Ropes & Gray's argument, in a responsel to the Office action or in an appeal, might say that the Examiner and/or the Office action have committed a procedural error, and failed to analyze all of the claim limitations. The assertion that the claim limitations considered as a whole are not significantly more than the abstract idea is an unsupported allegation, because the claim limitations as a whole have not been considered. The only claim limitations cited in the rejection are claim # 53 i.e.e
https://investorshangout.com/post/view?id=4866692 and remainder of the claim limitations have neither been cited nor analyzed. Because the Office action has a procedural error, the rejection is improper and invalid, and should be withdrawn.
Seen it before, Take all other 43 claims from the IPR and nail these peeps.
So true ZP!!