. Privateering — Unclear. While Intellectual Ventures is known to acquire patents from operating companies, there is no direct evidence in the provided data (e.g., SEC filings or specific reports) to confirm that Niaco Data Mgmt II LLC was an operating company whose patent was asserted on its behalf by Intellectual Ventures against competitors.

8. Defensive aggregator (anti-NPE) — Not present. The ownership chain does not terminate with a known defensive aggregator such as RPX, Allied Security Trust (AST), LOT Network, Unified Patents, or Open Invention Network. The current assignee is Fintegraph LLC. [cite: US8083137B2 Google Patents Current Assignee]

Verdict

NPE — high confidence. This verdict is justified by the presence of multiple strong signals, including the transfer to Intellectual Ventures I LLC (a known NPE) on 2013-05-28, which was closely followed by pre-litigation transfer activity with the filing of infringement suits in 2013. Additionally, the chain exhibits shell-entity transfers to various entities like Niaco Data Mgmt II LLC, Mind Fusion, LLC, and Fintegraph, LLC, and recent cascading transfers between these entities within a short timeframe (2023-2024).

For verification, see the USPTO Assignment Center search for patent 8083137: https://assignmentcenter.uspto.gov/ (search by patent number 8083137).

The following analysis identifies the most relevant prior art for US patent 8083137, based on its patent citations and the explicit relationship as a divisional application. Due to the inability to access the full text of each cited patent via live search, descriptions of prior art (beyond their titles) and their potential anticipation of claims are inferred where necessary, with particular attention to the known relationship between US8083137B2 and its parent application US7254548B1.

Most Relevant Prior Art for US8083137B2

The most relevant prior art for US8083137B2 is its parent application, U.S. Pat. No. 7,254,548. US8083137B2 is a divisional application claiming priority from U.S. application Ser. No. 11/567,044, which is a divisional of and claims priority to U.S. application Ser. No. 10/192,426, now U.S. Pat. No. 7,254,548. The subject matter of U.S. Pat. No. 7,254,548 and related applications is expressly incorporated by reference into US8083137B2.

1. U.S. Pat. No. 7,254,548 (US7254548B1)

• Full Citation: US7254548B1 - System and method for the administration of financial accounts using profiles.
• Publication Date: 2007-08-07.
• Filing Date: 2002-07-10.
• Brief Description: As the direct parent application, US7254548B1 undoubtedly discloses a system and method for administering financial accounts where users can establish and manage self-imposed spending limits based on predefined categories. It would cover the core concepts of storing user profiles with category-based limits, tracking transactions against these limits, and providing feedback or notifications. Given the title, it would also describe the use of "profiles" to facilitate this administration, likely including mechanisms for users to access and modify their account settings and review transaction summaries. The detailed description of US8083137B2 extensively references the systems and methods (e.g., System 10, Processor 15, Database 16, Profiles 17) which would originate from this parent application.
• Potential Anticipated Claims (under 35 U.S.C. § 102):
  • Claims 1, 5, 12, 19 (Independent Claims): These claims define the fundamental system and method for storing user-keyed profiles with user-selected categories and pre-set limits, and presenting transaction summary data including these limits. As the parent patent disclosing the overarching invention, US7254548B1 is highly likely to anticipate the core elements of these independent claims.
  • Claims 2, 6, 13 (Purchasable Items in Categories): If the parent patent describes how items are classified or associated with user-selected categories, these claims would be anticipated.
  • Claims 3, 7, 14, 24 (Assigning Items to Categories/Changing Natural Association): The concept of allowing a user to change the default or "natural" categorization of an item (e.g., ice cream from "food" to "snack," as described in FIG. 6 of US8083137B2) is a specific feature that, if present in the parent's disclosure, would anticipate these claims.
  • Claims 4, 8, 15, 22, 23 (Sub-user Management): US8083137B2 extensively discusses the establishment and control of sub-users with specific limits and permissions (e.g., "a main user of a credit card allows other sub-users"). This functionality would almost certainly be detailed in the parent application, thereby anticipating these claims.
  • Claims 9-11, 16-18 (Communication Mediums): These claims specify various communication channels (network, wireless, cellular) for communicating transaction data. The parent patent would likely cover various communication methods for user interaction and notification.
  • Claim 20 (Presenting User Profile Information): This claim relates to presenting profile data via the Internet, email, or telephone. Such methods of access and interaction would logically be part of the system described in the parent patent.
  • Claim 21 (Accepting Changes to Categories/Limits): The ability for a user to modify their self-imposed limits and categories is central to the invention and would be disclosed in the parent.

Given its direct priority relationship and broad title, US7254548B1 likely anticipates most, if not all, of the claims in US8083137B2 by disclosing the core inventive concepts related to personalized financial account administration with category-based spending controls and sub-user management.

2. U.S. Pat. No. 5,914,472 (US5914472A)

• Full Citation: US5914472A - Credit card spending authorization control system.
• Publication Date: 1999-06-22.
• Filing Date: 1997-09-23.
• Brief Description: This patent, by its title, appears to describe a system that allows for controlling or authorizing spending on credit cards. This would likely involve mechanisms to set limits or rules for transactions. While not explicitly stating "category-by-category," a "spending authorization control system" could encompass or be adapted to such a feature.
• Potential Anticipated Claims (under 35 U.S.C. § 102):
  • Claims 1, 5, 12, 19: These claims relate to storing a profile with user pre-set limits and presenting transaction summary data with those limits. A "spending authorization control system" that allows for user-defined limits, even if not explicitly categorized, could potentially anticipate the broad concept of a user-preset limit and tracking against it. The novelty of US8083137B2 here might rest on the "category by category" basis and the presentation of "transaction summary data containing said at least one user-selected category's user pre-set limit."

3. U.S. Pat. No. 5,953,710 (US5953710A)

• Full Citation: US5953710A - Children's credit or debit card system.
• Publication Date: 1999-09-14.
• Filing Date: 1996-10-09.
• Brief Description: This patent's title strongly suggests a system for managing financial transactions for children, likely involving a main account holder (parent) and sub-users (children) with controlled spending. Such a system would inherently require setting limits, possibly on specific types of purchases or amounts, to govern the child's usage of the card.
• Potential Anticipated Claims (under 35 U.S.C. § 102):
  • Claims 4, 8, 15, 22, 23 (Sub-user Management): These claims specifically relate to user-selected sub-user identities, sub-user transactions, and respective authorized amounts or times of usage. A "Children's credit or debit card system" would almost certainly involve these features for parental control. The distinction for US8083137B2 would depend on the specificity of "user-selected categories" for sub-users and the presentation of summary data containing the pre-set limits for those categories.

4. U.S. Pat. No. 2004/0039694 (US20040039694A1)

• Full Citation: US20040039694A1 - System and method for facilitating a subsidiary card account with controlled spending capability.
• Publication Date: 2004-02-26.
• Filing Date: 2001-05-29.
• Brief Description: This published application describes a system for managing "subsidiary card accounts" with "controlled spending capability." This directly addresses the concept of a main user providing a card to another (subsidiary) user and imposing spending restrictions. The "controlled spending capability" strongly implies the ability to set limits, and potentially category-based restrictions, for these subsidiary accounts.
• Potential Anticipated Claims (under 35 U.S.C. § 102):
  • Claims 4, 8, 15, 22, 23 (Sub-user Management): Similar to US5953710A, this reference directly targets the management of sub-accounts with spending controls, making it highly relevant to the claims in US8083137B2 that pertain to sub-user identities, their transactions, authorized amounts, and usage times. The specific "category by category" aspect of the limits and the presentation of summary data (as claimed in US8083137B2) would be a key differentiating factor.
  • Claims 1, 5, 12, 19 (Core Concepts): Depending on the level of detail regarding how "controlled spending" is achieved, this reference could also broadly anticipate the idea of user-defined limits against which transactions are tracked.

Important Note on Anticipation:
A definitive statement of anticipation under 35 U.S.C. § 102 would require a full, claim-by-claim comparison of US8083137B2's claims against the entire disclosure (specification, drawings, and claims) of each cited prior art reference. The analysis above is based on the titles and the general inventive concepts apparent from those titles and the relationships between the patents. US7254548B1, as the parent application, is the most likely to fully anticipate many of the claims of US8083137B2.

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.