DETAILED CORRESPONDENCE
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 the Application
Applicant's amendment filed on March 3, 2026 has been entered.
Response to Amendment
Claims 1, 10, and 19 were amended. Claims 8 and 17 were canceled. New claims 23-24 were added. Claims 1-7, 10-16, and 19-24 remain pending in the application and are provided to be examined upon their merits.
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 1-7, 10-16, and 19-24 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.
Claims 1-7, 10-16, and 19-24 are directed to the abstract idea of: Claim 1 -: 1, comprising: storing executable instructions; and communicatively coupled and configured to access and execute the executable instructions to: receive, on behalf of a requestor, identifying information associated with a cardholder of a transaction card, wherein the transaction card i) is associated with an existing card account identifier, and ii) enables access to funds associated with a financial account; retrieve stored identifying information associated with the cardholder; authenticate the requestor's identity by comparing at least a portion of the received identifying information to at least a portion of the stored identifying information retrieved; after authenticating the requestor's identity and in response to an indication that the existing card account identifier is potentially compromised or unavailable for use, generate a token comprising a first token segment having a first numeric digit, a second token segment having additional characters, and a third token segment having a validation character; transform the token into a temporary card account identifier by: storing the token in a token data; determining a portion of a card account identifier corresponding to the first token segment using a stored mapping between token segments and portions of card account identifiers; and constructing the temporary card account identifier in an array data using the additional characters of the second token segment, the validation character of the third token segment, and the determined portion of the card account identifier by: writing the additional characters of the second token segment to a first location in the array data; writing the validation character of the third token segment to a second location in the array data; and writing the determined portion of the card account identifier to a third location in the array data; and validating the temporary card account identifier by applying a checksum using the validation character; generate and transmit a visual encoded representation of the temporary card account identifier to a mobile device- of the cardholder, wherein the visual encoded representation of the temporary card account identifier i) is configured for visible display on the mobile device-, ii) encodes the temporary card account identifier, and iii) comprises a code-; receive, from the mobile device-, a geolocation of the mobile device-; receive, from a funds dispensing, in response to a withdrawal request executed at the funds dispensing, a validation request including the temporary account identifier extracted from the visual encoded representation by scanning- the visual encoded representation and ii) a location of the funds dispensing; determine whether the withdrawal request is valid by comparing the location of the funds dispensing to the geolocation of the mobile device-; and in response to the location of the funds dispensing being within a threshold distance of the geolocation of the mobile device-, transmit a validation message to the funds dispensing. (fundamental economic principles or practices, commercial or legal interactions, managing personal behavior or relationships or interactions between people, concepts performed in the human mind, (including an observation, evaluation, judgment, opinion). ) Claim 2 -: 2, claim 1, wherein i) the executable instructions, when executed, further determine whether one or more conditions for temporary use are satisfied, and ii) the one or more conditions for temporary use comprise one or more of: a) a threshold number of permitted uses of the temporary card account identifier to access at least a portion of the funds, b) a maximum amount of the funds to which the temporary card account identifier enables access, c) an expiration time limit associated with the temporary card account identifier wherein the temporary card account identifier no longer enables access to the at least a portion of the funds upon or subsequent to the expiration time limit, d) a maximum amount of the funds to which the temporary card account identifier enables access for each permitted use of the temporary card account identifier, or e) one or more permitted locations for receipt of the at least a portion of the funds. Claim 3 -: 3, claim 2, wherein the one or more conditions for temporary use are determined based at least in part on at least one of: i) one or more fraud detection/mitigation rules, or ii) historical transaction information associated with the cardholder. Claim 4 -: 4, claim 2, wherein the one or more conditions for temporary use further comprise one or more of i) a location of the location being within a threshold distance from a location of the mobile device-, or ii) being an authorized type. Claim 5 -: 5, claim 2, wherein i) the one or more conditions for temporary use comprise a geographic constraint constraining use of the temporary card account identifier to a geographic region encompassing a location the geolocation of the mobile device-, and ii) the temporary card account identifier does not enable access to the at least a portion of the funds outside of the geographic region. Claim 6 -: 6, claim 1, wherein the executable instructions, when executed, further transmit, for presentation on the mobile device-, instructions for establishing a Personal Identification Number (PIN) associated with the temporary card account identifier. Claim 7 -: 7, claim 1, wherein the received identifying information associated with the cardholder comprises at least one of: i) a login identifier, ii) a name, i1i) a telephone number, or iv) at least a portion of a government-issued identifier. (fundamental economic principles or practices, commercial or legal interactions, managing personal behavior or relationships or interactions between people, concepts performed in the human mind, (including an observation, evaluation, judgment, opinion). ) Claim 10 -: 10, a method comprising: receiving on behalf of a requestor, identifying information associated with a cardholder of a transaction card, wherein the transaction card i) is associated with an existing card account identifier, and ii) enables access to funds associated with a financial account; retrieving stored identifying information associated with the cardholder; authenticating the requestor's identity by comparing at least a portion of the received identifying information to at least a portion of the stored identifying information retrieved; after authenticating... [id. at 1], generating a token comprising a first token segment having a first numeric digit, a second token segment having additional characters, and a third token segment having a validation character; transforming the token into a temporary card account identifier by: storing the token in... determining a portion... constructing the temporary... writing the additional... writing the validation... writing the determined... validating the temporary... [id. at 1], generating and transmitting a visual encoded representation of the temporary card account identifier to a mobile device- of the cardholder, wherein the visual encoded representation of the temporary card account identifier i) is configured for visible display on the mobile device-, ii) encodes the temporary card account identifier, and iii) comprises a code-; receiving, from the mobile device-, a geolocation of the mobile device-; receiving, from a funds dispensing, in response to a withdrawal request executed at the funds dispensing, a validation request including the temporary account identifier extracted from the visual encoded representation by scanning- the visual encoded representation and ii) a location of the funds dispensing; determining whether the withdrawal request is valid by comparing the location of the funds dispensing to the geolocation of the mobile device-; and in response to the location of the funds dispensing being within a threshold distance of the geolocation of the mobile device-, transmitting a validation message to the funds dispensing. (fundamental economic principles or practices, commercial or legal interactions, managing personal behavior or relationships or interactions between people, concepts performed in the human mind, (including an observation, evaluation, judgment, opinion). ) Claim 11 -: 11, the method of claim 10, wherein i) the method further comprises determining whether one or more conditions for temporary use are satisfied, and ii) the one or more conditions for temporary use comprise one or more of a) a threshold number... b) a maximum amount... [id. at 2], c) an expiration time limit associated with the temporary card account identifier, wherein the temporary card account identifier no longer enables access to the at least a portion of the funds upon or subsequent to the expiration time limit, d) a maximum amount... e) one or more permitted... [id. at 2], Claim 12 -: 12, the method of claim 11, wherein the one or more conditions for temporary use are determined based at least in part on at least one of i) one or more fraud... ii) historical transaction... [id. at 3], Claim 13 -: 13, the method of claim 11, wherein the one or more conditions for temporary use further comprise being an authorized type. Claim 14 -: 14, the method of claim 11, wherein i) the one or more conditions for temporary use comprise a geographic constraint constraining use of the temporary card account identifier to a geographic region encompassing the geolocation of the mobile device-, and ii) the temporary card... [id. at 5], Claim 15 -: 15, the method of claim 10, further comprising transmitting, for presentation on the mobile device-, instructions for establishing a Personal Identification Number (PIN) associated with the temporary card account identifier. Claim 16 -: 16, the method of claim 10, wherein the received identifying information associated with the cardholder comprises at least one of: i) a login identifier,... ii) a name,... i1i) a telephone number,... iv) at least a portion... [id. at 7], (fundamental economic principles or practices, commercial or legal interactions, managing personal behavior or relationships or interactions between people, concepts performed in the human mind, (including an observation, evaluation, judgment, opinion). ) Claim 19 -: 19, a program product, the program product comprising at least one readable storage having readable program code portions stored therein, the readable program code portions configured to cause to: receive, on behalf... retrieve stored identifying... authenticate the requestor's... after authenticating... generate a token comprising... transform the token... storing the token in... determining a portion... [id. at 1], constructing the temporary card account identifier using the additional characters of the second token segment in an array datthe validation character of the third token segment, and the determined portion of the card account identifier by: writing the additional... writing the validation... writing the determined... validating the temporary... generate and transmit... receive, from the mobile... receive, from a funds... determine whether the... in response to the... [id. at 1], (fundamental economic principles or practices, commercial or legal interactions, managing personal behavior or relationships or interactions between people, concepts performed in the human mind, (including an observation, evaluation, judgment, opinion). ) Claim 20 -: 20, the program product of claim 19, wherein i) the readable program code portions are further configured to cause the to determine whether one or more conditions for temporary use are satisfied, and ii) the one or more conditions for temporary use comprise one or more of a) a threshold number... b) a maximum amount... [id. at 2], c) an expiration time... [id. at 11], d) a maximum amount... e) one or more permitted... [id. at 2], Claim 21 -: 21, claim 1, wherein the visual encoded representation encodes a token corresponding to the temporary account identifier. Claim 22 -: 22, claim 21, wherein the token comprises i) a first token segment comprising a first numeric digit, ii) a second token segment comprising one or more additional characters, and iii) a third token segment comprising a validation character, and wherein the temporary account identifier comprises the one or more additional characters of the second token segment and the validation character of the third token segment. Claim 23 -: 23. The of claim 1, wherein the third location in the array data comprises an initial location of the array data. Claim 24 -: 24. The method of claim 10, wherein the third... [id. at 23], (fundamental economic principles or practices, commercial or legal interactions, managing personal behavior or relationships or interactions between people, concepts performed in the human mind, (including an observation, evaluation, judgment, opinion). ) . The identified limitation(s) falls within the subject matter groupings of abstract ideas enumerated in Section I of the 2019 Revised Patent Subject Matter Eligibility Guidance: b) Certain methods of organizing human activity – fundamental economic principles or practices, commercial or legal interactions, managing personal behavior or relationships or interactions between people, c) Mental processes – concepts performed in the human mind, (including an observation, evaluation, judgment, opinion).
These limitation excerpts, under their broadest reasonable interpretation, fall within the grouping(s) of abstract ideas of: Certain methods of organizing human activity – since: card account identifiers associated with conditions for temporary use as recited in the claim limitations, under their broadest reasonable interpretation, covers performance of the limitation(s) as fundamental economic principles or practices, (including hedging, insurance, mitigating risk); commercial or legal interactions, (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations); managing personal behavior or relationships or interactions between people, (including social activities, teaching, and following rules or instructions). Mental processes – since: the above-underlined as recited in the claim limitations, under their broadest reasonable interpretation, covers performance of the limitation(s) as concepts performed in the human mind, (including an observation, evaluation, judgment, opinion). Therefore, the limitations fall within the above-identified grouping(s) of abstract ideas.
While independent claims 1, 10, and 19 do not explicitly recite verbatim this identified abstract idea, the concept of this identified abstract idea is described by the steps of independent claim 1 and is described by the steps of independent claim 10 and is described by the steps of independent claim 19.
Claim 1 (as amended): Particularly with respect to the analysis under Step 2A of the Office's § 101 Subject Matter Eligibility Test for Products and Processes as further necessitated by Applicant's amendment, independent claim 1 (as amended) further to the abstract idea includes additional elements of "computing system", "at least one memory", "computer", "at least one processor", "electronically", "datastore", "structure", "memory", "algorithm", "mobile device", "mobile app executing", "quick response (QR) code", "barcode", "system", and "scanning". However, independent claim 1 (as amended) does not include additional elements that are sufficient to integrate the exception into a practical application because "computing system", "at least one memory", "computer", "at least one processor", "electronically", "datastore", "structure", "memory", "algorithm", "mobile device", "mobile app executing", "quick response (QR) code", "barcode", "system", and "scanning" of independent claim 1 (as amended) recite generic computer and/or field of use components pertaining to the particular technological environment that are recited a high-level of generality that perform functions ("a computing system, comprising", "at least one memory storing computer-executable instructions; and", "at least one processor communicatively … the computer-executable instructions to", "electronically receive, on behalf of … with a financial account", "retrieve stored identifying information associated … cardholder from a datastore", "authenticate the requestor's identity by … retrieved from the datastore", "after authenticating the requestor's identity … or unavailable for use", "generate a token comprising a … having a validation character", "transform the token into a … card account identifier by", "storing the token in a token data structure", "determining a portion of a … card account identifiers; and", "constructing the temporary card account … card account identifier by", "writing the additional characters of … the array data structure", "writing the validation character of … array data structure; and", "writing the determined portion of … array data structure; and", "validating the temporary card account … using the validation character", "generate and transmit a visual … code or a barcode", "receive, from the mobile device, … of the mobile device", "receive, from a funds dispensing … the funds dispensing system", "determine whether the withdrawal request … the mobile device; and" and "in response to the location … the funds dispensing system") that merely perform, conduct, carry out, implement, and/or narrow the abstract idea itself (e.g. all or portion(s) of the noted recited steps) and/or that recite generic computer and/or field of use functions that are recited at a high-level of generality that include only steps narrowing the abstract idea [Step 2A Prong I] (e.g. all or portion(s) of the noted recited steps) and/or because the additional method steps comprise or include: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, [Step 2A Prong II] adding the words "apply it" (or an equivalent) 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) (all or portions of the noted step(s)), and adding insignificant extra-solution activity to the judicial exception -- see MPEP 2106.05(g) (all or portions of the "at least one memory storing computer-executable instructions; and", "at least one processor communicatively … the computer-executable instructions to", "retrieve stored identifying information associated … cardholder from a datastore", "storing the token in a token data structure", "determining a portion of a … card account identifiers; and", "writing the additional characters of … the array data structure", "writing the validation character of … array data structure; and", "writing the determined portion of … array data structure; and", "generate and transmit a visual … code or a barcode" step(s)), and generally linking the use of the judicial exception to a particular technological environment or field of use -- see MPEP 2106.05(h) (all or portions of the noted step(s)). Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the additional elements do not amount to more than a recitation of the words "apply it" (or an equivalent) or are not more than mere instructions to implement an abstract idea or other exception on a computer, and the additional elements do not add more than insignificant extra-solution activity to the judicial exception, and the additional elements do not amount to more than generally linking the use of a judicial exception to a particular technological environment or field of use. Additionally, the additional method steps comprise or include: reciting additional elements in implementing the abstract idea that do not constitute significantly more than the abstract idea because they comprise or include well-understood, routine, and conventional activities previously known to the industry (e.g. all or portion(s) of the "at least one memory storing computer-executable instructions; and", "at least one processor communicatively … the computer-executable instructions to", "retrieve stored identifying information associated … cardholder from a datastore", "storing the token in a token data structure", "determining a portion of a … card account identifiers; and", "writing the additional characters of … the array data structure", "writing the validation character of … array data structure; and", "writing the determined portion of … array data structure; and", "generate and transmit a visual … code or a barcode", (insignificant extra-solution activity) steps), see Alice Corp., 134 S. Ct. at 2360, and/or that are otherwise not significant toward constituting any inventive concept beyond the abstract idea. (E.g. The above-italicized grounds of rejection apply at least to all or portion(s) of the noted recited steps.) For example regarding well-understood, routine, and conventional activities, the cited rationale have recognized the following computer function as well-understood, routine, and conventional functions when it is claimed or as insignificant extra-solution activity: electronic recordkeeping, Alice Corp. Pty. Ltd. v. CLS Bank Int'l, 134 S. Ct. at 2359, 110 USPQ2d at 1984 (2014) (creating and maintaining "shadow accounts"); Ultramercial, Inc. v. Hulu, LLC, 772 F.3d at 716, 112 USPQ2d at 1755 (Fed. Cir. 2014) (updating an activity log), storing and retrieving information in memory, Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015); OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d at 1363, 115 USPQ2d at 1092-93 (Fed. Cir. 2015), electronically scanning or extracting data from a physical document, Content Extraction and Transmission, LLC v. Wells Fargo Bank, 776 F.3d 1343, 1348, 113 USPQ2d 1354, 1358 (Fed. Cir. 2014) (optical character recognition), and a web browser's back and forward button functionality, Internet Patent Corp. v. Active Network, Inc., 790 F.3d 1343, 1348, 115 USPQ2d 1414, 1418 (Fed. Cir. 2015); and the cited rationale have found the following type of activity to be well-understood, routine, and conventional activity when it is claimed or as insignificant extra-solution activity: recording a customer's order, Apple, Inc. v. Ameranth, Inc., 842 F.3d 1229, 1244, 120 USPQ2d 1844, 1856 (Fed. Cir. 2016), restricting public access to media by requiring a consumer to view an advertisement, Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709, 716-17, 112 USPQ2d 1750, 1755-56 (Fed. Cir. 2014), presenting offers and gathering statistics, OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d at 1362-63, 115 USPQ2d at 1092-93 (Fed. Cir. 2015), and arranging a hierarchy of groups, sorting information, eliminating less restrictive pricing information and determining the price, Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1331, 115 USPQ2d 1681, 1699 (Fed. Cir. 2015). None of the additional elements taken individually or when taken as an ordered combination amount to significantly more than the abstract idea. Accordingly, independent claim 1 (as amended) remains ineligible notwithstanding Applicant's amendments.
Claim 10 (as amended): Materially with respect to the analysis under Step 2A of the Office's § 101 Subject Matter Eligibility Test for Products and Processes as further necessitated by Applicant's amendment, independent claim 10 (as amended) further to the abstract idea includes additional elements of "electronically", "computing system", "datastore", "structure", "memory", "algorithm", "mobile device", "mobile app executing", "quick response (QR) code", "barcode", "system", and "scanning". However, independent claim 10 (as amended) does not include additional elements that are sufficient to integrate the exception into a practical application because "electronically", "computing system", "datastore", "structure", "memory", "algorithm", "mobile device", "mobile app executing", "quick response (QR) code", "barcode", "system", and "scanning" of independent claim 10 (as amended) recite generic computer and/or field of use components pertaining to the particular technological environment that are recited a high-level of generality that perform functions ("a method comprising", "electronically receiving, by a computing … with a financial account", "retrieving, by the computing system, … cardholder from a datastore", "authenticating, by the computing system, … retrieved from the datastore", "after authenticating the requestor's identity … or unavailable for use", "generating a token comprising a … having a validation character", "transforming the token into a … card account identifier by", "storing the token in a token data structure", "determining a portion of a … card account identifiers; and", "constructing the temporary card account … card account identifier by", "writing the additional characters of … the array data structure", "writing the validation character of … array data structure; and", "writing the determined portion of … array data structure; and", "validating the temporary card account … using the validation character", "generating and transmitting, by the … code or a barcode", "receiving, from the mobile device, … of the mobile device", "receiving, from a funds dispensing … the funds dispensing system", "determining whether the withdrawal request … the mobile device; and" and "in response to the location … the funds dispensing system") that merely perform, conduct, carry out, implement, and/or narrow the abstract idea itself (e.g. all or portion(s) of the noted recited steps) and/or that recite generic computer and/or field of use functions that are recited at a high-level of generality that include only steps narrowing the abstract idea [Step 2A Prong I] (e.g. all or portion(s) of the noted recited steps) and/or because the additional method steps comprise or include: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, [Step 2A Prong II] adding the words "apply it" (or an equivalent) 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) (all or portions of the noted step(s)), and adding insignificant extra-solution activity to the judicial exception -- see MPEP 2106.05(g) (all or portions of the "retrieving, by the computing system, … cardholder from a datastore", "storing the token in a token data structure", "determining a portion of a … card account identifiers; and", "writing the additional characters of … the array data structure", "writing the validation character of … array data structure; and", "writing the determined portion of … array data structure; and", "generating and transmitting, by the … code or a barcode" step(s)), and generally linking the use of the judicial exception to a particular technological environment or field of use -- see MPEP 2106.05(h) (all or portions of the noted step(s)). Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claim 1 also applies hereto. Additionally, the additional method steps comprise or include: reciting additional elements in implementing the abstract idea that do not constitute significantly more than the abstract idea because they comprise or include well-understood, routine, and conventional activities previously known to the industry (e.g. all or portion(s) of the "retrieving, by the computing system, … cardholder from a datastore", "storing the token in a token data structure", "determining a portion of a … card account identifiers; and", "writing the additional characters of … the array data structure", "writing the validation character of … array data structure; and", "writing the determined portion of … array data structure; and", "generating and transmitting, by the … code or a barcode", (insignificant extra-solution activity) steps), see Alice Corp., 134 S. Ct. at 2360, and/or that are otherwise not significant toward constituting any inventive concept beyond the abstract idea. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited steps.) See discussion above regarding Claim 1 for pertinent previously cited rationale finding well-understood, routine, and conventional activities. None of the additional elements taken individually or when taken as an ordered combination amount to significantly more than the abstract idea. Accordingly, independent claim 10 (as amended) remains ineligible notwithstanding Applicant's amendments.
Claim 19 (as amended): Specifically regarding the analysis under Step 2A of the Office's § 101 Subject Matter Eligibility Test for Products and Processes as further necessitated by Applicant's amendment, independent claim 19 (as amended) further to the abstract idea includes additional elements of "computer", "non-transitory", "storage medium", "computing system", "electronically", "datastore", "structure", "memory", "algorithm", "mobile device", "mobile app executing", "quick response (QR) code", "barcode", "system", and "scanning". However, independent claim 19 (as amended) does not include additional elements that are sufficient to integrate the exception into a practical application because "computer", "non-transitory", "storage medium", "computing system", "electronically", "datastore", "structure", "memory", "algorithm", "mobile device", "mobile app executing", "quick response (QR) code", "barcode", "system", and "scanning" of independent claim 19 (as amended) recite generic computer and/or field of use components pertaining to the particular technological environment that are recited a high-level of generality that perform functions ("a computer program product, the … a computing system to", "electronically receive, on behalf of … with a financial account", "retrieve stored identifying information associated … cardholder from a datastore", "authenticate the requestor's identity by … retrieved from the datastore", "after authenticating the requestor's identity … or unavailable for use", "generate a token comprising a … having a validation character", "transform the token into a … card account identifier by", "storing the token in a token data structure", "determining a portion of a … card account identifiers; and", "constructing the temporary card account … card account identifier by", "writing the additional characters of … the array data structure", "writing the validation character of … array data structure; and", "writing the determined portion of … array data structure; and", "validating the temporary card account … using the validation character", "generate and transmit a visual … code or a barcode", "receive, from the mobile device, … of the mobile device", "receive, from a funds dispensing … the funds dispensing system", "determine whether the withdrawal request … the mobile device; and" and "in response to the location … the funds dispensing system") that merely perform, conduct, carry out, implement, and/or narrow the abstract idea itself (e.g. all or portion(s) of the noted recited steps) and/or that recite generic computer and/or field of use functions that are recited at a high-level of generality that include only steps narrowing the abstract idea [Step 2A Prong I] (e.g. all or portion(s) of the noted recited steps) and/or because the additional method steps comprise or include: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, [Step 2A Prong II] adding the words "apply it" (or an equivalent) 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) (all or portions of the noted step(s)), and adding insignificant extra-solution activity to the judicial exception -- see MPEP 2106.05(g) (all or portions of the "retrieve stored identifying information associated … cardholder from a datastore", "storing the token in a token data structure", "determining a portion of a … card account identifiers; and", "writing the additional characters of … the array data structure", "writing the validation character of … array data structure; and", "writing the determined portion of … array data structure; and", "generate and transmit a visual … code or a barcode" step(s)), and generally linking the use of the judicial exception to a particular technological environment or field of use -- see MPEP 2106.05(h) (all or portions of the noted step(s)). Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claim 1 also applies hereto. Moreover, the additional method steps comprise or include: reciting additional elements in implementing the abstract idea that do not constitute significantly more than the abstract idea because they comprise or include well-understood, routine, and conventional activities previously known to the industry (e.g. all or portion(s) of the "retrieve stored identifying information associated … cardholder from a datastore", "storing the token in a token data structure", "determining a portion of a … card account identifiers; and", "writing the additional characters of … the array data structure", "writing the validation character of … array data structure; and", "writing the determined portion of … array data structure; and", "generate and transmit a visual … code or a barcode", (insignificant extra-solution activity) steps), see Alice Corp., 134 S. Ct. at 2360, and/or that are otherwise not significant toward constituting any inventive concept beyond the abstract idea. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited steps.) See discussion above regarding Claim 1 for pertinent previously cited rationale finding well-understood, routine, and conventional activities. None of the additional elements taken individually or when taken as an ordered combination amount to significantly more than the abstract idea. Accordingly, independent claim 19 (as amended) remains ineligible notwithstanding Applicant's amendments.
Independent Claims: Nothing in independent claims 1, 10, and 19 improves another technology or technical field, improves the functioning of any claimed computer device itself, applies the abstract idea with any particular machine, solves any computer problem with a computer solution, or includes any element that may otherwise be considered to amount to significantly more than the abstract idea.
None of the dependent claims 2-7, 11-16, and 20-24 when separately considered with each dependent claim's corresponding parent claim overcomes the above analysis because none presents any method step not directed to the abstract idea that amounts to significantly more than the judicial exception or any physical structure that amounts to significantly more than the judicial exception.
Claims 2, 11, and 20: Dependent claims 2, 11, and 20 do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, "ATM" of dependent claims 2, 11, and 20 recite generic computer and/or field of use components pertaining to the particular technological environment that are recited a high-level of generality. No additional element introduced in these claims taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claims 2, 11, and 20 are ineligible.
Claims 2 and 11: Dependent claims 2 and 11 add an additional method step of "a) a threshold number of permitted uses of the existing card account identifier to access at least a portion of the funds", "b) a maximum amount of the funds to which the existing card account enables access", "c) an expiration time limit associated with the existing card account, wherein the existing card account … least a portion of the funds upon or subsequent to the expiration time limit", "d) a maximum amount of the funds to which the existing card account enables access for each permitted use of the existing card account, or", "e) one or more permitted ATM locations for receipt of the at least a portion of the funds". However, the additional method step of dependent claim 2 and 11 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited steps) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, Regarding Step 2B, the additional elements do not amount to more than a recitation of the words "apply it" (or an equivalent) or are not more than mere instructions to implement an abstract idea or other exception on a computer, and the additional elements do not amount to more than generally linking the use of a judicial exception to a particular technological environment or field of use. (E.g. The above-italicized grounds of rejection apply at least to all or portion(s) of the noted recited steps.) No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claims 2 and 11 are ineligible.
Claim 3: Dependent claim 3 adds an additional method step of "i) one or more fraud detection/mitigation rules, or", "ii) historical transaction information associated with the cardholder". However, the additional method step of dependent claims 3 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited steps) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claims 2 and 11 above. Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claims 2 and 11 also applies hereto. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited steps.) No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 3 is ineligible.
Claim 4: Dependent claim 4 adds an additional method step of "i) a location of the ATM location being within a threshold distance from a location of the mobile device, or", "ii) the ATM being an authorized type of ATM". However, the additional method step of dependent claims 4 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited steps) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claims 2 and 11 above. Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claims 2 and 11 also applies hereto. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited steps.) No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 4 is ineligible.
Claim 5: Dependent claim 5 adds an additional method step of "i) the one or more conditions for temporary use comprise a geographic constraint constraining use of … to a geographic region encompassing a location the geolocation of the mobile device, and", "ii) the existing card account does not enable access to the at least a portion of the funds outside of the geographic region". However, the additional method step of dependent claims 5 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited steps) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claims 2 and 11 above. Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claims 2 and 11 also applies hereto. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited steps.) No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 5 is ineligible.
Claim 6: Dependent claim 6 adds an additional method step of "the computing system of claim 1, wherein the computer-executable instructions, when executed, further transmit, for … for establishing a Personal Identification Number (PIN) associated with the existing card account identifier". However, the additional method step of dependent claims 6 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited steps) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claim 1 above. Regarding Step 2B, the additional elements do not amount to more than a recitation of the words "apply it" (or an equivalent) or are not more than mere instructions to implement an abstract idea or other exception on a computer, and the additional elements do not add more than insignificant extra-solution activity to the judicial exception, and the additional elements do not amount to more than generally linking the use of a judicial exception to a particular technological environment or field of use. (E.g. The above-italicized grounds of rejection apply at least to all or portion(s) of the noted recited steps.) For example regarding well-understood, routine, and conventional activities, the cited rationale have recognized the following computer function as well-understood, routine, and conventional functions when it is claimed or as insignificant extra-solution activity: a web browser's back and forward button functionality, Internet Patent Corp. v. Active Network, Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1; and the cited rationale have found the following type of activity to be well-understood, routine, and conventional activity when it is claimed or as insignificant extra-solution activity: recording a customer's order, Apple, Inc. v. Ameranth, Inc., (Fed. Cir. 2016), see previous legal citation herein Re: Claim 1, restricting public access to media by requiring a consumer to view an advertisement, Ultramercial, Inc. v. Hulu, LLC (Fed. Cir. 2014), see previous legal citation herein Re: Claim 1, and presenting offers and gathering statistics, OIP Techs., Inc. v. Amazon.com, Inc., (Fed. Cir. 2015), see previous legal citation herein Re: Claim 1, pertaining to all or portion(s) of the noted recited steps. No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 6 is ineligible.
Claims 7 and 16: Dependent claims 7 and 16 add an additional method step of "i) a login identifier", "ii) a name", "i1i) a telephone number, or", "iv) at least a portion of a government-issued identifier". However, the additional method step of dependent claim 7 and 16 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited steps) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claims 2 and 11 above. Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claims 2 and 11 also applies hereto. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited steps.) No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claims 7 and 16 are ineligible.
Claim 13: Dependent claim 13 adds an additional method step of "the method of claim 11, wherein the one or more conditions for temporary use further comprise the ATM being an authorized type of ATM". However, the additional method step of dependent claims 13 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited steps) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claims 2 and 11 above. Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claims 2 and 11 also applies hereto. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited steps.) No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 13 is ineligible.
Claim 14: Dependent claim 14 adds an additional method step of "i) the one or more conditions for temporary use comprise a geographic constraint constraining use of … card account to a geographic region encompassing the geolocation of the mobile device, and", "ii) the existing card account does not enable access to the at least a portion of the funds outside of the geographic region". However, the additional method step of dependent claims 14 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited steps) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claims 2 and 11 above. Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claims 2 and 11 also applies hereto. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited steps.) No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 14 is ineligible.
Claim 15: Dependent claim 15 adds an additional method step of "the method of claim 10, further comprising transmitting, for presentation via the mobile app executing … for establishing a Personal Identification Number (PIN) associated with the existing card account identifier". However, the additional method step of dependent claims 15 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited steps) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claim 1 above. Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claim 6 also applies hereto. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited steps.) See discussion above regarding Claim 6 for pertinent previously cited rationale finding well-understood, routine, and conventional activities, pertaining to all or portion(s) of the noted recited steps. No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 15 is ineligible.
Claim 20: Dependent claim 20 adds an additional method step of "i) the computer-readable program code portions are further configured to cause the computing system to determine whether one or more conditions for temporary use are satisfied, and", "ii) the one or more conditions for temporary use comprise one or more of", "a) a threshold number of permitted uses of the existing card account identifier to access at least a portion of the funds", "b) a maximum amount of the funds to which the existing card account enables access", "c) an expiration time limit associated with the existing card account, wherein the existing card account … least a portion of the funds upon or subsequent to the expiration time limit", "d) a maximum amount of the funds to which the existing card account enables access for each permitted use of the existing card account, or", "e) one or more permitted ATM locations for receipt of the at least a portion of the funds". However, the additional method step of dependent claims 20 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited steps) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claims 2 and 11 above. Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claims 2 and 11 also applies hereto. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited steps.) No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 20 is ineligible.
Claim 21: Dependent claim 21 adds an additional method step of "wherein the visual encoded representation encodes a token corresponding to the temporary account identifier". However, the additional method step of dependent claims 21 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited step) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claims 2 and 11 above. Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claims 2 and 11 also applies hereto. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited step.) No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 21 is ineligible.
Claim 22: Dependent claim 22 adds additional method steps of "wherein the token comprises i) a first token segment … of the second token segment and the validation character of the third token segment". However, the additional method steps of dependent claims 22 are directed to the abstract idea noted above and do not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method steps merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrow the abstract idea (e.g. all or portion(s) of the noted recited steps) and/or because the additional method steps comprise or include: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claims 2 and 11 above. Regarding Step 2B treatment of the evaluated additional elements individually and in combination, the same previously-stated legal authority and/or rationale supporting the grounds of rejection applied to the above Claims 2 and 11 also applies hereto. (E.g. These previously-stated grounds of rejection that were italicized when applied to the referenced previous Claim(s) apply at least to all or portion(s) of the noted recited steps.) No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claim 22 is ineligible.
Claims 23 and 24: Dependent claims 23 and 24 add an additional method step of "wherein the third memory location in the array data structure comprises an initial memory location of the array data structure". However, the additional method step of dependent claim 23 and 24 is directed to the abstract idea noted above and does not otherwise alter the analysis presented above, and do not integrate the exception into a practical application, because the additional method step merely perform, conduct, carry out, and/or implement the abstract idea itself and/or only narrows the abstract idea (e.g. all or portion(s) of the noted recited step) and/or because the additional method step comprises or includes: evaluated additional elements individually and in combination for which the courts have identified examples in which a judicial exception has not been integrated into a practical application, as previously discussed regarding Claim 1 above. Regarding Step 2B, the additional elements do not amount to more than a recitation of the words "apply it" (or an equivalent) or are not more than mere instructions to implement an abstract idea or other exception on a computer, and the additional elements do not add more than insignificant extra-solution activity to the judicial exception, and the additional elements do not amount to more than generally linking the use of a judicial exception to a particular technological environment or field of use. (E.g. The above-italicized grounds of rejection apply at least to all or portion(s) of the noted recited step.) For example regarding well-understood, routine, and conventional activities, the cited rationale have recognized the following computer function as well-understood, routine, and conventional functions when it is claimed or as insignificant extra-solution activity: electronic recordkeeping, Alice Corp. Pty. Ltd. v. CLS Bank Int'l, (2014); Ultramercial, Inc. v. Hulu, LLC, (Fed. Cir. 2014), see previous legal citations herein Re: Claim 1, and storing and retrieving information in memory, Versata Dev. Group, Inc. v. SAP Am., Inc., (Fed. Cir. 2015); OIP Techs., Inc. v. Amazon.com, Inc., (Fed. Cir. 2015), see previous legal citations herein Re: Claim 1, pertaining to all or portion(s) of the noted recited step. No additional step introduced in this claim taken individually or when taken as an ordered combination amounts to significantly more than the abstract idea. Accordingly, dependent claims 23 and 24 are ineligible.
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§101 Subject Matter Eligibility Test for Products and Processes
Response to Arguments
Regarding eligibility rejections under 35 U.S.C. § 101, the Applicant's arguments submitted March 3, 2026 (hereinafter "REMARKS") in response to the Official Correspondence mailed December 9, 2025 (hereinafter "Non-Final Correspondence") have been fully considered but are not persuasive. Further to the December 9, 2025 Non-Final Correspondence, the reiterated grounds of rejection are fully set forth above under the 35 U.S.C. § 101 heading as applied to the herein examined current claims.
• The Applicant argued:
"Claims 1-8, 10-17, and 19-22 [;] rejected under 35 U.S.C. [] 101 as [] directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more[;] directed to mental processes and certain methods of organizing human activity. Applicant disagrees with these rejections[ and] has amended claim 1 to state:
"1. (Currently Amended) A computing system, comprising:
"[amended claim language].
"[I]ndependent claims 1, 10, and 19 are not directed toward an abstract idea. [T]he claims integrate the idea into a practical application or amount to significantly more than an abstract idea itself and therefore are directed toward statutory subject matter under Section 101.
"[T]hat the claims are directed to certain methods of organizing human activity and mental processes[:] Applicant respectfully submits that amended claim 1 does not recite mental processes or certain methods of organizing human activity []. [T]he amended claims recite systems and methods for securely authorizing use of a temporary card account identifier based on validating a user by comparing locations of a mobile device of a cardholder and a funds dispensing system and encoding the temporary card account identifier in a visual encoded representation to be scanned by the funds dispensing system. The amended claims [] recite generating a token and transforming the token into the temporary card account identifier through a series of technical operations including storing the token in a token data structure, determining a portion of a card account identifier using a stored mapping, constructing the temporary card account identifier in an array data structure by writing portions of the temporary card account identifier to specific locations in the array data structure, and validating the temporary card account identifier using a checksum algorithm.
"[] The claims, as amended, are not capable of performance in the human mind, as they involve manipulation of data structures and writing of data to specific memory locations within an array data structure. [] The current claims [] require the manipulation of data structures and the output of an array data structure containing the temporary card account identifier. [T]he current claims do not recite a mental process.
"[] The context of the claims as related to card accounts does not render the claims patent-ineligible. While the claims may be related to commercial or legal interactions in that they provide a technological platform for the execution of transactions without human interaction or intervention, the claims are in no way directed to commercial or legal interactions.
"[T]he claims do not recite the mere idea of authorizing the dispensing of funds, but a highly specific way of constructing and authorizing use of the temporary card account identifier to allow for the secure dispensing of funds.
"[T]he pending claims as amended herein are patent-eligible under 35 U.S.C. [] 101.
'Applicant respectfully submits that the claims recite a practical application of any alleged abstract idea which may be found in Step 2A - Prong 1, which Applicant does not concede. Under Step 2A (Prong 2), as to any "abstract idea" that might be alleged in a rejection under 35 U.S.C. [] 101, the above-referenced computer-specific characteristics integrate the alleged abstract idea into a practical application.
"The claims as amended recite specific technological implementations that provide concrete solutions to the technical problem of securely validating temporary account access. The amended claims recite specific technological processes involving token generation with segmented structures, transformation operations using data structures and mappings, checksum validation algorithms, visual encoding in QR codes or barcodes, and location-based validation through geolocation comparison. These elements represent specific technological implementations rather than abstract ideas. [T]he ordered combination of token generation with specific segment structures, transformation through technical operations involving data structures and stored mappings, checksum validation, visual encoding in machine-readable formats, and locationbased validation through geolocation comparison represents a specific technological solution rather than an abstract idea. The claims integrate multiple technological components including token data structures, mapping databases, checksum algorithms, visual encoding systems, mobile device communication, and location validation systems to achieve a practical technological result.
"[] The claimed systems and methods integrate a set of steps into an overall claimed process, which, when viewed as a whole, has the clear practical application of verifying a cardholder's identity to dispense funds when an existing card account identifier is potentially compromised or unavailable for use, and solves a technical problem[:] generating a temporary card account identifier and an encoded representation of a temporary card account identifier to correlate trust between a user's device and an ATM. See Specification, paragraphs [0034] and [0204]-[0208]. The token generation and transformation process represents a first layer of security, where generating a token with specific segments and transforming it into a temporary card account identifier through technical operations including token data structure Storage, mapping-based determination of card account identifier portions, construction using specific token segments, and checksum validation provides a secure mechanism for creating temporary identifiers. Sending the visual encoded representation of the temporary card account identifier to the mobile device to the cardholder represents a second layer of security. Encoding the temporary account identifier in the visual encoded representation represents a third layer of security, while also offering a convenient mechanism for the funds dispensing system to scan the visual encoded representation to extract the temporary account identifier. [C]omparing the locations of the mobile device and the funds dispensing system represents a fourth layer of security. [T]he technical improvements reflected in the claims provide for the practical application of verifying a cardholder and authorizing dispensing of funds without relying upon any conventional methods of cardholder identification, such as requiring the cardholder to visit a branch of a financial institution.
"[C]laim 1 (and similarly claims 10 and 19) does not recite an abstract idea under Step 2A - Prong 1, and if so, it integrates the abstract idea into a practical application of the abstract idea under Step 2A - Prong 2. [] Applicant['s] claims 1, 10, and 19, and all claims dependent thereon, be [] patent eligible.
"[C]laims 1, 10, and 19 are patent-eligible. [I]ndependent claims 1, 10, and 19 are patent eligible under Step 2B. []
'Claim 1 recites the additional limitations of "writing the additional characters of the second token segment to a first memory location in the array data structure; writing the validation character of the third token segment to a second memory location in the array data structure; and writing the determined portion of the card account identifier to a third memory location in the array data structure." This combination of elements impose meaningful limits on any alleged abstract idea. [T]he specific construction of the temporary card account identifier within the array data structure, imposes meaningful limits on any abstract idea such as a mental process or commercial interaction. [T]he ordered combination of generating a token with specific segments, transforming the token through technical operations involving data structures and mappings, validating using a checksum algorithm, generating encoded visual representations, and performing location-based validation represents a specific technological implementation. [C]laim 1 is patent eligible.
"When considered in totality, the claims amount to si gnificantly more than mental processes or fundamental economic principles or practices[]. [] Applicant respectfully submits that independent claims 1, 10, and 19, and the claims depending therefrom, are patent eligible under Step 2B as well.
"[I]ndependent claims 1, 10, and 19, and the claims depending therefrom, are patentable under 35 U.S.C. [] 101. []
"[] Applicant respectfully submits that claims 23 and 24 represent meaningful technical features beyond those recited in claims 1 and 10, respectively.
"Applicant believes that the application is in condition for allowance. Favorable reconsideration is respectfully requested. The Examiner is invited to contact the undersigned by telephone if it is felt that a telephone interview would advance prosecution."
(REMARKS, pp. 12-19).
However, the above-quoted arguments submitted March 3, 2026 at REMARKS pp. 12-19 regarding rejections under 35 U.S.C. § 101 have been fully considered, but are not persuasive. Materially, the Office respectfully disagrees with the Applicant's above-quoted factual allegations and legal conclusion. '[T]he "invention" is what is claimed'. Zoltek Corp. v. United States, 672 F.3d 1309, 1318, 102 USPQ2d 1001, 1008 (Fed. Cir. 2012). The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. Contrary to the Applicant's above-quoted assertions, the Applicant's alleged invention as delineated by the currently pending claims appears to be deeply rooted in the abstract idea. The Applicant's claims do not purport to improve the functioning of the computer itself, or to improve any other technology or technical field, rather "the focus of the claims is not on [] an improvement in computers as tools, but on certain independently abstract ideas that use computers as tools." Electric Power Group, LLC, v. Alstom, 830 F.3d 1350, 1354, 119 U.S.P.Q.2d 1739, 1742 (Fed. Cir. 2016). See Alice Corp., 134 S. Ct. at 2358: 'Stating an abstract idea "while adding the words 'apply it'" is not enough for patent eligibility. Mayo, supra, at ___, 132 S. Ct. 1289, 182 L. Ed. 2d 321, 325. Nor is limiting the use of an abstract idea "'to a particular technological environment.'" Bilski, supra, at 610-611, 130 S. Ct. 3218, 177 L. Ed. 2d 792.'
In response to applicant's argument that the claim requires an additional element or a combination of additional elements to apply, rely on, or use the judicial exception in a manner that imposes a meaningful limit on the judicial exception, it is noted that the features upon which applicant relies are not recited in the rejected claim(s) (i.e., are not required to present by the broadest reasonable interpretation of the rejected claim(s)). Although the claims are interpreted in light of the specification, limitations from the specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993). For example, the claims do not recite or specifically require: e.g., "transformation operations using data structures and mappings" or "programmatic assembly of data elements" or "algorithmic computation" or "encoding algorithms and image generation" or "network communication protocols" or "specific computer implementation" . See Alice Corp., 134 S. Ct. at 2358: 'Stating an abstract idea while adding the words "apply it with a computer" simply combines those two steps, with [a] deficient result. Thus, if a patent's recitation of a computer amounts to a mere instruction to "implemen[t]" an abstract idea "on . . . a computer," Mayo, supra, at ___, 132 S. Ct. 1289, 182 L. Ed. 2d 321, 337), that addition cannot impart patent eligibility.'
In response to Applicant's argument that the claimed subject matter provides any improvement to any technology or technical field, the alleged improvement(s) in the abstract idea itself (e.g. a recited fundamental economic concept) is not an improvement in technology. Example(s) that the courts have indicated may not be sufficient to show an improvement in computer-functionality: ii. Accelerating a process of analyzing audit log data when the increased speed comes solely from the capabilities of a general-purpose computer, FairWarning IP, LLC v. Iatric Sys., 839 F.3d 1089, 1095, 120 USPQ2d 1293, 1296 (Fed. Cir. 2016); iii. Mere automation of manual processes, such as using a generic computer to process an application for financing a purchase, Credit Acceptance Corp. v. Westlake Services, 859 F.3d 1044, 1055, 123 USPQ2d 1100, 1108-09 (Fed. Cir. 2017) or speeding up a loan-application process by enabling borrowers to avoid physically going to or calling each lender and filling out a loan application, LendingTree, LLC v. Zillow, Inc., 656 Fed. App'x 991, 996-97 (Fed. Cir. 2016) (non-precedential); iv. Recording, transmitting, and archiving digital images by use of conventional or generic technology in a nascent but well-known environment, without any assertion that the invention reflects an inventive solution to any problem presented by combining a camera and a cellular telephone, TLI Communications, 823 F.3d at 611-12, 118 USPQ2d at 1747; v. Affixing a barcode to a mail object in order to more reliably identify the sender and speed up mail processing, without any limitations specifying the technical details of the barcode or how it is generated or processed, Secured Mail Solutions, LLC v. Universal Wilde, Inc., 873 F.3d 905, 910-11, 124 USPQ2d 1502, 1505-06 (Fed. Cir. 2017); vii. Providing historical usage information to users while they are inputting data, in order to improve the quality and organization of information added to a database, because "an improvement to the information stored by a database is not equivalent to an improvement in the database's functionality," BSG Tech LLC v. Buyseasons, Inc., 899 F.3d 1281, 1287-88, 127 USPQ2d 1688, 1693-94 (Fed. Cir. 2018); viii. Arranging transactional information on a graphical user interface in a manner that assists traders in processing information more quickly, Trading Technologies v. IBG LLC, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019); Examples that the courts have indicated may not be sufficient to show an improvement to technology include: i. A commonplace business method being applied on a general purpose computer, Alice Corp., 573 U.S. at 223, 110 USPQ2d at 1976; Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015); iii. Gathering and analyzing information using conventional techniques and displaying the result, TLI Communications, 823 F.3d at 612-13, 118 USPQ2d at 1747-48; iv. Delivering broadcast content to a portable electronic device such as a cellular telephone, when claimed at a high level of generality, Affinity Labs of Tex. v. Amazon.com, 838 F.3d 1266, 1270, 120 USPQ2d 1210, 1213 (Fed. Cir. 2016); Affinity Labs of Tex. v. DirecTV, LLC, 838 F.3d 1253, 1262, 120 USPQ2d 1201, 1207 (Fed. Cir. 2016); v. A general method of screening emails on a generic computer, Symantec, 838 F.3d at 1315-16, 120 USPQ2d at 1358-59;
Limitations that the courts have found not to be enough to qualify as "significantly more" when recited in a claim with a judicial exception include adding insignificant extra-solution activity to the judicial exception, e.g., mere data gathering in conjunction with a law of nature or abstract idea such as a step of obtaining information about credit card transactions so that the information can be analyzed by an abstract mental process, as discussed in CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375, 99 USPQ2d 1690, 1694 (Fed. Cir. 2011). For Step 2B, relying on what the courts have recognized, or those in the art would recognize, as elements that are well-understood, routine and conventional, the claims in the present application are ineligible under Step 2B. For example, the courts have recognized the following computer functions to be well-understood, routine, and conventional functions when they are claimed in a merely generic manner: performing repetitive calculations, receiving, processing, and storing data, electronically scanning or extracting data from a physical document, electronic recordkeeping, automating mental tasks, and receiving or transmitting data over a network, e.g., using the Internet to gather data. Courts have held computer-implemented processes not to be significantly more than an abstract idea (and thus ineligible) where the claim as a whole amounts to nothing more than generic computer functions merely used to implement an abstract idea, such as an idea that could be done by a human analog (i.e., by hand or by merely thinking). The Applicant may please refer to and see the current rejection based upon the currently pending claims under the 35 U.S.C. § 101 heading above.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
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Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). 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 SLADE E. SMITH whose telephone number is 571- 272-8645. The examiner can normally be reached Monday from 7:30 AM to 3:30 PM.
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, Matthew S. Gart can be reached on 571-272-3955. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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Sincerely,
/SLADE E SMITH/Primary Examiner, Art Unit 3696 03/13/2026