Prosecution Insights
Last updated: April 19, 2026
Application No. 17/353,637

GROUPING PAYMENTS AND PAYMENT REQUESTS

Non-Final OA §101
Filed
Jun 21, 2021
Examiner
FELTEN, DANIEL S
Art Unit
3692
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Block Inc.
OA Round
5 (Non-Final)
46%
Grant Probability
Moderate
5-6
OA Rounds
4y 11m
To Grant
58%
With Interview

Examiner Intelligence

Grants 46% of resolved cases
46%
Career Allow Rate
267 granted / 586 resolved
-6.4% vs TC avg
Moderate +12% lift
Without
With
+12.1%
Interview Lift
resolved cases with interview
Typical timeline
4y 11m
Avg Prosecution
39 currently pending
Career history
625
Total Applications
across all art units

Statute-Specific Performance

§101
32.9%
-7.1% vs TC avg
§103
34.0%
-6.0% vs TC avg
§102
7.1%
-32.9% vs TC avg
§112
23.2%
-16.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 586 resolved cases

Office Action

§101
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 . 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 02/12/2026 has been entered. Acknowledgement Applicant’s amendments and remarks submitted on 02/12/2026 are acknowledged. Status of Claims Claims 1-2, 4, 6-8, 10-11, 15 and 19-22 are amended. Claim 5 is cancelled. Claim 23 is new Claims 1-4, 6-8, 10-17 and 19-23 are pending in the application and are presented to be examined upon their merits. Response to Arguments Intended Use It is acknowledged that claims 1-2, 7-8, 11, 15 and 21 have been amended to remove intended use language. Rejections Under 35 U.S.C. § 101 It is acknowledged that independent claims 19 and 20 are amended to recite, “accessing one or more applications on the first user device,” “applying the one or more filters to one or more applications,” “processing information retrieved from the one or more applications to which the one or more filters are applied,” and “determining corresponding user relationship data between the first user and each one of the plurality of second users based on the information.”. Although the Applicant asserts that the recited limitations in claim 1 improve the security of mobile payment platform applications, it is maintained that the limitations, under the broadest reasonable interpretation can be thought of as abstract of “managing personal behavior or relationships or interactions between people” which may include social activities, teaching, and following rules or instructions, as example, filtering content, BASCOM Global Internet v. AT&T Mobility, LLC, 827 F.3d 1341, 1345-46, 119 USPQ2d 1236, 1239 (Fed. Cir. 2016) (finding that filtering content was an abstract idea under step 2A. It can also be considered “collecting information, analyzing it, and displaying certain results of the collection and analysis,” where the data analysis steps are recited at a high level of generality such that they could practically be performed in the human mind, Electric Power Group v. Alstom, S.A., 830 F.3d 1350, 1353-54, 119 USPQ2d 1739, 1741-42 (Fed. Cir. 2016). Again, the 35 USC 101 rejection is maintained because, after further consideration, the analyzing steps recited in the claim(s) merely recites using data to filter intended recipients (i.e., analyzing certain data such as “contextual relationship” on the user device to extract information to determine contextual relationships), which the courts have determined not to be an improvement to the functioning of a computer itself or to any other technology or technical field, [See MPEP 2106.05(a)], but determined as computer functions that are well-understood, routine and conventional [see MPEP 2106.05(d)(I)(2)(iv)]. Thus, it is the case that the additional elements in combination do no more than generally link the use of the judicial exception to a particular technical environment (Fig. 1)(network-based environment) or technical field of use [see specification, (item# 100), ¶0024-¶0025, ¶0029]. The 35 U.S.C. 103 rejection with withdrawn. Claim Rejections - 35 USC § 101 35 U.S.C. 101 reads as follows: Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title. Claims 1-4, 6-8, 10-17 and 19-23 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 abstract idea) without significantly more. Claims 1-4 and 10-17 are directed to a method, claims 19 and 21 are directed to a system, and claims 20 and 22 are directed to a non-transitory readable storage medium. Therefore, these claims fall within the four statutory categories of invention. The claimed invention, clam 1 being representative, is directed to an abstract idea of splitting a payment by sending and receiving a group message (i.e., payment request) Claim 1 recites, “receiving,.., an indication to initiate a money transfer…wherein receiving the indication includes detecting…one or more filters for identifying…for the money transfer;… analyzing… a contextual relationship between the first user and the second users…based at least in part on the one or more filters,…wherein analyzing…includes accessing…to extract information relevant to determining the contextual relationship between the first user and the individual second users, and yields user relationship data ; selecting,…,one or more second users from among the individual second users based at least on the user relationship; sending,…the request for the money transfer to at least one or more second users.”, which can be grouped under certain methods of organizing human because the claims involve fundamental economic practices- including legal interactions in terms of payment services that are indicative of sales activities [see e.g., specification ¶0026], as well as conveying concepts relating to settlement processes, which suggest the formulation of contractual agreements or negotiations between people in the performance of financial transactions and/or the satisfaction of legal obligations. The additional elements (i.e., user device, payment service system, filters etc.,) individually or in combination as a whole does not put the judicial exception into a practical application because the additional elements are recited at a high level of generality [ see specification, (Fig. 1)[¶0024-¶0025] as well as (Fig. 12)[¶0070-¶0074]] and does not show an improvement to the functioning of the computer itself or another technology. For example, the specification and claims describe sending and receiving data over a network. [see specification [¶0024-¶0025] ]. Moreover, the determining and the analyzing steps recited in the claim(s) merely recites using data to filter intended recipients (i.e., analyzing certain data such as “contextual relationship” on the user device to extract information to determine contextual relationships), which the courts have determined not to be an improvement to the functioning of a computer itself or to any other technology or technical field, [See MPEP 2106.05(a)], but computer functions that are well-understood, routine and conventional [see MPEP 2106.05(d)(I)(2)(iv)] Thus, it is the case that the additional elements in combination do no more than generally link the use of the judicial exception to a particular technical environment (Fig. 1)(network-based environment) or technical field of use [see specification, (item# 100), ¶0024-¶0025, ¶0029]. The additional elements individually and in combination as a whole, perform computer functions of receiving and sending messages (data) over a network (i.e., via WiFi, cellular and/or Bluetooth) to process payment transactions. It is maintained that the courts have recognized certain computer functions of receiving, processing and storing data as well as transmitting data over a network as unpatentable [see MPEP 2106.05(d)(II)(i) Symantec, 838 F.3d at 1321, 120 USPQ2d at 1362 (utilizing an intermediary computer to forward information); TLI Communications LLC v. AV Auto. LLC, 823 F.3d 607, 610, 118 USPQ2d 1744, 1745 (Fed. Cir. 2016) (using a telephone for image transmission); OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1093 (Fed. Cir. 2015) (sending messages over a network); buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014) (computer receives and sends information over a network); (iv) 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., 788 F.3d at 1363, 115 USPQ2d at 1092-93]. Claims 2-4 recite elements which are provided to carry out the abstract idea without being improved or providing significantly more than the abstract idea. Claims 6-8 recite information regarding the contextual information (i.e., transaction history, list of identifiers, schedule information, etc.,). This is non-function descriptive material. Where a claim limitation is directed to conveying a message or meaning to a human reader independent of the intended computer system, and/or non-transitory computer-readable medium merely serves as a support for information or data, no functional relationship exists. See In re Gulack, 703 F.2d 1381, 1385, 217 USPQ 401, 404 (Fed. Cir. 1983). Claims 11-17 further recite, how to implement the abstract idea. Independent claims 20 does not provide meaningful limitation in that it provides a storage medium for storing instruction to implement the abstract idea. Independent claim 19 provides a system that is similarly rejected as claim 1. Clam 21 does not provide a meaningful limitation which is significantly more than the abstract idea. Claim 22 does not provide a meaningful limitation which is significantly more than the abstract idea. Claim 23 does not provide a meaningful limitation which is significantly more than the abstract idea. Conclusion 58. Any inquiry concerning this communication or earlier communications from the examiner should be directed to DANIEL S FELTEN whose telephone number is (571)272-6742. The examiner can normally be reached Flex. 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, Ryan D Donlon can be reached on 5712703602. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. DANIEL S. FELTEN Examiner Art Unit 3692 /DANIEL S FELTEN/Primary Examiner, Art Unit 3692
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Prosecution Timeline

Jun 21, 2021
Application Filed
Dec 02, 2023
Non-Final Rejection — §101
Mar 12, 2024
Applicant Interview (Telephonic)
Mar 12, 2024
Examiner Interview Summary
Apr 08, 2024
Response Filed
Jul 12, 2024
Final Rejection — §101
Nov 16, 2024
Applicant Interview (Telephonic)
Nov 16, 2024
Examiner Interview Summary
Nov 18, 2024
Request for Continued Examination
Nov 19, 2024
Response after Non-Final Action
Mar 17, 2025
Non-Final Rejection — §101
May 07, 2025
Interview Requested
Aug 20, 2025
Response Filed
Nov 09, 2025
Final Rejection — §101
Dec 22, 2025
Interview Requested
Feb 12, 2026
Request for Continued Examination
Mar 04, 2026
Response after Non-Final Action
Mar 21, 2026
Non-Final Rejection — §101 (current)

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

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Prosecution Projections

5-6
Expected OA Rounds
46%
Grant Probability
58%
With Interview (+12.1%)
4y 11m
Median Time to Grant
High
PTA Risk
Based on 586 resolved cases by this examiner. Grant probability derived from career allow rate.

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