of using multiple rd party intermediaries they're directed to using multiple rd party intermediaries in a very specific and concrete way because the claims tell us exactly what each party does the claims tell us that the payment broker does not know who entities are going to know certain information which seems more abstract more of an idea and something that's a specific technological solution to a technological problem so i think i disagree with that and if you look at the claims which are reproduced on page eight of our brief as well as in the appendix you'll see all of the very specific details and that's something that really distinguishes this cli's claims from the claims at issue analysis if you look at the claims that are as they're short and they just say do it they don't tell you how whereas in this in these claims they tell you exactly how to do it they tell you who transmits what they tell you who has what information when and that is the concrete information that that is enough to pass step one muster this also has been damaged and it's a claim to it's claimed advantage that breaks the chain of data transmission thanked her as an electronic payment systems and thereby provides the claimed enhanced security the director says as much in her brief on page thirty dollars saying and i quote the payment broker facilitates the rd party payment system which provides the benefit of increased data security this additional layer of security was not found or used in the conventional environment specification of little steps that are more or less inevitable you know more general word you know communicate with somebody and you could say walk to the desk pick up the phone punch this number this number this number and you could make it extremely long without adding any and you know legally material information why is where are the details here you know particularly the very long economic practice because they're novel so these claims are different from just saying that the examiner would have been able to find prior art disclosing this if that were the case so the argument is not that the claims are long and therefore the that we have the different we have the different parties and starting at b it's mentions the brokerage server and if you look at not roman numeral number three it says receiving instruction in a payment being made electronically by someone other than the payment broker who's associated with the payee but also tells us the payer gets to select the payment method then if you go to number four numeral number four it retrieves the information identifying the pairs selected funding source so the pair doesn't need to do that if you had your phone you wouldn't need to retrieve your credit card numbers which is an added security benefit especially if you are in a public place or on a public fly find out where you go down to number six roman number six to cause the payment to be made electronically to the page on the funding sources behalf by a rd party other than the payment broker so we're again clarifying the different roles of the rd party if you go on to the letter c will see similar limitations explaining what the funding does in response to instruction from the payment broker it instructs a rd party other than the payment program to make the payment in the rd party's name and here's another key to this client this claim thereby preventing  the payee of the identity of the payer now a lot of claims say oh we have we have a wonderful solution to this problem but they don't claim the solution these claims are concrete because they have the exact and explicit directions and they claim the solution and that's enough to pass alice stepped on because the abstract idea should not be distilled down to just being using multiple rd party intermediaries and even would you say that that in privacy and she believes that that's done by allocating different responsibilities among different players absolutely ok so it's the fact that  responsibilities among multiple players such that each player does not have all the information and that breaks the chain of communication and it's a sort of technological solution to a specific type of logical problem because the example is protection and that could be a different claim or maybe these claims are written broad enough to cover it but it's not a it's not an alice issue it's not a problem of whether or not these these claims should still twenty or thirty  there's no doubt that there could be other solutions so yes perhaps it would be perhaps it wouldn't be as cost effective these claims require three dollars and these claims are written to solve the problem which is enough to make it pass alice now whether or not somebody could come up with a way of using twenty that would infringe or wouldn't infringe these claims as a separate issue but the only issue before the court today is whether the the claims pass the alice analysis steps one and step two now even if this court were to say the abstract idea is use multiple rd party intermediaries then the claims we think it's not for the reasons i've already discussed but then the claims would pass at step two and the reason is because it has a very concrete and specific steps that comprise the inventive concept or at the very steps that i've just explained to you of each each party having access to different information so the payment broker doesn't know who the rd party is so the funding source doesn't know the rd part financial information and the payee and its banks don't know the identity of the funding source you these claims prevent a situation where a receive some money and then basically has a chain of transact transaction information and can go back and take more out of your bank account for example when you're buying something on the internet or in a mobile payment environment so they prevent that chain of that chain reaction was rather than consider the inventiveness of the claimed restructuring of roles in electronic payment system the board erred by focusing its analysis at step two on the conventionality of the computer hardware components but mr foti never argued that these portions of the claims constituted the inventive concept the inclusion of conventional components does not render the inventive concept of the specific roles of rd parties any less inventive here the invention concept is the non conventional non generic arrangement of the additional rd party intermediaries in their servers and the specific roles they do which solve the problems rooted in electronic payment world so your argument is not that technology is being used in any special way here it's just from what you are gather from what you said that the technology being used in normal usage our argument is that the individual components are being used in their normal usage however when combined they're being used in a non conventional way which is the way that allows the prohibits transmission of all payment information from the payer to the payee and that is the n generic invented concept here at step t itself they pointed missions that the individual components were routine conventional but there's nothing in the specification nor is there any evidentiary record that the combination was routine in conventional and that's why this case is is similar to the r which were which were also cases that involve conventional components but they were arranged in a new way and used in a new way all reserved the rest of my time good morning your honor smith please the court let me begin with this whole notion i think of this whole multiple rd parties which i want to say st of all was never really raised as of multiple rd parties argument before but as i understand what they're saying in the in the specification they talk about different things as being rd parties they talk about the funding source the brokerage server broker the funding server or various different approaches i think it may be  helpful to start with your three because that's the sort of what's sort of lays out how the system works i'm thinking three is at thirty five of the record and what we see here and this is  the basically the funding sources so that's like your bank and so for each their inferred but it's the payee is a real account and or funding source and then on the right is the payer is funding source and then because it's electronic there are not actually pictured here but to abscond this rd party and the whole point of that is to add a rd party to protect the payers information from being divulged to the payee and that is what the certain amount of this word non died they do when where they describe that it's in the context of talking about the rd party and having the rd party between the payer and payee and that is just so if i look at figure three i can't for making payments to the payee and then being rebirth reimbursed from the payer and the purpose of that is so that the information and specifically the real account and the phone in source which is exactly on a rd party to his bank information or his account information by having a rd party in the middle and so that's what's described here in the claim it's also described in the context of the funding source server and that's at the bottom beginning at a twenty five dollars at beginning about line twenty and again the same thing as the payment with the rd party in the middle and the purpose is to protect the players real account and funding source information so there are lots of arguments in the briefs about other sorts of potential problems that they're trying so none of those are some one of those i am just some want to hear your response to the argument on the mordred combination that is that the board and he was short shrift to behalf mr snowden is that those components are individually admitted to be conventional but there is nothing that it meets them in their order combination to be conventional i just wonder what your no there is evidence that it's conventional or that could be the response could be something along the lines of that particular arrangement is part about the abstract idea itself i mean there's a lot of responses i want to make sure that you're focusing on the specific question right and i was going to get to that page ten of the record the board looks to the exam nurse for news and about that and then again at eleven the bottom of i'm sorry fifteen sorry fifteen sixteen the board again engages very thoroughly with looking out the order combination so ten it talks about the examiner and quotes from the examiner that the claims do not require any non conventional computer network or database or even a non conventional non generic arrangement of known conventional pieces but merely a call for performance of the claim to electronic fun try just like and paragraph three on a set of generic proponents are considered separately when they start to look at them as an ordered combination and says the claim doesn't for example improve the function of the computer and there's nothing significant or goes onto the next page and describes and discuss the particulars of the components individually as well as as an ordered company and i just want to briefly point out that the various problems that they are trying to highlight in their previous about a lot of debility man in the middle tax and hackers are not actually supported in the specification those are all attorney arguments when they talk about a lot of to build and the potential for inclusion of chain or transaction details they cite two to ten into eleven  and humane in terms of just i think i understood how i understood you to be saying these arguments about hacked again and whatnot are not in the spec so i thought what's in it have to be in spec suppose they agree and i think you matter to a response to an office action isn't that the way you create a record before the examiner that is arguments that could be made before the examiner but the examiner in some submission to the examiner that for example said steps who have required in the claim help reduce hacking i don't think that would change the nature of the invention in any way if they did the inventors themselves would not contemplate or start a factual point did the applicant put in something to the examiner that said that there was attorney argument made there wasn't any sort of declaration evidence or declaration and thought of the same is true of the man in the middle of tax they say to their people and their response when i finish this action and the same with hackers in fact the only discussion of hackers in the terms of computer components to protect against these kinds of problems if there are no additional questions you will see the remainder of my time i start this quarter from the th and we thank you  we amended the claims during prosecution to require multiple rd parties there could be no argument that these claims cover a rd party nor could the abstract idea be directed to something that the claims explicitly exclude if you look at appendix page fifteen there is a line from the examiner regarding the ordered combination where it says considered as an ordered combination the computer components of appellant system and nothing that is not already present when the components are considered separately that's it that's the only analysis we have from the board because the examiner earlier the th on ordered companies and that's conclusory there's no citation to evidence and there's no evidence on the record to support that and finally also regarding the ordered combination issue you don't need to improve the way a computer functions to show that there is something unique in the word combination to pass alice and we've seen that in several of these cases most recent recently in ankara as well as other case that involves sensors fails will be the vision that fails vision x be that the united states where the using traditional censorious in a new way and a new combination of ways was was indeed enough to