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 .
Status of Claims
This action is in reply to the response filed on January 9, 2026.
Claims 1, 5, and 9-11 were amended.
Claim(s) 1-20 are currently pending and have been examined.
This action is made Non-Final.
Continued Examination Under 37 CFR 1.114
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 January 9, 2026 has been entered.
Response to Arguments
Applicant argued that Examiner’s 101 rejection was improper because Examiner’s previous Office Action did not explain how accessing accounting information from an accounting software system recites a legal or commercial interaction. Examiner disagrees. Applicant has amended the claimed invention to replace language describing the generation of a tax return or a financial statement with generic language describing the generation of one or more files. However, Applicant’s amended claimed invention recites a fundamental economic practice because it recites a process to generate one or more files based on transaction data and account type. Using transaction data and account type data to generate files is fundamental to accounting, and the accounting of economic activity is a fundamental economic practice. Therefore, Examiner finds Applicant’s argument non-persuasive.
Applicant argued that Examiner’s 101 rejection was improper because the claims integrate any alleged judicial exception into a practical application at least by providing a specific improvement to computer functionality that enhances the computer’s ability to process and manage financial data. Examiner disagrees. The additional elements of a processor, a computer readable medium, and an application programming interface are recited at a high-level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer component. These additional elements, when considered separately and as an ordered combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea and are at a high level of generality. Contrary to Applicant’s assertions, the ability to access accounting information and extract transaction data is not a specific improvement in the functioning of the computer. Applicant has not identified any limitations of the computer that would make such a task impossible but for the implementation of the claimed invention, and Applicant has not explained how the claimed invention has overcome any such limitations to improve the computer. Applicant also has not pointed out any computer functionality that did not exist prior to the conception of the claimed invention. The computer is merely used by Applicant’s claimed invention as a tool. The functionality and operation of the computer itself has not been modified, altered, or otherwise improved upon. Novel hardware is not required for a computer-related invention to be patent eligible. However, an argument that a claimed invention is patent eligible because it improves a computer must be supported by more than conclusory statements. Therefore, Examiner finds Applicant’s argument non-persuasive.
Applicant argued that Examiner’s 101 rejection was improper because the claims provide an inventive concept that amounts to “significantly more” than the alleged exception. Examiner disagrees. Applicant’s claimed invention does not provide an inventive concept that amounts to “significantly more” than the alleged exception because, when considered separately and as an ordered combination, the additional element of using computer hardware/software amounts to no more than mere instructions to apply the exception using generic computer components. Mere instructions to apply an exception using generic computer components cannot provide an inventive concept that amounts to “significantly more” than the alleged exception. Therefore, Examiner finds Applicant’s argument non-persuasive.
Applicant argued that Examiner’s 101 rejection was improper because the claims recite an inventive concept that includes a combination of features that are not well-understood, routine, or conventional, and Examiner has not cited any prior art that teaches or suggest the claimed combination. Examiner disagrees. Examiner’s 101 rejection does not require a factual determination to support a conclusion that an additional element is well-understood, routine, conventional activity because Examiner’s 101 rejection does not rely on a finding that Applicant’s claimed invention is well-understood, routine, or conventional. Furthermore, Examiner’s 101 rejection does not cite any prior art that teaches or suggests the claimed combination because it is not required under 35 USC 101 to determine patent eligibility. Prior art citations are only required for rejections under 35 USC 102 and 35 USC 103 in determining patentability. Patent eligibility is a completely separate issue from patentability. Applicant has mischaracterized the MPEP to suggest that Examiner must determine whether additional elements in a claim are well-understood, routine, conventional activity under Step 2B of the Alice two-step analysis. This is false. Examiner must determine whether the additional elements provide significantly more than the alleged exception, which is a completely different standard. In making a determination of whether the additional elements provide significantly more than the alleged exception, Examiner is instructed to evaluate (not determine) whether the elements define only well-understood, routine, conventional activity. During said evaluation, if Examiner finds that the additional elements define well-understood, routine, conventional activity, then (and only then) is Examiner required to provide evidentiary support. In the instant case, Examiner’s evaluation of whether the additional elements define only well-understood, routine, conventional activity did not produce such a finding. Therefore, evidentiary support was not needed. It is worth reiterating that the question of whether additional elements are well-understood, routine, conventional activity is not determinative of whether an inventive concept that amounts to “significantly more” is present or whether the claimed invention is ultimately patent eligible. At best, a finding that additional elements are other than what is well-understood, routine, conventional activity merely favors eligibility. It does not determine eligibility. After evaluating whether the additional elements in Applicant’s claimed invention defined well-understood, routine, conventional activity (among other factors), Examiner determined that the additional limitations did not recite additional elements that amount to significantly more than the judicial exception. Therefore, Examiner finds Applicant’s argument non-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.
Claim(s) 1-20 is/are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Claim(s) 1-20 are directed to a system, method, or product, which are/is one of the statutory categories of invention. (Step 1: YES).
The Examiner has identified independent system claim 11 as the claim that represents the claimed invention for analysis and is similar to independent method claims 1, 13 and 20 and product Claim 10. Claim 11 recites the following limitations:
[at least one first processor; and]
[a first non-transitory computer readable medium communicatively coupled to the at least one first processor, the first non-transitory computer readable medium having stored thereon computer software comprising a first set of instructions that, when executed by the at least one first processor, causes the computing system to:]
autonomously access, [via an application programming interface (API)], accounting information from a first accounting software system among a plurality of disparate accounting software systems;
autonomously extract, from the accounting information accessed from the first accounting software system, transaction data and a chart of accounts, the extracted transaction data corresponding to a transaction entry for each individual transaction among a plurality of transactions from the accounting information and the chart of accounts comprising a listing of account names and corresponding standardized account type or sub-account type into which each account name is classified, wherein the extracted transaction data comprises data regarding transactions each associated with one of the account names listed in the chart of accounts; and
autonomously generate one or more files based on the extracted transaction data and based on the standardized account type or sub-account type for each transaction.
These limitations, under their broadest reasonable interpretation, cover performance of the limitation as certain methods of organizing human activity because the limitations recite a fundamental economic principle or practice. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation as a fundamental economic principle of practice, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea. The processor, computer readable medium, and application programming interface in Claim 11 are just applying generic computer components to the recited abstract limitations. The recitation of generic computer components in a claim does not necessarily preclude that claim from reciting an abstract idea. Claim(s) 1, 10, 13, and 20 are also abstract for similar reasons. (Step 2A-Prong 1: YES. The claims recite an abstract idea)
This judicial exception is not integrated into a practical application. In particular, the claims recite the additional elements of a processor, a computer readable medium, and an application programming interface. The computer hardware/software is/are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function) such that it amounts to no more than mere instructions to apply the exception using a generic computer component. Accordingly, these additional elements, when considered separately and as an ordered combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea and are at a high level of generality. Therefore, claim(s) 1, 10, 11, 13, and 20 are directed to an abstract idea without a practical application. (Step 2A-Prong 2: NO. The additional claimed elements are not integrated into a practical application)
The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when considered separately and as an ordered combination, they do not add significantly more (also known as an “inventive concept”) to the exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional element of using computer hardware amounts to no more than mere instructions to apply the exception using a generic computer component. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Accordingly, these additional elements do not change the outcome of the analysis when considered separately and as an ordered combination. Thus, claim(s) 1, 10, 11, 13, and 20 are not patent eligible. (Step 2B: NO. The claims do not provide significantly more)
Dependent claims 2-9, 12, and 14-19 further define the abstract idea that is present in their respective independent claim(s) 1, 10, 11, 13, and 20 and thus correspond to certain methods of organizing human activity and hence are abstract for the reasons presented above. Dependent claims 2-9, 12, and 14-19 do not include any additional elements that integrate the abstract idea into a practical application or are sufficient to amount to significantly more than the judicial exception when considered both individually and as an ordered combination. Therefore, dependent claims 2-9, 12, and 14-19 are directed to an abstract idea. Thus, claim(s) 1-20 are not patent-eligible.
Conclusion
Pertinent Art
The prior art made of record and not relied upon is considered pertinent to Applicant’s disclosure. Krishna (US 2015/0106246) discloses systems and methods for secure financial transactions.
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/JOHN O PRESTON/Examiner, Art Unit 3693
March 7, 2026
/ELIZABETH H ROSEN/Primary Examiner, Art Unit 3693