Prosecution Insights
Last updated: April 19, 2026
Application No. 13/098,024

LOYALTY REDEMPTION

Final Rejection §101
Filed
Apr 29, 2011
Examiner
LONG, MEREDITH A
Art Unit
3622
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Regions Bank
OA Round
24 (Final)
43%
Grant Probability
Moderate
25-26
OA Rounds
3y 1m
To Grant
65%
With Interview

Examiner Intelligence

Grants 43% of resolved cases
43%
Career Allow Rate
173 granted / 403 resolved
-9.1% vs TC avg
Strong +22% interview lift
Without
With
+21.8%
Interview Lift
resolved cases with interview
Typical timeline
3y 1m
Avg Prosecution
37 currently pending
Career history
440
Total Applications
across all art units

Statute-Specific Performance

§101
38.1%
-1.9% vs TC avg
§103
30.0%
-10.0% vs TC avg
§102
11.8%
-28.2% vs TC avg
§112
14.0%
-26.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 403 resolved cases

Office Action

§101
DETAILED ACTION This communication is in response to the amendment/remarks filed 23 December 2025. Claims 1 and 16 have been amended. Claims 1, 5-11, 14, 16, 18-24, and 27 are currently pending. Claims 1, 5-11, 14, 16, 18-24, and 27 are rejected. Notice of Pre-AIA or AIA Status The present application is being examined under the pre-AIA first to invent provisions. Response to Amendment/Remarks Regarding 35 USC § 101, Applicant’s remarks have been fully considered but are not persuasive. Applicant argues that “Conventional methods typically required the customer to redeem the instrument only at the same merchant that issued the loyalty points. As indicated in the specification (e.g. pages 6-7 and Figs. 4 to 7) a plurality of graphical display that can be used to guide a customer through a purchase instrument redemption process. In Fig. 4, after logging in his/her user account, the customer can be provided a list of participating (or contracted) merchant in which the purchase instrument may be redeemed. The graphical display can include at least one link to the websites of the plurality of contract merchants, and in some embodiments, the purchase instrument can be redeemed at more than one merchant. The claims therefore do contain additional elements that amount to significantly more than the judicial exception. For at least this reason, the claims are directed to eligible subject matter. Applicants respectfully request withdrawal of this ground of rejection.” Remarks at 9. Applicant also argues that “[t]his is in contrast to prior systems for redeeming purchase instruments that did not allow real time uploads and downloads of information (let alone on a mobile device) as well as periodic uploads and downloads of information and that did not provide an interface configured to display a plurality of card layout templates allowing the customer to customize the purchase instrument at one graphical display.” Remarks at 9. The items pointed to by Applicant such as the use of a graphical display to guide a customer through a purchase is use of a generic computer component to implement the abstract idea. The discussion of a technological solution (to a technological problem) is found in MPEP 2106.05(a). “[T]he disclosure must provide sufficient details such that one of ordinary skill in the art would recognize the claimed invention as providing an improvement. The specification need not explicitly set forth the improvement, but it must describe the invention such that the improvement would be apparent to one of ordinary skill in the art.” Note that multiple quality specialists have been consulted with respect to this § 101 rejection. Thus, it is not merely one examiner’s conclusion that the claims and the specification do not contain a technological solution. The disclosure does not provide sufficient details such that one of ordinary skill would recognize the invention as providing an improvement. Examiner does not set what is and is not “sufficient” and a bright line test is not available. However, it does not appear that there is ANY support that a technological improvement exists in the specification. While the present invention may be different than previous systems, that difference is not a technological improvement under the § 101 analysis. See US 2011/0125529 (“Miller”), previously cited, wherein Miller discloses real time and periodic uploads and downloads of information at ¶ 0016. The existence of Miller indicates that the presence of real time and periodic uploads and downloads was not absent from the art prior to the present invention. Claim Rejections - 35 USC § 101 35 U.S.C. 101 reads as follows: Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title. Claims 1, 5-11, 14, 16, 18-24, and 27 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. Step 1 Claims 1, 5-11, and 14 recite a method which is considered a process. Claims 16, 18-24, and 27 recite a system which is considered a machine or manufacture. Step 2A-Prong One Claims 1, 5-11, 14, 16, 18-24, and 27 recite a method that allows a user to select a merchant and an amount of points to transfer to a user-customized purchase instrument (see accessing from a mobile device a network interface allowing a user to log into a user account and redeem an amount of loyalty points for a purchase instrument; creating the purchase instrument based on the merchant and loyalty points selection with a processing module, storing the purchase instrument in electronic form, the processing module activating the purchase instrument and updating the amount of loyalty points left in the user account, and sending the customer a link to access the purchase instrument; logging into a user account to redeem an amount of loyalty points, wherein the loyalty points are stored in a user account for a purchase instrument of a merchant, viewing a graphical display that includes at least one link to websites of the plurality of contract merchants, the mobile device or merchant server providing a graphical interface, accessing the graphical interface configured to display a plurality of card layout templates allowing the customer to customize the purchase instrument at one graphical display customizing the purchase instrument, accessing a system computer associated with the purchase instrument redemption system having both real time uploads and downloads of information and periodic uploads and downloads of information and that directs and monitors a request from the user's mobile device to a transaction database and periodically receives data from the contract merchant's server containing information regarding customers' accumulated loyalty points, transferring an amount of value on the purchase instrument back to an amount of loyalty points of the user account allowing the customer to select the merchant among a plurality of contract merchants and determine the amount of redeemed loyalty points by the customer and customize and preview the purchase instrument at one graphical display the processing module storing the purchase instrument in an electronic form and sending the customer a link to access it; and activating the purchase instrument and updating the amount of loyalty points left in the user account, communicating the loyalty points redemption to the selected merchant, and the system transfers an amount of loyalty points from the user account to an amount of value on the purchase instrument, the system configured to be accessed from a mobile device in claim 1, for example). This concept is a commercial interaction and sales activity which falls within the Certain Methods of Organizing Human Activity grouping. Thus, the claims recite an abstract idea. Dependent claims 5, 8-11, 18, and 22-24 further narrow the above abstract idea by further defining what is meant by a purchase instrument (see the purchase instrument is a gift card, the purchase instrument is a printable coupon, the purchase instrument is a gift certificate, the purchase instrument is a code sent to the customer in an email). These limitations do not take the claims out of the abstract idea grouping. Thus, the claims recite an abstract idea. The performance of the claim limitations using generic computer components does not preclude the claim limitations from being in the Certain Methods of Organizing Human Activity grouping. Accordingly, the claims recite an abstract idea. Step 2A-Prong Two The claims recite the additional elements of storing information in a user account, accessing the user account via a network interface, a computer that directs and monitors a user’s request, and allowing the user to customize a purchase instrument via a graphical interface. The claims as a whole merely describe how to generally “apply” the concept of accessing a user account to customize a purchase instrument. The claimed computer components are recited at a high level of generality and are merely invoked as tools to perform the method steps. Simply implementing the abstract idea on a generic computer including a graphical interface is not a practical application of the abstract idea. Accordingly, the claims do not integrate the abstract idea into a practical application because they do not impose any meaningful limits of practicing the abstract idea. Additionally, the step of “periodically receiv[ing] data from a merchant server containing information regarding customers’ accumulated loyalty points” is mere data gathering which is considered insignificant extra-solution activity and does not integrate the abstract idea into a practical application. Step 2B The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed previously with respect to Step 2A-Prong Two, the additional element in the claim amounts to no more than mere instructions to apply the exception using a generic computer component. The same analysis applies here in Step 2B, i.e., mere instructions to apply an exception using a generic computer component cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. See MPEP 2106.05(f). The claims do not provide an inventive concept (significantly more than the abstract idea).Additionally, the courts have recognized that “receiving or transmitting data over a network, e.g., using the Internet to gather data” in routine, conventional, and well-understood (see MPEP 2106.05(d)). The claims are ineligible. The courts have determined that mere data gathering is routine, conventional, and well-understood activity when claimed in a merely generic manner. See i. Receiving or transmitting data over a network, e.g., using the Internet to gather data in MPEP 2106.05(d). Conclusion THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to MEREDITH A LONG whose telephone number is (571)272-3196. The examiner can normally be reached Mon - Fri 9:30 - 6. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Ilana Spar can be reached at 571-270-7537. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /MEREDITH A LONG/Primary Examiner, Art Unit 3622
Read full office action

Prosecution Timeline

Apr 29, 2011
Application Filed
Jan 25, 2013
Non-Final Rejection — §101
Jul 01, 2013
Response Filed
Sep 05, 2013
Final Rejection — §101
Jan 13, 2014
Request for Continued Examination
Jan 17, 2014
Response after Non-Final Action
Aug 04, 2014
Non-Final Rejection — §101
Dec 12, 2014
Response Filed
Mar 30, 2015
Final Rejection — §101
May 30, 2015
Response after Non-Final Action
Jul 01, 2015
Request for Continued Examination
Jul 10, 2015
Response after Non-Final Action
Mar 11, 2016
Non-Final Rejection — §101
Jun 17, 2016
Response Filed
Sep 16, 2016
Final Rejection — §101
Jan 22, 2017
Response after Non-Final Action
Feb 15, 2017
Examiner Interview (Telephonic)
Feb 15, 2017
Response after Non-Final Action
Mar 20, 2017
Request for Continued Examination
Mar 22, 2017
Response after Non-Final Action
Sep 29, 2017
Non-Final Rejection — §101
Jan 02, 2018
Response Filed
Apr 04, 2018
Final Rejection — §101
Jul 09, 2018
Response after Non-Final Action
Jul 31, 2018
Examiner Interview (Telephonic)
Jul 31, 2018
Response after Non-Final Action
Aug 09, 2018
Request for Continued Examination
Aug 13, 2018
Response after Non-Final Action
Dec 14, 2018
Non-Final Rejection — §101
Mar 20, 2019
Response Filed
May 06, 2019
Final Rejection — §101
Aug 09, 2019
Response after Non-Final Action
Aug 26, 2019
Response after Non-Final Action
Sep 09, 2019
Request for Continued Examination
Sep 16, 2019
Response after Non-Final Action
Sep 27, 2019
Non-Final Rejection — §101
Jan 02, 2020
Response Filed
Mar 30, 2020
Final Rejection — §101
Aug 03, 2020
Response after Non-Final Action
Aug 24, 2020
Response after Non-Final Action
Sep 03, 2020
Request for Continued Examination
Sep 04, 2020
Response after Non-Final Action
Jan 14, 2021
Non-Final Rejection — §101
May 20, 2021
Response Filed
Jul 14, 2021
Final Rejection — §101
Dec 31, 2021
Request for Continued Examination
Jan 11, 2022
Response after Non-Final Action
Feb 25, 2022
Non-Final Rejection — §101
Aug 02, 2022
Response Filed
Sep 30, 2022
Final Rejection — §101
Jan 05, 2023
Response after Non-Final Action
Jan 20, 2023
Response after Non-Final Action
Jan 26, 2023
Request for Continued Examination
Jan 31, 2023
Response after Non-Final Action
Mar 20, 2023
Non-Final Rejection — §101
Jun 15, 2023
Response Filed
Sep 20, 2023
Final Rejection — §101
Dec 22, 2023
Response after Non-Final Action
Jan 11, 2024
Examiner Interview (Telephonic)
Jan 11, 2024
Response after Non-Final Action
Mar 25, 2024
Request for Continued Examination
Mar 26, 2024
Response after Non-Final Action
May 03, 2024
Non-Final Rejection — §101
Jul 26, 2024
Response Filed
Aug 08, 2024
Final Rejection — §101
Nov 13, 2024
Response after Non-Final Action
Nov 14, 2024
Response after Non-Final Action
Dec 13, 2024
Request for Continued Examination
Dec 16, 2024
Response after Non-Final Action
Feb 06, 2025
Non-Final Rejection — §101
May 09, 2025
Response Filed
May 19, 2025
Final Rejection — §101
Aug 21, 2025
Response after Non-Final Action
Sep 25, 2025
Request for Continued Examination
Sep 27, 2025
Response after Non-Final Action
Sep 29, 2025
Non-Final Rejection — §101
Dec 23, 2025
Response Filed
Mar 06, 2026
Final Rejection — §101 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

25-26
Expected OA Rounds
43%
Grant Probability
65%
With Interview (+21.8%)
3y 1m
Median Time to Grant
High
PTA Risk
Based on 403 resolved cases by this examiner. Grant probability derived from career allow rate.

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