Prosecution Insights
Last updated: April 19, 2026
Application No. 17/355,911

APPLYING A FUNCTION TO A PASSWORD TO DETERMINE AN EXPECTED RESPONSE

Final Rejection §101
Filed
Jun 23, 2021
Examiner
PERUNGAVOOR, VENKATANARAY
Art Unit
2492
Tech Center
2400 — Computer Networks
Assignee
American Express Travel Related Services Company, Inc.
OA Round
9 (Final)
88%
Grant Probability
Favorable
10-11
OA Rounds
2y 10m
To Grant
91%
With Interview

Examiner Intelligence

Grants 88% — above average
88%
Career Allow Rate
877 granted / 999 resolved
+29.8% vs TC avg
Minimal +4% lift
Without
With
+3.5%
Interview Lift
resolved cases with interview
Typical timeline
2y 10m
Avg Prosecution
43 currently pending
Career history
1042
Total Applications
across all art units

Statute-Specific Performance

§101
13.6%
-26.4% vs TC avg
§103
43.7%
+3.7% vs TC avg
§102
16.7%
-23.3% vs TC avg
§112
11.9%
-28.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 999 resolved cases

Office Action

§101
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 . DETAILED ACTION This office action is in response to the application filed on or reply to the remarks of 1/7/2026. The instant application has claims 1-3,5-11 and 13-22 pending. The system, method and medium for generating an OTP seed for authorization for accessing private data. There a total of 20 claims. Response to Arguments The applicant’s argument relating to integrated into a practical application is not persuasive. There are several court cases that illustrate a practical concept is still deemed abstract idea and ineligible by Fed. Circuit Court. The examples include device profiles for imaging device, playing bingo, or guarantee online transaction, data analysis on documents. See Digitech Image Tech's v. Electronics For Imaging, 758 F.3d 1344 (Fed. Cir. 2014); Planet Bingo, LLC v. VKGS, LLC, 576 Fed. Appx. 1005 (Fed. Cir. 2014) ; Buysafe, Inc. v. Google, Inc., 765 F.3d 1350 (Fed. Cir. 2014); Content Extraction and Transmission. v. Wells Fargo Bank, 776 F.3d 1343 (Fed. Cir. 2014) 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 1-3,5-11 and 13-22 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. The steps can be performed by an human on an generic computer. The claim recites the generating of OTP for authorization, which can be implemented on an generic computer. And further the steps of generating OTP is based on an mathematical algorithm using seed and permanent device identifier. The limitation of “receiving, from the service provider, a seed for a one-time password (OTP) the for the user device from the service provider, wherein the seed for the OTP comprises a random number that is (1) valid for a predetermined time period and (2) is discarded after first use, wherein the listening service monitors for incoming seeds from the OTP authorization service of the service provider”, as drafted, is a process that, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components. That is, other than reciting “by a processor,” nothing in the claim element precludes the step from practically being performed in the mind. For example, but for the “by a processor” language, “receiving, the service provider, a seed for a one-time password (OTP) the for the user device from the service provider, wherein the seed for the OTP comprises a random number that is (1) valid for a predetermined time period and (2) is discarded after first use, wherein the listening service monitors for incoming seeds from the OTP authorization service of the service provider” in the context of this claim encompasses the user receiving an OTP seed from an service provider on an mobile phone to be entered into the computer to authorize an transaction. Similarly, the limitation of “receiving, a validation result from the service provider indicating that the service provider independently generated the device bound response OTP from the seed for the OTP and the permanent unique device identifier of the user device using a same deterministic function, wherein the seed for the OTP is discarded after receipt of the validation result;”, as drafted, is a process that, under its broadest reasonable interpretation, covers performance of the limitation done in the mind but for the recitation of generic computer components the 2019 Revised Patent Subject Matter Eligibility Guidance (“2019 PEG”) Federal Register January 7, 2019. For example, but for the “by a processor” language, “receiving, , a validation result from the service provider indicating that the service provider independently generated the device bound response OTP from the seed for the OTP and the permanent unique device identifier of the user device using a same deterministic function, wherein the seed for the OTP is discarded after receipt of the validation result;” in the context of this claim encompasses the user receiving an result of confirmation of the correct entry of OTP for acceptance, e.g. as mentioned in clam 7 the mobile device gets success message. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components, then it falls within the “Certain methods of organizing human activity” & “Mathematical Concepts” grouping of abstract ideas. Accordingly, the claim recites an abstract idea. This judicial exception is not integrated into a practical application. In particular, the claim only recites one additional element – using a processor to perform both the “receiving, the service provider, a seed for a one-time password (OTP) for the user device from the service provider, wherein the seed for the OTP comprises a random number that is (1) valid for a predetermined time period and (2) is discarded after first use, wherein the listening service monitors for incoming seeds from the OTP authorization service of the service provider” and “receiving, , a validation result from the service provider indicating that the service provider independently generated the device bound response OTP from the seed for the OTP and the permanent unique device identifier of the user device using a same deterministic function, wherein the seed for the OTP is discarded after receipt of the validation result;” steps. The processor in both steps is recited at a high-level of generality (i.e., as a generic processor performing a generic computer function of user receiving an OTP seed for entry into computer for validation and receiving positive or negative result) such that it amounts no more than mere instructions to apply the exception using a generic computer component. Accordingly, this additional element does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. The claim is directed to an abstract idea. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional element of using a processor to perform user receiving an OTP seed for entry into computer for validation and receiving positive or negative result steps amounts to no more than mere instructions to apply the exception using a generic computer component. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. The claim is not patent eligible. Furthermore, there are several court cases where similar subject matter was found ineligible. The Federal Circuit held that a patent was directed to an abstract idea when it allowed a purchaser to use a one-time code instead of a credit card number to complete a transaction see Universal Secure Registry LLC v. Apple Inc., (Fed. Cir. 2021). Another case, which involved allowing a credit card to be used to authorize a transit ride without any other ticket or card and included the ability to automatically purchase a monthly fare voucher, were directed to an abstract idea see Smart Systems Innovations v. Chicago Transit Authority, 873 F.3d 1364 (Fed. Cir. 2017). Conclusion THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to Venkat Perungavoor whose telephone number is (571)272-7213. The examiner can normally be reached 9-5. 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, Rupal Dharia can be reached on 571-272-3880. 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. /VENKAT PERUNGAVOOR/Primary Examiner, Art Unit 2492 Email: venkatanarayan.perungavoor@uspto.gov
Read full office action

Prosecution Timeline

Jun 23, 2021
Application Filed
Jun 28, 2021
Response after Non-Final Action
Feb 02, 2023
Non-Final Rejection — §101
Apr 28, 2023
Interview Requested
May 04, 2023
Examiner Interview Summary
May 04, 2023
Examiner Interview (Telephonic)
May 08, 2023
Response Filed
Jun 06, 2023
Final Rejection — §101
Aug 14, 2023
Response after Non-Final Action
Sep 12, 2023
Request for Continued Examination
Oct 05, 2023
Response after Non-Final Action
Oct 23, 2023
Non-Final Rejection — §101
Jan 29, 2024
Response Filed
Feb 13, 2024
Final Rejection — §101
Apr 03, 2024
Interview Requested
Apr 10, 2024
Examiner Interview Summary
Apr 10, 2024
Applicant Interview (Telephonic)
Apr 16, 2024
Response after Non-Final Action
Apr 23, 2024
Examiner Interview (Telephonic)
Apr 24, 2024
Response after Non-Final Action
May 16, 2024
Request for Continued Examination
May 22, 2024
Response after Non-Final Action
Oct 07, 2024
Final Rejection — §101
Dec 05, 2024
Examiner Interview (Telephonic)
Dec 05, 2024
Examiner Interview Summary
Jan 09, 2025
Response after Non-Final Action
Jan 24, 2025
Non-Final Rejection — §101
Jan 24, 2025
Examiner Interview (Telephonic)
Apr 29, 2025
Response Filed
May 19, 2025
Final Rejection — §101
Jul 22, 2025
Response after Non-Final Action
Aug 20, 2025
Request for Continued Examination
Aug 26, 2025
Response after Non-Final Action
Oct 06, 2025
Non-Final Rejection — §101
Jan 07, 2026
Response Filed
Feb 09, 2026
Final Rejection — §101
Apr 09, 2026
Applicant Interview (Telephonic)
Apr 09, 2026
Examiner Interview Summary

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

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Prosecution Projections

10-11
Expected OA Rounds
88%
Grant Probability
91%
With Interview (+3.5%)
2y 10m
Median Time to Grant
High
PTA Risk
Based on 999 resolved cases by this examiner. Grant probability derived from career allow rate.

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