Section 101 Examples
Example 23: Graphical User Interface For Relocating Obscured Textual Information

This is an example provided by the U.S. Patent and Trademark Office for analyzing Section 101 patent subject matter eligibility issues. This example is taken from Appendix 2 of the July 2015 Update on Subject Matter Eligibility, and this example should be viewed in light of the introduction that was provided with it.

The index for all of the examples provided by the Patent and Trademark Office is found on BitLaw's Section 101 Index.

Example 23: Graphical User Interface For Relocating Obscured Textual Information

The following claims are hypothetical. Claim 1 demonstrates a claim that is not directed to an abstract idea. Claims 2 and 3 are directed to an abstract idea and do not recite significantly more. Claim 4 recites an abstract idea, but there are additional limitations in the claim that amount to significantly more than the abstract idea.

Background

The invention relates to a graphical user interface (GUI). A GUI manages the interaction between a computer system and a user through graphical elements such as windows on a display. Windows display various types of outputs for various computer processes and may contain controls to accept user input for those processes. In some instances, multiple windows are displayed at the same time; due to limited display space, however, the windows may overlap and obscure the content of underlying windows.

In the instant application, the inventor has improved upon previous GUIs by dynamically relocating obscured textual information of an underlying window to become automatically viewable to the user. In particular, in a graphical user interface that comprises multiple windows, the invention continuously monitors the boundaries of the windows to ascertain an overlap condition indicating that the windows overlap such that the textual information of an underlying window is obscured from a user’s view by the overlapping window. Only when the textual information of the underlying window is detected to be obscured, the invention re‐formats and moves the textual information in the underlying window to an unobscured portion of the underlying window so that the textual information is viewable by the user. When the overlap condition no longer exists, the textual information is returned to its original format and location.

The inventor’s process is performed by modifying the vertical and horizontal margins of the underlying window in accordance with the overlap and utilizing a word wrap function to wrap the text around the obscured area based upon the new margins, and, where necessary, reducing the text size to permit the entirety of the textual information to be viewable in the unobscured portion. The textual information is scaled based upon a scaling factor that is calculated using a mathematical algorithm. First, an area of the underlying window and an area of the unobstructed portion of the underlying window are calculated. Next, the scaling factor is calculated which is proportional to the difference in area between the underlying window and the unobstructed portion of the underlying window. Finally, the font size of the textual information is changed in accordance with the scaling factor. The new scaled textual information is then moved as described above to the unobstructed portion of the underlying window. When the windows no longer overlap, the textual information is returned to its original format and location by resetting the vertical and horizontal margins of the window to their original values and no longer applying the scaling factor to the font size. By permitting textual information to be dynamically relocated based upon an overlap condition, the computer’s ability to display information and interact with the user is improved.

Claims

1. A computer‐implemented method for dynamically relocating textual information within an underlying window displayed in a graphical user interface, the method comprising:
• displaying a first window containing textual information in a first format within a graphical user interface on a computer screen;
• displaying a second window within the graphical user interface;
• constantly monitoring the boundaries of the first window and the second window to detect an overlap condition where the second window overlaps the first window such that the textual information in the first window is obscured from a user’s view;
• automatically relocating the textual information, by a processor, to an unobscured portion of the first window in a second format during an overlap condition so that the textual information is viewable on the computer screen by the user; and
• automatically returning the relocated textual information, by the processor, to the first format within the first window when the overlap condition no longer exists.
2. A computer‐implemented method of resizing textual information within a window displayed in a graphical user interface, the method comprising:
• generating first data for describing the area of a first graphical element;
• generating second data for describing the area of a second graphical element containing textual information; and
• calculating a scaling factor for the textual information which is proportional to the difference between the first data and second data.
3. A computer‐implemented method of resizing textual information within a window displayed in a graphical user interface, the method comprising:
• generating first data for describing the area of a first graphical element;
• generating second data for describing the area of a second graphical element containing textual information; and
• calculating, by the computer, a scaling factor for the textual information which is proportional to the difference between the first data and second data.
4. A computer‐implemented method for dynamically relocating textual information within an underlying window displayed in a graphical user interface, the method comprising:
• displaying a first window containing textual information in a first format within a graphical user interface on a computer screen;
• displaying a second window within the graphical user interface;
• constantly monitoring the boundaries of the first window and the second window to detect an overlap condition where the second window overlaps the first window such that the textual information in the first window is obscured from a user’s view;
• determining the textual information would not be completely viewable if relocated to an unobstructed portion of the first window;
• calculating a first measure of the area of the first window and a second measure of the area of the unobstructed portion of the first window;
• calculating a scaling factor which is proportional to the difference between the first measure and the second measure;
• scaling the textual information based upon the scaling factor;
• automatically relocating the scaled textual information, by a processor, to the unobscured portion of the first window in a second format during an overlap condition so that the entire scaled textual information is viewable on the computer screen by the user; and
• automatically returning the relocated scaled textual information, by the processor, to the first format within the first window when the overlap condition no longer exists.

Analysis

Claim 1: Eligible.

The claim recites a series of steps for relocating textual information in an underlying window to an unobscured portion of the underlying window. Thus, the claim is directed to a process, which is one of the statutory categories of invention (Step 1: YES).

Next, the claim must be analyzed to determine whether it is directed to a judicial exception. Here, the claimed method relates to addressing a problem with overlapping windows within a graphical user interface. In particular, the claim recites dynamically relocating textual information within a window displayed in a graphical user interface based upon a detected overlap condition. When the windows overlap, textual information is reformatted and relocated to an unobscured portion of the underlying window; when the windows no longer overlap, the textual information is returned to its original format and location. The claim does not recite a basic concept that is similar to any abstract idea previously identified by the courts. For example, the claim does not recite any mathematical concept or a mental process such as comparing or categorizing information that can be performed in the human mind, or by a human using a pen and paper. Accordingly, the claim does not set forth or describe an abstract idea. Instead, the claimed method is necessarily rooted in computer technology to overcome a problem specifically arising in graphical user interfaces. Additionally, the claim does not recite any other judicial exception. Therefore, the claim is not directed to a judicial exception (Step 2A: NO). The claim is patent eligible.

If the examiner believes that the record would benefit from clarification, remarks could be added to an Office action or reasons for allowance indicating that the claim is not directed to any judicial exception.

Claim 2: Ineligible.

The claim is directed to a series of steps for calculating a scaling factor, and thus is a process which is a statutory category of invention (Step 1: YES).

The claim is then analyzed to determine whether it is directed to any judicial exceptions. The claim recites the steps of calculating a first area and a second area and using the areas to calculate a scaling factor. This concept is similar to the other types of basic concepts that have been found by the courts to be abstract. In particular, the courts have found mathematical algorithms to be abstract ideas (e.g., a mathematical procedure for converting one form of numerical representation to another in Benson, or an algorithm for calculating parameters indicating an abnormal condition in Grams). Therefore, the claim is directed to an abstract idea (Step 2A: YES).

Next, the claim is analyzed to determine whether there are additional limitations recited in the claim that amount to significantly more than the abstract idea, either individually or as an ordered combination. The body of the claim does not recite any additional limitations besides the mathematical algorithm for calculating a scaling factor. However, the preamble of the claim does provide the additional limitations that the process is computer‐ implemented and textual information is contained in a window in a graphical user interface. These limitations indicate the claimed process is used in a graphical user interface environment. Where the preamble only states the purpose or the field of use of an invention, the preamble does not limit the scope of the claim. Such a limitation does not give “life, meaning and vitality to the claim.” (See MPEP 2111.02.) Therefore, the limitations in the preamble do not limit the claim and there are no additional limitations beyond the mathematical algorithm. Therefore, the claim does not amount to significantly more than the abstract idea itself (Step 2B: NO). The claim is not patent eligible.

A rejection of claim 2 should identify the exception by pointing to the generating and scaling steps and explain that the steps are a mathematical algorithm similar to those found by the courts to be abstract. The rejection should also note that the preamble does not limit the scope of the claim and, therefore, there are no additional limitations in the claim besides the abstract idea.

Claim 3: Ineligible.

The claim is directed to a series of steps for calculating a scaling factor, and thus is a process which is a statutory category of invention (Step 1: YES).

The claim is then analyzed to determine whether it is directed to any judicial exceptions. The claim recites the steps of calculating a first area and a second area and using the areas to calculate a scaling factor. As discussed above, these steps describe a mathematical algorithm which has been found by the courts to be an abstract idea. Therefore, the claim is directed to an abstract idea (Step 2A: YES).

The claim is then analyzed to determine whether it is directed to any judicial exceptions. The claim recites that the step of calculating a scaling factor is performed by “the computer” (referencing the computer recited in the preamble). Such a limitation gives “life, meaning and vitality” to the preamble and, therefore, the preamble is construed to further limit the claim. (See MPEP 2111.02.) Thus, the claim recites the additional limitations that the mathematical algorithm is implemented by a computer in a graphical user interface environment. However, the mere recitation of “computer‐implemented” is akin to adding the words “apply it” in conjunction with the abstract idea. Such a limitation is not enough to qualify as significantly more. With regards to the graphical user interface limitation, the courts have found that simply limiting the use of the abstract idea to a particular technological environment is not significantly more. (See, e.g., Flook.) Even though the disclosed invention may improve computer technology, the claimed invention provides no meaningful limitations such that this improvement is realized. Therefore, the claim does not amount to significantly more than the abstract idea itself (Step 2B: NO). The claim is not patent eligible.

A rejection of claim 3 should identify the exception by pointing to the generating and scaling steps and explain that the steps are a mathematical algorithm similar to those found by the courts to be abstract. The rejection should also note that the preamble is limiting on the scope of the claim, but the additional limitations do not amount to significantly more because they merely require the abstract idea to be performed by a computer and in a particular technological environment.

Claim 4: Eligible.

As discussed above, the claim recites a series of acts and thus is a process (Step 1: YES).

Next, the claim is evaluated to determine if the claim is directed to a judicial exception. The claim recites similar steps to those recited in claim 2; notably calculating a first measure of the area of a first window and a second measure of the area of the unobstructed portion of the first window and calculating a scaling factor that is proportional to the difference between the first and second measure. As explained with regards to claim 2, the courts have previously found mathematical algorithms to be abstract ideas. Therefore, the claim is directed to an abstract idea (Step 2A: YES).

The claim must be analyzed to determine if the claim recites additional limitations that amount to significantly more than the abstract idea. The claim recites the additional limitations of a computer screen and processor. The recitation of the computer screen for displaying and the processor for moving data is not enough by itself to transform the exception into a patentable invention, because these limitations are generic computer components performing generic computer functions at a high level of generality. Merely using these generic computer components to perform the identified basic functions does not constitute meaningful limitations that would amount to significantly more than the abstract idea.

However, when viewing these computer limitations as an ordered combination with the remaining limitations, the claim amounts to significantly more than the abstract idea. The claim further recites the limitations of displaying a first and second window, detecting an overlap condition indicating the windows overlap such that textual information in the first window is obscured from view, determining the textual information is too large to fit in an unobstructed portion of the first window, scaling the textual information based upon the calculated scale factor, automatically relocating the scaled textual information to an unobstructed portion of the first window so that it is viewable by the user, and automatically returning the textual information to its original format when the overlap condition no longer exists. These limitations are not merely attempting to limit the mathematical algorithm to a particular technological environment. Instead, these claim limitations recite a specific application of the mathematical algorithm that improves the functioning of the basic display function of the computer itself. As discussed above, the scaling and relocating the textual information in overlapping windows improves the ability of the computer to display information and interact with the user.

Taking all the claim elements both individually and as an ordered combination, the claim as a whole amounts to significantly more than the mathematical algorithm of calculating a scaling factor (Step 2B: YES). Thus, the claim recites patent eligible subject matter.

If the examiner believes that the record would benefit from clarification, remarks could be added to an Office action or reasons for allowance indicating that the claim recites a mathematical algorithm which is an abstract idea. However, the claim is eligible because it recites additional limitations that when considered as an ordered combination demonstrate an improvement to the computer’s basic ability to display information and interact with the user.