DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 02/23/2026 has been entered.
The following is a non-final office action in response to the request for continued examination of 02/23/2026.
Status of Claims
Claims 1-2, 4-12, and 14-22, as originally filed 02/23/2026, are pending and have been examined on the merits (claims 1 and 11 being independent). Claims 1 and 11 have been amended.
Information Disclosure Statement
The information disclosure statement (IDS) submitted on 03/02/2026 is in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner.
Response to Arguments
Applicant’s arguments and amendments filed 02/23/2026 have been fully considered but they are not persuasive.
Applicants assert that the pending claims fully comply with the requirement of 35 U.S.C. 101. Examiner respectfully disagrees. Applicant’s argument and amendments have been considered and are not persuasive. The rejections under 35 USC 101 have been maintained and clarified in view of the USPTO MPEP 2106.
Applicant arguments (see Applicant’s remarks, pages 14-16):
(1) “A. Under Revised Step 2A, Amended Independent Claims 1 and 11 Integrate the Ideas into a Practical Application” (see remarks, pages 14-15):
Applicant’s arguments that “Applicant respectfully submits that the claims recite an improvement to other technology or technical field, and also recite use of the ideas in a meaningful way beyond generally linking to a particular technological environment.” ( see remarks, page 14), are not found persuasive.
Response (1): As set forth in the previous Office Action, Examiner considers that the judicial exception is not integrated into a practical application. The claim limitations are not indicative of integration into a practical application by claiming an improvement to the functioning of the computer or to any other technology or technical field. Further, the claim limitations are not indicative of integration into a practical application by applying or using the judicial exception in some other meaningful way. In particular the claim limits of (a) “a device profile”, “a device identifier” and “mobile network” amount to simply applying the abstract idea to a computer network and/or a computer component (e.g. “apply it”), (b) “the first selection button is operable to navigate to a second graphical user interface display”, “the second selection button and the third selection button are operable to navigate to a third graphical user interface display”, and “the fourth selection button, the fifth selection button, the seventh selection button are operable to navigate to a fifth graphical user interface” describe selecting elements to a generic device (e.g. a graphical user interface). For example, the “the first selection button” is not described in the specification in such a way require anything more than merely a generically “interactive” display, and therefore also amounts to simply applying the abstract idea to a generic device and client combination (e.g. “apply it” or the equivalent), and (c) “selection button”, again describes a generically interactive element, which amounts to simply applying the abstract idea of filtering on a computer (e.g. on a web browser) are claimed and described at a high level of generality and are functions any general purpose computer performs such that it amounts to no more than mere instruction to apply the exception to a particular technological environment. Further, none of the limitations recite technological implementation details for any of the steps but, instead, only recite broad functional language being performed by the generic use of at least one processor. The claim limits also recite processors, storing computing instructions, computer-readable media, SMS text message, hyperlinks, graphical user interface display, the first selection button, the second selection button, the third selection button, the fourth selection button, a fifth selection button, a seventh selection button, an eighth selection button, payment application, and a input pad as additional elements. However, the use of these additionally elements are described at a high level of generality and perform generic computer functions such that it amounts to no more than mere instruction to apply the exception to a particular technological environment. Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaning limits on practicing the abstract idea. Thus, Applicant’s arguments are not persuasive.
(2) “B. Under Step 2B, Amended Independent Claims 1 and 11 Recite an Inventive Concept by Adding Specific Limitations that Are Not Well-Understood, Routine, or Conventional Activity in the Field” (see remarks, pages 15-16):
Applicant’s arguments that “Applicant respectfully submits that the ordered combination of limitations of amended independent claims 1 and 11 add specific limitations that are improvements beyond what is well understood, routine, or conventional in the field” (see remarks, page 16), are not found persuasive.
Response (2): As set forth in the previous Office Action, Examiner considers that the claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements when considered both individually and as an ordered combination do not amount to significantly more than the abstract idea(s). As discussed above with respect to integration of the abstract idea into a practical application, the additional element of using a processor to perform the abstract idea(s) amounts to no more than mere instructions to apply the exaction using a generic computer component. Mere instruction to apply an exception using a generic computer component cannot provide an inventive concept. These generic computer components are claimed at a high level of generality to perform their basic functions which amount to no more than generally linking the use of the judicial exception to the particular technological environment of field of use (See specification, [0059-0060]: a single computer, a cluster or collection of computers, servers, a cloud of computers, a database, a communication module, a data module, a risk engine, calculation engine, Internet, and computer data network).
Furthermore, in Berkheimer, the limitations recited in amended independent claims 1 and 11 are not well-understood, routine, or conventional. The Examiner notes that the steps of the claims, taken individually or as an ordered combination, have been identified as corresponding to an abstract idea. The additional elements in the claim are processors, storing computing instructions, computer-readable media, data communication, operating the transaction system, real-time payment transaction, SMS text message, hyperlinks, graphical user interface display, the first selection button, the second selection button, the third selection button, the fourth selection button, a fifth selection button, a seventh selection button, an eighth selection button, payment application, and a input pad (Independent claim 1). Furthermore, it is clear, through a plain reading of Applicant’s specification, that the computing processors are suitably programmed to perform the abstract ilea, see at least paragraphs [0164]. The claims at issue do not require any nonconventional computer, network, or other components, or even a non-conventional and non-generic arrangement of known, conventional pieces but merely call for performance of the claimed functions on a set of generic computer components. The elements of the instant process, when taken alone, each execute in a manner conventionally expected of these elements. The elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone.
According to the USPTO guidelines of April 19, 2018 incorporating the Berkheimer memo (Berkheimer memo, hereinafter), in a step 2B analysis, an additional element (or combination of elements) is not well-understood, routine or conventional unless the examiner finds, and expressly supports a rejection in writing with, one or more of the following:
1. A citation to an express statement in the specification or to a statement made by an applicant during prosecution that demonstrates the well-understood, routine, conventional nature of the additional element(s).
2. A citation to one or more of the court decisions discussed in MPEP § 2106.05(d)(II) as noting the well-understood, routine, conventional nature of the additional element(s).
3. A citation to a publication that demonstrates the well-understood, routine, conventional nature of the additional element(s).
4. A statement that the examiner is taking official notice of the well-understood, routine, conventional nature of the additional elements). This option should be used only when the examiner is certain, based upon his or her personal knowledge, that the additional elements) represents well-understood, routine, conventional activity engaged in by those in the relevant art, in that the additional elements are widely prevalent or in common use in the relevant field, comparable to the types of activity or elements that are so well-known that they do not need to be described in detail in a patent application to satisfy 35 U.S.C. § 112(a).
The fact that a generic computing system such as described above can be suitably programmed, may be used to perform the claimed method and the fact that the claims at issue do not require any nonconventional computer, network, or other components, or even a “non- conventional and non-generic arrangement of known, conventional pieces” but instead merely call for performance of the claimed functions on a set of generic computer components, satisfies the Berkheimer memo requirement that the additional elements are conventional elements (as outlined in criterion 1 of the Berkheimer memo). The elements of the instant process, when taken alone, each execute in a manner conventionally expected of these elements. The elements of the instant process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. Hence these additional elements do not add anything significantly more than an abstract idea. Thus, Applicant’s arguments are not persuasive.
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 1-2, 4-12, and 14-22 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter without significantly more.
When considering subject matter eligibility under 35 U.S.C. 101, (1) it must be determined whether the claim is directed to one of the four statutory categories of invention, i.e., process, machine, manufacture, or composition of matter. If the claim does fall within one of the statutory categories, (2a) it must then be determined whether the claim is directed to a judicial exception (i.e., law of nature, natural phenomenon, and abstract idea), and if so (2b), it must additionally be determined whether the claim is a patent-eligible application of the exception. If an abstract idea is present in the claim, any element or combination of elements in the claim must be sufficient to ensure that the claim amounts to significantly more than the abstract idea itself. Examples of abstract ideas include fundamental economic practices; certain methods of organizing human activities; an idea itself; and mathematical relationships/formulas. Alice Corporation Pty. Ltd. v. CLS Bank International, et al., 573 U.S. (2014).
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. In the instant case, the claim(s) as a whole, considering all claim elements both individually and in combination, do not amount to significantly more than an abstract idea.
Step (1): In the instant case, the claims are directed towards to a method for performing the financial transaction that relates to providing security in transactions, e.g., transferring funds between entities, which contains the steps of receiving, registering, determining, providing, facilitating, and identifying. The claim recites a series of steps and, therefore, is a process. The claims do fall within at least one of the four categories of patent eligible subject matter because claim 1 is direct to a system and claim 11 is direct to a process, i.e. machines programmed to carrying out process steps, Step 1-yes.
Step (2A) Prong 1: A method for performing the financial transaction that relates to providing security in transactions, e.g., transferring funds between entities, is akin to the abstract idea subject matter grouping of: Certain Methods of Organizing Human Activity as ‘fundamental economic principles or practices’ and ‘commercial or legal interactions’. As such, the claims include an abstract idea.
The specific limitations of the invention are (a) identified to encompass the abstract idea include: {…. receiving, at a transaction system, a request to register a second entity under a certified biller status using a second account maintained at a second financial institution, the request comprising a public identifier for the second entity, the transaction system being in data communication with a first financial institution and the second financial institution, and an entity operating the transaction system being different from the first financial institution and the second financial institution; registering the second entity under the certified biller status after receiving confirmation that the public identifier corresponds to the second entity and that the second account is held by the second entity, wherein the second entity qualifies for the certified biller status based on the entity operating the transaction system performing due diligence to verify that the public identifier and the second account legitimately belong to the second entity, and wherein the second entity comprises a governmental entity; determining if a first account of a first entity maintained at the first financial institution is capable of real-time payment transactions and if the first account is authorized to participate in the real-time payment transactions, wherein determining if the first account is capable of the real-time payment transactions comprises: receiving, from the first financial institution, updated account data for the first account; determining a payment likelihood indicator based at least in part on a status and a current available balance of the first account as updated by the updated account data, wherein the payment likelihood indicator is determined by applying one or more rules comprising: determining whether the first account is currently open based on intra-day status; determining whether the current available balance of the first account adjusted by pending transactions is greater than an amount specified by an invoice by at least a predetermined threshold amount; determining whether the amount specified by the invoice is consistent with historical spending patterns of the first entity; providing, from the transaction system to the first entity, first information that identifies the second entity as satisfying the certified biller status, wherein the first information comprises a first logo associated with the certified biller status that identifies the second entity as satisfying the certified biller status; monitoring a message format of the authorization for invalidity; providing, from the transaction system to the first entity, an alert in real-time when the message format is invalid; facilitating a real-time payment transaction from the first account maintained by the first financial institution to the second account maintained by the second financial institution, wherein the real-time payment transaction pays the invoice, wherein: the certified biller status represents a security status for the public identifier as associated with the second entity to increase security for the real-time payment transaction and to prevent fraud from occurring in the real-time payment transaction; the invoice comprises an interactive invoice originating from the second entity; …….. the first financial institution maintains a first settlement account; the first settlement account is credited for the payment amount to account for a successful debit of the first account held by the first entity at the first financial institution for the payment amount; the second financial institution maintains a second settlement account; the second settlement account is debited for the payment amount to account for a successful credit to the second account held by the second entity at the second financial institution for the payment amount; funds for the payment amount are transferred from the first settlement account to the second settlement account in a settlement completion that occurs after the successful credit is made to the second account for the payment amount; the second entity does not receive an account number of the first account to increase security of the first account and to decrease fraud; the first entity does not receive an account number of the second account to increase security of the second account and to decrease fraud.}
As stated above, this abstract idea falls into the (b) subject matter grouping of: Certain Methods of Organizing Human Activity as ‘fundamental economic principles or practices’ and ‘commercial or legal interactions’ for performing the financial transaction that relates to providing security in transactions, e.g., transferring funds between entities.
Step (2A) Prong 2: The instant claims do not integrate the exception into a practical application because additional elements: (a) “a device profile”, “a device identifier” and “mobile network” amount to simply applying the abstract idea to a computer network and/or a computer component (e.g. “apply it”), (b) “the first selection button is operable to navigate to a second graphical user interface display”, “the second selection button and the third selection button are operable to navigate to a third graphical user interface display”, and “the fourth selection button, the fifth selection button, the seventh selection button are operable to navigate to a fifth graphical user interface” describe selecting elements to a generic device (e.g. a graphical user interface). For example, the “the first selection button” is not described in the specification in such a way require anything more than merely a generically “interactive” display, and therefore also amounts to simply applying the abstract idea to a generic device and client combination (e.g. “apply it” or the equivalent), and (c) “selection button”, again describes a generically interactive element, which amounts to simply applying the abstract idea of filtering on a computer (e.g. on a web browser) do not apply, rely on, or use the judicial exception in a manner that that imposes a meaningful limitation on the judicial exception (i.e. apply it with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea - see MPEP 2106.05(f)).
The instant recited claims including additional elements (i.e. processors, storing computing instructions, computer-readable media, SMS text message, hyperlinks, graphical user interface display, the first selection button, the second selection button, the third selection button, the fourth selection button, a fifth selection button, a seventh selection button, an eighth selection button, payment application, and a input pad) do not improve the functioning of the computer or improve another technology or technical field nor do they recite meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment. The limitations merely use a generic computing technology (Specification paragraphs [0059-0060]: a single computer, a cluster or collection of computers, servers, a cloud of computers, a database, a communication module, a data module, a risk engine, calculation engine, Internet, and computer data network) as apply it with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea - see MPEP 2106.05(f)). Therefore, the claims are directed to an abstract idea.
Step (2B): When considered both individually and as an ordered combination, the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements (Claims: e.g., processors, storing computing instructions, computer-readable media, SMS text message, hyperlinks, graphical user interface display, the first selection button, the second selection button, the third selection button, the fourth selection button, a fifth selection button, a seventh selection button, an eighth selection button, payment application, and a input pad) amount to no more than generally linking the use of the judicial exception to a particular technological environment or merely using generic components as tool to perform an abstract idea.
There is a fundamental difference between computer functionality improvements, on the one hand, and uses of existing computers as tools to perform a particular task, on the other. There is nothing, for example, in the pending claims to suggest that any of the claimed one or more “processors”, suitably programmed, are somehow made more efficient or that the manner in which these elements carry out their basic functions is otherwise improved in any way. Any advantages from the claimed invention do not concern an improvement in computer capabilities but instead relate to an alleged improvement in the fundamental economic practice of providing a financial transaction, e.g. transferring funds, for which a computer is used as a tool in its ordinary capacity.
The computer is merely a platform on which the abstract idea is implemented. Simply executing an abstract concept on a computer does not render a computer “specialized,” nor does it transform a patent-ineligible claim into a patent-eligible one. See Bancorp Servs., LLC v. Sun Life Assurance Co. of Can., 687 F.3d 1266, 1280 (Fed. Cir. 2012). There are no improvements to another technology or technical field, no improvements to the functioning of the computer itself, transformation or reduction of a particular article to a different state or thing or any other meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment as a result of performing the claimed method. Also, the addition of merely novel or non-routine components to the claimed idea does not necessarily turn an abstraction into something concrete (See Ultramercial, Inc. v. Hulu, LLC, _ F.3d_, 2014 WL 5904902, (Fed. Cir. Nov. 14, 2014). Hence, the claims do not recite significantly more than an abstract idea.
In conclusion, merely “linking/applying” the exception using generic computer components does not constitute ‘significantly more’ than the abstract idea. (MPEP 2106.05 (f)(h)). Therefore, the claims are not patent eligible under 35 USC 101.
Dependent claims 2, 4-10, 12, and 14-22 when analyzed as a whole and in an ordered combination are held to be patent ineligible under 35 U.S.C. 101 because the additional recited limitation(s) fail(s) to establish that the claim(s) is/are not directed to an abstract idea, as detailed below. The additional recited limitations in the dependent claims only refine the abstract idea.
For instance, in claims 2 and 12, the step of “… the interactive invoice comprises an option to pay the invoice immediately” (i.e. providing an option to pay the invoice), in claims 4 and 14, the step of “… the interactive invoice comprises information about a reward that can be applied toward paying the invoice…” (i.e. providing an option to pay the invoice), in claims 5 and 15, the step of “… the first information that identifies the second entity as satisfying the certified biller status …” (i.e. identifying an entity), in claims 6 and 16, the step of “… the second entity is identified as one of the recommended billers for the first entity based on second information received from the first financial institution...” (i.e. identifying an entity), in claims 7 and 17, the step of “… the first information that identifies the second entity as satisfying the certified biller status also identifies the second entity as one of recommended...” (i.e. identifying an entity), in claims 8 and 18, the step of “… receiving a current location of the first entity….” (i.e. receiving a location of the entity), in claims 9 and 19, the step of “… receiving a current balance of the first account….” (i.e. receiving a current balance), in claims 10 and 20, the step of “… the real-time payment transaction involves a promise-to-pay message sent to the second financial institution from the first financial institution after a successful debit…” (i.e. performing a settlement) , and in claims 21 and 22, the step of “… receiving a current location of the first entity; and providing, to the first entity, an offer for a loan….” (i.e. receiving a location of the entity) are all processes that, under its broadest reasonable interpretation, covers performance of a fundamental economic practice but for the recitation of a generic computer component. For example, receiving a location of the user and providing an offer for a loan to the user based on the current location of the user is a most fundamental commercial process.
This is an abstract concept with nothing more and is also considered mere instructions to apply an exception akin to a commonplace business method or mathematical algorithm being applied on a general purpose computer, Alice Corp. Pty. Ltd.; Gottschalk and Versata Dev. Group, Inc.; see MPEP 2106.05(f)(2).
In dependent claims 2, 4-10, 12, and 14-22, the step claimed are rejected under the same analysis and rationale as the independent claims 1 and 11 above. Merely claiming the same process using the financial information or other information of the first user and the second user and then providing a transferring fund or an offer for a loan for the user does not change the abstract idea without an inventive concept or significantly more. Clearly, the additional recited limitations in the dependent claims only refine the abstract idea further. Further refinement of an abstract idea does not convert an abstract idea into something concrete.
Therefore, claims 1-2, 4-12, and 14-22 are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter.
Conclusion
The prior art made of record but not relied upon herein but pertinent to Applicant’s disclosure is listed in the enclosed PTO-892.
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/YONGSIK PARK/Examiner, Art Unit 3694
March 17, 2026
/BENNETT M SIGMOND/Supervisory Patent Examiner, Art Unit 3694