DETAILED ACTION
Acknowledgements
This action is in response to Applicant’s filing on Mar. 26, 2026, and is made Final. This action is being examined by James H. Miller, who is in the eastern time zone (EST), and who can be reached by email at James.Miller1@uspto.gov or by telephone at (469) 295-9082.
Interviews
Examiner interviews are available by telephone or, preferably, by video conferencing using the USPTO’s web-based collaboration platform. Applicants are strongly encouraged to schedule via the USPTO Automated Interview Request (AIR) portal at http://www.uspto.gov/interviewpractice. Interviews conducted solely for the purpose of “sounding out” the examiner, including by local counsel acting only as a conduit for another practitioner, are not permitted under MPEP § 713.03. The Office is strictly enforcing established interview practice, and applicants should ensure that every interview request is directed toward advancing prosecution on the merits in compliance with MPEP §§ 713 and 713.03.
For after-final Interview requests, supervisory approval is required before an interview may be granted. Each AIR should specifically explain how the After-Final Interview request will advance prosecution—for example, by identifying targeted arguments responsive to the rejection of record, alleged defects in the examiner’s analysis, proposed claim amendments, or another concrete basis for discussion. See MPEP § 713. If the AIR form’s character limits prevent inclusion of all pertinent details, Applicants may send a contemporaneous email to the examiner at James.Miller1@uspto.gov.
The examiner is generally available Monday through Friday, 10:00 a.m. to 4:00 p.m. EST.
For any GRANTED Interview Request, Applicant can expect an email within 24 hours confirming an interview slot from the dates/times proposed and providing collaboration tool access instructions. For any DENIED Interview Request, the record will include a communication explaining the reason for the denial.
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 .
Claim Status
The status of claims is as follows:
Claims 1, 4, 8, 9, 11, 14–18, and 21–24 are now pending and examined with Claims 1, 9, and 14 in independent form.
Claims 1, 4, 8, 9, 14, 15, and 16 are presently amended.
Claims 19 and 20 are presently cancelled.
Claims 23 and 24 are presently added.
Response to Amendment
Applicant's Amendment has been reviewed against Applicant’s Specification filed Feb. 13, 2020, [“Applicant’s Specification”] and accepted for examination. No new matter was entered.
Applicant's Amendment to address the rejections under 35 U.S.C. § 112(a) have been reviewed and has overcome each and every rejection under § 112(a) previously set forth in the Non-Final Office Action mailed Oct. 22, 2025 [“Non-Final Office Action"]. The rejection of Claims 1, 4, 8, 9, 11, and 14–22 under § 112(a) is withdrawn.
Response to Arguments
35 U.S.C. § 101 Argument
Applicant agues the claims recite “a technological improvement on data processing and system functionality.” Specifically, the claims recite a specific distributed computer architecture (mobile device, AMVDTS, and remote data sources) that implement a technical data processing pipeline by transforming unstructured images into structured text via OCR and validating that data across multiple external databases without human intervention. This solves a computer-centric problem of reliably validating identify and transaction data across heterogeneous distributed sources and improves system functionality (automated cross-database validation, reduced latency, and increased throughput. Applicant’s Reply at 15.
Examiner’s Response: Applicant's argument is conclusory and fails to comply with 37 CFR 1.111(b) because it amounts to a general allegation that the claims define an eligible invention without specifically pointing out how the language of the claims support Applicant’s assertion. On the merits, the problem of verifying identity and documents for MVD transactions is an administrative/business problem and not a technical one. The computer is used as a tool in a conventional client-server structure to implement the abstract idea. MPEP § 2106.05(f).
Applicant argues that if there is an abstract idea, the calims integrate it into a practical application by enabling end-to-end transaction processing across distributed system components, including mobile devices and kiosks with automated validation, remote completion, and no in-person interaction. The ordered combination of features (OCR extraction, automated cross-referencing of multiple external databases, multi-factor identify checks, and coordinated mobile-kiosk workflows is not routine or conventional. Applicant’s Rely at 16.
Examiner’s Response: Applicant's argument is conclusory and fails to comply with 37 CFR 1.111(b) because it amounts to a general allegation that the claims define an eligible invention without specifically pointing out how the language of the claims support Applicant’s assertion. On the merits, each feature (OCR, external database checks, MFA, mobile apps, kiosks, location services) is individually well known and the claims merely combine them to automate the manual process of MVD services. Further coordinating mobile and kiosk interactions and avoiding in-person visits are business improvements (better service, shorter wait times) and not a technological improvement to a computer’s functioning. The ordered d combination reflects routine use of generic technology without the kids of “how” required for an inventive concept.
Applicant argues the claims are an improvement in technology like Enfish, DDR Holdings, and McRO.
Examiner’s Response: Applicant's arguments is conclusory and fails to comply with 37 CFR 1.111(b) because it amounts to a general allegation that the claims define an eligible invention without specifically pointing out the nexus between the cited cases and the claimed invention. On the merits, the pending claims are distinguished. Enfish claimed a new data structure, unlike here. DDR solved a problem unique to the internet but Applicant’s Specification, which operates as an admission, teaches the same abstract process can be performed manually. Spec. ¶¶ 21, 22, 26, 28, 31. McRO claimed specific rule-based animation techniques and here, the claims do not claim any rules. The present claims use generic computer components and techniques in their ordinary way to automate the administrative process of MVS services. But for the recitation of the generic computer equipment, the claims describe automating motor vehicle services, a manual method long prevalent in our system before the advent of the computer1. “[M]ere automation of manual processes using generic computers does not constitute a patentable improvement in computer technology. In those cases, the focus of the claims is not on such an improvement in computers as tools, but on certain independently abstract ideas that use computers as tools." Credit Acceptance Corp. v. Westlake Servs., 859 F.3d 1044, 1055 (Fed. Cir. 2017); MPEP § 2106.05(a). Here, the claims recite the mere automation of manual processes of existing MVD services using generic (exemplary) computers. Spec. ¶¶ 21, 22, 26, 28, 31. Applicant admits the claims merely “use” facial recognition, optical character recognition (OCR), geolocation, and image analysis in their known way. The facial recognition, OCR, geolocation, and image analysis software is developed outside the scope of the claims and again, merely “used” to automate MVD services. Thus, the focus of the claims is not on such an improvement in computers as tools, but on certain independently abstract ideas that use computers as tools.” MPEP § 2106.05(a).
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, 4, 8, 9, 11, 14–18, and 21–24 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., an abstract idea) without significantly more.
Analysis
Step 1: Claims 1, 4, 8, 9, 11, 14–18, and 21–24 are directed to a statutory category. Claims 1, 4, 8, and 24; and Claims 9 and 11, both recite “methods” and are therefore, each directed to the statutory category of “a process.” Claims 14–18, 21, 22, and 23 recite “a system” and are therefore, directed to the statutory category of “a machine.”
Representative Claim
Claim 14 is representative [“Rep. Claim 14”] of the subject matter under examination and recites, in part, emphasis added by Examiner to identify limitations with normal font indicating the abstract idea exception, bold limitations indicating additional elements. Each limitation is identified by a letter for later use as a shorthand notation in referencing/describing each limitation. Portions of the claim use italics to identify intended use limitations2 and underline, as needed, in further describing the abstract idea exception:
[A] 14. A system for electronically and remotely providing motor vehicle department (MVD) related services to mobile device users, comprising:
[B] an automated motor vehicle department transaction system (AMVDTS) including a control server configured to communicate with government databases via an application programming interface (API);
[C] a mobile device using a mobile application configuring the mobile device to provide a customer with secure and encrypted access to the AMVDTS via a data network, wherein the mobile device is further programmed to;
[D] validate an identity of the customer in cooperation with the AMVDTS via facial recognition [software],
[D1] wherein an image of a face of the customer is compared with government records including identification card photographs stored in a remote server, and
[D2] wherein validation includes two-stage authentication comprising a biometric match in combination with a code received on a mobile device via electronic message,
[D3] wherein the validation is performed across a plurality of remotely located data sources accessible over the data network;
[E] enable the customer to select a transaction at the mobile device from a list of services provided by the AMVDTS via the mobile application including no less than driver's licensing, vehicle registrations, and vehicle title transfers;
[F] present instructions from the AMVDTS for a service selected by the customer at the mobile device in a step- by-step fashion electronically via the mobile device and the mobile application to enable the customer to complete and validate a transaction with the AMVDTS;
[G] enable the customer to provide customer data including documents regarding the transaction via the mobile device over the data network to the AMVDTS,
[G1] wherein the AMVDTS validates the pertinent data including the documents utilizing validation data resources accessible by the AMVDTS further including third party records accessible over the data network from a remote server, and
[G2] wherein optical character recognition is used by the AMVDTS to extract text from the documents, wherein the optical character recognition converts unstructured image data into structured text data usable for automated validation;
[G3] the AMVDTS further performing automated image analysis to detect document quality issues including blur, glare, or incompleteness and performs fraud detection by comparison to external data sources;
[H] enable functional MVD kiosk location determination by the mobile device and the AMVDTS,
[H1] based on the location of the mobile device in a community,
[H2] for printing of official documents at an MVD kiosk following processing of the valid payment by the AMVDTS,
[H3] wherein the location of the mobile device is determined utilizing one or more of GPS, data network communication, signal strength and triangulation with respect to the mobile device, and
[H4] wherein the AMVDTS identifies a functional kiosk; and
[I] rendering the official documents at the MVD kiosk with a printer associated with the MVD kiosk, the MVD kiosk printing after verifying a transaction record transmitted from the AMVDTS.
Claims are directed to an abstract idea exception.
Step 2A, Prong One: Step 2A, Prong One: Rep. Claim 14 recites [A] “providing motor vehicle department (MVD) related services” that includes [D] validating an identity of the customer (as a human MVD clerk would do) via comparison of facial biometric information, [D1] wherein an image of a face of the customer is compared with government records including identification card photographs (as a human clerk compares a customer's face to a government-issued ID photograph) [D3] wherein the validation is performed across a plurality of remotely located data sources (as a human clerk consults multiple government record sources); [E] enabling the customer to select a transaction from a list of services including driver's licensing, vehicle registrations, and vehicle title transfers (as a human MVD clerk presents a customer with available service options); [F] presenting instructions for a service selected by the customer in a step-by-step fashion to enable the customer to complete and validate a transaction (as a human MVD clerk guides a customer through the steps required to complete a governmental transaction); [G] enabling the customer to provide customer data including documents regarding the transaction (as a human MVD clerk collects documents from a customer); [G1] wherein the pertinent data including the documents are validated utilizing validation data resources including third party records accessible from a remote server (as a human MVD clerk cross-references submitted documents against government and third-party record sources); and [H4] wherein a functional service location is identified (as a human MVD clerk or customer identifies an available and operational service window or kiosk). These limitations recite the abstract idea exception of (1) a mental process of collecting and comparing a customer's facial biometric information against stored government identification records to verify identity, which is a concept that can be practically performed in the human mind or by a human clerk visually comparing a customer's face to a photograph on a government-issued identification card and consulting government records; MPEP § 2106.04(a)(2)(I), and (2) certain methods of organizing human activity, specifically a commercial and governmental transaction, of the type that human motor vehicle department clerks have historically performed manually by guiding customers through service selection, collecting and reviewing documents submitted for a transaction, cross-referencing those documents against government and third-party record sources, and directing customers to an available and functional service location. MPEP § 2106.04(a)(2)(II).
Step 2A, Prong Two: The additional elements identified in Rep. Claim 14, considered individually and as an ordered combination, do not integrate the abstract idea exception into a practical application. MPE § 2106.04(d).
The additional elements are limited to the computer components and indicated in bold, supra. The additional elements are: A system comprising: Limitations B, C, a remote server, Limitations D2, G2, G3, H, H1, H3, and I.
The additional elements do not improve the functioning of a computer or other technology. MPEP § 2106.05(a).
A claim improves technology only when it recites a specific improvement to the way a computer itself operates, not merely the application of an existing process using a computer. MPEP § 2106.05(a) (citing Enfish, LLC v. Microsoft Corp., 822 F.3d 1327, 1336 (Fed. Cir. 2016)). Here, the abstract idea exception of (1) verifying a customer’s identity by collecting and comparing a customer's facial biometric information against stored government identification records and (2) guiding an MVD transaction through service selection, collecting and reviewing documents, cross-referencing those documents against government and third-party record sources, and directing customers to an available and functional service location was previously performed manually by human MVD clerks. Spec. ¶¶ 2, 4, 5, 6, 7, 10. Because the process can be performed manually, the computer is not being improved and is merely being used as a tool to perform the pre-existing manual process. Applying a pre-existing manual process using generic computer components is not an improvement to computer technology.
The specification confirms this characterization by describing the advantages of the claimed system in terms of business outcomes (shorter wait times, reduced fraud, elimination of human clerk error), rather than in terms of any specific technical improvement to the computer, server, mobile device, or network infrastructure itself. Spec. ¶¶ 7, 9, 10, 11, 31. The specification does not describe any specific technical improvement to validation algorithms, OCR, image analysis methods, network communication protocols, encryption, or geolocation. Spec. ¶¶ 21–31. Although the claims recite OCR (Limitation G2) and image analysis (Limitation G3), these processes are described in the specification only at a high functional level without disclosing any specific algorithm, data structure, or technical implementation by which these results are achieved. Spec. ¶ 30 (“The AMVDTS can detect the quality of the documents. Optical character recognition can be used by the AMVDTS to extract text from the documents. Text extracted from the documents can be presented to the customer for validation,” which confirms OCR is described only as producing a result and not implementing a technical process.). Similarly, although the claims recite facial recognition (Limitation D), the specification teaches that this functionality is provided by a third-party under an “SLA” (service level agreement) with DoD, Homeland Security, and federal/state police. Spec. ¶¶ 21, 31. A service level agreement is a contractual and business arrangement and not a technical implementation. Further, the technical execution of facial recognition is performed entirely by third parties outside the scope of both the claims and the specification. Id. This confirms Limitation D recites only a functional result of an outsourced comparison process without claiming any specific technical means of performing it. Thus, none of the additional elements reflect a specific technical improvement to the functioning of a computer or other technology.
The additional elements are mere instructions to apply the abstract idea exception. MPEP § 2106.05(f).
Each additional element is recited only in terms of the functional result it achieves, without specifying the technical means by which that result is accomplished. Additionally, Applicant’s Specification does not otherwise describe the additional elements with specificity beyond exemplary language or describes them as a general-purpose computer, as a part of a general-purpose computer, or as any known and exemplary (generic) computer component known in the prior art. The specification’s own broad, exemplary characterization confirms that these components are not described in a manner that would impose any specific technical limitation that would integrate the abstract idea into a practical application. Thus, Applicant takes the position that such hardware/software is so well known to those of ordinary skill in the art that no explanation is needed under 35 U.S.C. § 112(a). Lindemann Maschinenfabrik GMBH v. Am. Hoist & Derrick Co., 730 F.2d 1452, 1463 (Fed. Cir. 1984) (citing In re Meyers, 410 F.2d 420, 424 (CCPA 1969) (“[T]he specification need not disclose what is well known in the art”). E.g., Spec. ¶¶ 21, 22, 23, 24, 25 (describing the control server, mobile device, mobile application, data network, and kiosk using broad exemplary language, such as “e.g.,” “such as,” “can include,” “for example,” which confirms that no specific technical implementation is required or disclosed); ¶ 21 (network described as an open-ended list of any known network, which confirms the network is generic); ¶ 25 (kiosk described as including “any of” a camera, scanner, user interface, biometric reader, printer, or payment mechanism which are all generic hardware performing their ordinary functions).
The additional elements do not apply the abstract idea with a particular machine.
Although the claims recite specific hardware components (i.e., control server, mobile device, mobile application, remote server, databases, MVD kiosk), these components are recited at a high functional level and perform only their generic functions of receiving, transmitting, storing, and processing data. Spec. ¶¶ 21–25. A machine is “particular” only when it imposes a meaningful limit on the claims scope. MPEP § 2106.05(b). Here, any server communicating via an API, any mobile device running any mobile application, and any kiosk with a any printer would satisfy the calims hardware requirements, which confirms that the hardware components are generic rather than “particular.” MPEP § 2106.05(b).
The additional elements, considered as an ordered combination, do not integrate the abstract idea into a practical application.
Considering the additional elements together as an ordered combination Rep. Claim 14 describes a system where a generic mobile application on a generic mobile device provides encrypted access to a generic control server (Limitations B, C); the server verifies identity using a third party facial recognition service operating under a SLA and 2FA (Limitation D2); processes uploaded documents using functionally claimed OCR and image analysis (Limitations G2, G3); determines device location using functionally claimed geolocation technologies (Limitations H, H1, H3); and prints official documents at a generic kiosk printed upon verification (Limitation I). This ordered arrangement does not reflect as specific technical architecture. Rather, it describes the application of generic computer components to perform the abstract idea.
Therefore, the claim as a whole, considering the additional elements individually and as an ordered combination, amounts to no more than mere instructions to apply the abstract idea using generic computer components and is not a practical application. MPEP § 2106.05(f). The additional elements do not integrate the abstract idea exception into a practical application because they do not impose any meaningful limits on the abstract idea exception. Accordingly, Rep. Claim 14 is directed to an abstract idea.
Independent Claims 1 and 9 are not substantially different than Rep. Claim 14 and include all the limitations of Rep. Claim 14. Independent Claims 1 and 9 contain no additional elements not otherwise analyzed for Rep. Claim 14. Therefore, Independent Claims 1 and 9 are also directed to the same abstract idea.
The claims do not provide an inventive concept.
Step 2B: Rep. Claim 14 fails Step 2B because the claim as a whole, even when considering the additional elements individually and in combination, does not amount to significantly more than the abstract idea. MPEP § 2106.05. The additional elements (i.e., A system comprising: Limitations B, C, a remote server, Limitations D2, G2, G3, H, H1, H3, and I), are each well-understood, routine, and conventional (“WRC”) computer components and functions in the relevant field, as evidenced by Applicant’s own disclosure3. Further, Applicant’s Specification discloses that these components operate in no particular order and are implemented using generic, off-the-shelf computing technology. Spec. ¶ 20 (steps/functions may be performed in any order or concurrently); ¶¶ 21, 22, 23, 24, 25 (describing each component using exemplary language as generic or known computing equipment and networks).
Limitation B is WRC. A control sever configured to communicate with government databases via an API is a conventional server performing its ordinary database communications through a standard interface. The specification describes this in general terms without specifying any API protocol, data structure, or server configuration. Spec. ¶¶ 20, 21, 31.
Limitation C is WRC. A mobile device using a mobile application to provide encrypted access to a server via a data network describes conventional mobile hardware running conventional application software and performing conventional communication functions. The specification describes the mobile device and mobile application in general functional terms without specifying any encryption protocol or security architecture. Spec. ¶¶ 21, 22, 23, 24.
A remote server is WRC. A remote server storing photographs describes a conventional function of a server, i.e., to store data and permit access to stored data. The specification describes the remote server in general terms as any server. Spec. ¶ 21.
Limitation D2 is WRC. Two-stage authentication combining a biometric match with a code received via electronic messaging describes a conventional 2FA process. Both biometric verification and one-time code delivery via electronic messaging are WRC techniques. The specification describes authentication only at a high functional level without specifying any biometric matching algorithm, token generation, or messaging delivery protocol and relies entirely on third-party SLA-based services for the facial recognition functions. Spec. ¶¶ 9, 21, 31.
Limitations G2 and G3 are WRC. Limitations G2 and G3 describe conventional data processing technologies performing their ordinary functions. The specification describes both capabilities using permissive functional “can” language without disclosing any specific algorithm, image processing technique, or fraud detection methodology. Spec. ¶¶ 9, 30.
Limitations H, H1 and H3 are WRC. These limitations describe WRC technologies performing their ordinary functions. The specification describes these technologies using permissive functional language without specifying any location algorithm or technical implementation. Spec. ¶¶ 24, 26.
Limitation I is WRC. Limitation I describes a generic printer performing its ordinary print function. The specification describes the printer as one of the generic hardware components listed in an “any of” list and describes document printing at a high functional level without specifying any rendering algorithm or technical implementation. Spec. ¶ 25, 28, 30.
The Specification further confirms that the functions of receiving, storing, transmitting, and processing data are normal, well-understood operations of generic computer systems, and the steps may be performed in any order or concurrently. See, e.g., Spec. ¶¶ 20, 21.
The combination is also WRC at the high level of generality recited:
The combination of the additional elements is likewise WRC. A combination of individually well-understood, routine, and conventional elements does not provide an inventive concept unless the combination itself produces an unconventional result or is applied in an unconventional manner. MPEP § 2106.05(d)(2). Here, the combination performs each step in exactly the manner described as conventional throughout Applicant’s own Specification. There is no indication that the combination of these elements operates in an unconventional manner or produces a result that is other than what would be expected from the generic application of these individual components. Spec. ¶¶ 20–31.
Unlike BASCOM, where the claims recited a specific non-conventional arrangement of installing a filtering tool at a specific network location rather than on individual devices, Rep. Claim 14 does not recite how the elements are combined in a non-conventional way. The claims recite each element at a high level of generality without specifying the particular arrangement or order that constitutes the alleged improvement. At the high level of generality recited, the combination is WRC. Because the claims here recite only generic components performing generic functions at a high level of generality, the abstract idea recited in claims cannot be improved by a computer. MPEP § 2106.05(f). No inventive concept is present under Step 2B. MPEP § 2106.05(d).
Accordingly, the additional elements of Rep. Claim 14 have been recognized, based on Applicant’s own disclosure, as WRC activity in the field. MPEP § 2106.05(d). These elements do no more than “apply” the recited abstract idea(s) using known computer and computer-related components. See also Step 2A, Prong Two, supra.
Independent Claim 1 is a method that performs the same abstract processing and generic computer operations recited in Rep. Claim 14. Independent Claim 9 is also a method that performs the same abstract processing and generic computer operations recited in Rep. Claim 14. Independent Claims 1 and 9 add no additional elements beyond those of Rep. Claim 14 that would amount to significantly more than the abstract idea. Therefore, Independent Claims 1 and 9 also do not recite an inventive concept under Step 2B.
Dependent Claims Not Significantly More
The dependent claims have been given the full two-part analysis including analyzing the additional limitations both individually and in combination with the elements of the independent claims. Each dependent claim incorporates all the limitations of its parent Independent Claim and therefore recites the same abstract idea. The additional limitations recited in the dependent claims do not integrate the abstract idea exception into a practical application under Step 2A, Prong Two, and do not amount to significantly more than the abstract idea under Step 2B, for the following reasons:
Dependent Claims 4, 8, 11, 15–18, and 21–24 all recite "wherein" clauses or limitations that further specify the abstract idea of the independent claims and contain no additional elements not otherwise analyzed above. Regarding Dependent Claims 4, 11, and 15, the two-stage authentication via code entry technique is recited without any description of a specific implementation in the specification. Because the specification does not describe any specific two-stage authentication technique, under BRI this limitation encompasses the well-known two-factor authentication (2FA) technique. Under established precedent, an applicant need not describe in detail what is well known in the art, and by omitting any description of this technique the applicant implicitly concedes it is a well-understood, routine, and conventional technique that requires no further description. Lindemann Maschinenfabrik GMBH v. Am. Hoist & Derrick Co., 730 F.2d 1452, 1463 (Fed. Cir. 1984); In re Meyers, 410 F.2d 420, 424 (CCPA 1969). Accordingly, the examiner finds the 2FA technique to be well-understood, routine, and conventional activity in the particular field of this invention based on Applicant's own disclosure. See Spec. ¶ 0031. Alternatively, Church et al. (U.S. Pat. Pub. No. 2018/0227128) (cited PTO-892) is prior art in the same authentication field and provides additional evidence of the conventionality of 2FA. See Church, ¶ 0003 ("Two-factor authentication (2FA) is often used to authenticate users during sign-on."); see also ¶¶ 0058, 0059, Fig. 2.
Regarding Dependent Claim 16, the timing of 2FA occurring after an initial registration step has also been recognized as well-understood, routine, and conventional activity in the particular field of this invention based on Applicant's own disclosure and merely operates on the generic components already analyzed above. Alternatively, Church et al. (U.S. Pat. Pub. No. 2018/0227128) (cited PTO-892) provides additional evidence of the conventionality of 2FA occurring after initial registration. See Church, Title ("Secure Device Registration for Multi-Factor Authentication"); see also ¶¶ 0043, 0044, 0045 (registration occurs before 2FA in step 88), Fig. 2. The abstract idea itself cannot provide the inventive concept or practical application. MPEP § 2106.05(d)(III); MPEP § 2106.04(d)(3).
Dependent Claim 21 further specifies that multi-factor authentication comprises a biometric facial recognition match combined with a time-based one-time password (TOTP) transmitted via a secure channel to the mobile device, with access permitted only after successful verification of both factors. TOTP is a named but well-known authentication standard and "secure channel" is a functional description of encryption without specifying any protocol or technical implementation. The specification does not describe TOTP or secure channel transmission with any technical specificity. See Spec. ¶¶ 0030, 0031. Under Berkheimer, the applicant's failure to describe these techniques with any technical specificity confirms they are well-understood, routine, and conventional in the authentication field and a conclusion further supported by Church et al. (U.S. Pat. Pub. No. 2018/0227128). Multi-factor authentication combining biometrics with time-based codes is conventional. See Church ¶¶ 43, 44, 45, 58, 59. The claim's concluding "thereby improving system security and preventing unauthorized access" language recites only a desired functional result of any authentication system and does not supply an inventive concept.
Dependent Claim 22 further specifies that the AMVDTS analyzes documents for quality deficiencies and extracts text using OCR for cross-referencing with "heterogeneous government and third-party databases" to detect fraud. This limitation adds only a further functional description of what databases are queried (i.e., "heterogeneous government and third-party databases") without specifying any technical means for performing the cross-referencing, any specific database query protocol, or any fraud detection algorithm. Any system performing OCR and querying multiple external databases would satisfy this limitation, confirming it is generic. The specification confirms this by describing the cross-referencing function only at a high functional level relying entirely on third-party SLA-based services. See Spec. ¶¶ 9, 30, 31. The claim's concluding "thereby improving the accuracy, reliability, and security of document validation" language recites only desired functional outcomes and does not supply an inventive concept.
Dependent Claim 23 recites that the AMVDTS automatically validates extracted document data by comparing structured text data to records from a plurality of external databases to detect inconsistencies indicative of invalid or fraudulent data. This limitation recites no additional hardware, software, or technical implementation beyond what is already present in Claim 14. Rather, it further narrows the abstract idea recited in Rep. Claim 14. The abstract idea itself cannot provide the inventive concept or practical application. MPEP § 2106.05(d)(III); MPEP § 2106.04(d)(3). Additionally, this limitation recites only the functional result of a data comparison without specifying any algorithm, detection methodology, or technical implementation by which inconsistencies are identified. The specification describes this function generically using permissive language without any specific technical disclosure. Spec. ¶¶ 30, 31.
Dependent Claim 24 recites that validation and transaction processing are performed without requiring in-person interaction, thereby reducing system processing latency and improving throughput. The limitation "without requiring in-person interaction" is a negative limitation that characterizes the mode of operation (remote versus in-person) without adding any positive technical feature. Performing a previously in-person process remotely using a computer network is precisely the abstract idea of automating a pre-existing manual process. The abstract idea itself cannot provide the inventive concept or practical application. MPEP § 2106.05(d)(III); MPEP § 2106.04(d)(3). The claim's "thereby reducing system processing latency and improving throughput" language recites only the expected and conventional results of any automated remote processing system versus in-person processing and does not supply an inventive concept. The specification confirms that remote processing is described exclusively in terms of business outcomes ("near ZERO wait time via mobile app") rather than any specific technical improvement. Spec. ¶ 11.
Conclusion
Claims 1, 4, 8, 9, 11, 14–18 and 21–24 are therefore drawn to ineligible subject matter as they are directed to an abstract idea without significantly more. The analysis above applies to all statutory categories of invention. As such, the presentment of Rep. Claim 14 otherwise styled as another statutory category is subject to the same analysis.
Examiner Statement of Prior Art—No Prior Art Rejections
Based on the prior art search results, the prior art of record fails to anticipate or render obvious the claimed subject matter of Independent Claims. While some individual features of Independent Claims may be shown in the prior art of record—no known reference, alone or in combination, would provide the invention of Independent Claims. The prior art most closely resembling the applicant’s claimed invention are:
Thomson (U.S. Pat. Pub. No. 2015/0058211) is pertinent because it discloses an mobile application and mobile device for transitions involving motor vehicles. Thomson, ¶¶ 9, 29.
Davis (U.S. Pat. Pub. No. 2005/0273621) is pertinent because it discloses a variety of technologies that can be employed by state departments of motor vehicles (DMVs), and other agencies, e.g., to reduce customer wait time and otherwise improve customer satisfaction, to streamline workflow, and to enhance security.
McCauley (U.S. Pat. Pub. No. 2017/0308906) is pertinent because it discloses systems and methods for updating a vehicle record maintained in an MVD database.
FOR: Int. Pat. Pub. No. WO 01/22317 A2 is pertinent because it discloses A system and method for online vehicle registration using interactive communication between the user and server to effectively result in a plate/document/article (e.g., license plate, sticker) order for production/distribution.
NPL: Easy and Free DMV Fee Lookup, 2019 is pertinent because it discloses California’s most trusted online vehicle registration service.
NPL: Virginia Department of Motor Vehicles, 2019 is pertinent because it discloses interfaces of the Virginia Department of Motor Vehicles.
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 JAMES H MILLER whose telephone number is (469)295-9082. The examiner can normally be reached M-F: 10- 4 PM (EST).
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Bennett M Sigmond can be reached at (303) 297-4411. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/JAMES H MILLER/Primary Examiner, Art Unit 3694
1 Patrascu, Daniel “How the License Plate Was Introduced” Oct. 14, 2018 (The first vehicle registration occurred in 1893) (cited herein on PTO-892)
2 Statements of intended use fail to limit the scope of the claim under BRI. MPEP § 2103(I)(C).
3 See Changes in Examination Procedure Pertaining to Subject Matter Eligibility, Recent Subject Matter Eligibility Decision (Berkheimer v. HP, Inc.), 3-4, https://www.uspto.gov/sites/default/files/documents/memo-berkheimer-20180419.PDF (April, 18, 2018) (That additional elements are well-understood, routine, or conventional may be supported by various forms of evidence, including "[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).").
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