DETAILED ACTION
Notice of 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 3/16/2026 has been entered.
Response to Amendment
Applicant’s Amendment and remarks dated 3/16/2026 have been considered. Claims 6, 13, and 20 were previously cancelled. Claims 21-23 are added. Claims 1-5, 7-12, 14-19, and 21-23 are pending.
Response to Arguments
On page 8 of Applicant’s 3/16/2026 Amendment and remarks, Applicant asserts that no new matter is added and that written description support for new claims 21-23 can be found in at least paras. 0015, 0025, and 0028 of the instant specification.
The examiner agrees that at least paras. 0015, 0025, and 0028 of the instant specification provide sufficient written description support for the claim amendments.
On pages 9-11 of Applicant’s 3/16/2026 Amendment and remarks, with respect to the rejections under 35 U.S.C. 101, with respect to Step 2A, Prong 1, Applicant argues that the newly-added “responsive to flagging the convergence node as the suspicious node, identify transfers associated with the suspicious node as suspected illicit transfers” limitation, that claim 1, as amended is not a mental process and that as a whole, the claimed features “define a specific computer-implemented technique for analyzing complex transaction networks using simulation-based graph traversal.”
The examiner respectfully disagrees. The newly-added “responsive to flagging the convergence node as the suspicious node, identify transfers associated with the suspicious node as suspected illicit transfers” is a mental step. For examine, a human can mentally flag a node as being suspicious, and in response to such flagging, a human can mentally identify transfers associated with the suspicious node as suspected illicit transfers, for example, by identifying at least one edge associated with the node as suspected of being illicit.
Further, the examiner respectfully disagrees that claim 1, as a whole, “define[s] a specific computer-implemented technique for analyzing complex transaction networks using simulation-based graph traversal.” There is no minimum amount of complexity claimed with respect to the recited “dynamic network graph” based on converting “network data” and therefore such graph could be as simple as 2 nodes having a single connected edge. Moreover, mere simulation with respect to random walks over a graph is a mental process, and the addition of general purpose computing techniques (as addressed under Step 2A, Prong 2), does not make the claim, as a whole, pertain to an improvement to a computer technology or other technical field.
On pages 11-12 of Applicant’s 3/16/2026 Amendment and remarks, with respect to the rejections under 35 U.S.C. 101, with respect to Step 2A, Prong 2, Applicant argues that the newly-added “responsive to flagging the convergence node as the suspicious node, identify transfers associated with the suspicious node as suspected illicit transfers” limitation, is more analogous to claim 3 of Example 47 than claim 2 of Example 47.
The examiner respectfully disagrees. As explained above, this newly-added limitation is a mental step, similar to the “(d) detecting one or more anomalies in a data set” of claim 2 of Example 47. In contrast, as set forth in example claim 3 of Example 47, “(d) detecting a source address associated with the one or more malicious network packets in real time; (e) dropping the one or more malicious network packets in real time; and (f) blocking future traffic from the source address” are not mental steps. The examiner has reviewed the specification, and unfortunately, has not seen anything in the specification regarding further steps similar to steps (d)-(f) in example 3 of Claim 47 that could be added to claim 1 to make it subject-matter eligible.
On page 12 of Applicant’s 3/16/2026 Amendment and remarks, with respect to the rejections under 35 U.S.C. 101, with respect to Step 2B, Applicant argues that the analysis does not need to proceed to Step 2B.
The examiner respectfully disagrees for the reasons explained above with respect to Step 2A, Prongs 1-2.
On page 12 of Applicant’s 3/16/2026 Amendment and remarks, Applicant notes that claims 21-23 have been added.
The examiner respectfully submits that claims 21-23 would similarly be rejected under 35 U.S.C. 101. Claims 21-22 merely describe types of transfers and suspected illicit transfers, and a human could look at the types of transfers and ascertain whether they describe illicit transfers. Regardless, such limitations amount to no more than generally linking the use of a judicial exception to a particular technological environment or field of use. As explained by the Supreme Court, a claim directed to a judicial exception cannot be made eligible "simply by having the applicant acquiesce to limiting the reach of the patent for the formula to a particular technological use." Diamond v. Diehr, 450 U.S. 175, 192 n.14, 209 USPQ 1, 10 n. 14 (1981). Thus, limitations that amount to merely indicating a field of use or technological environment in which to apply a judicial exception do not integrate a judicial exception into a practical application.
Claim 23 merely recites “wherein the threshold number of simulation instances varies according to a type of suspected illicit activity” and a human can mentally decide to vary a threshold number based on a type of suspected illicit activity.
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 1-5, 7-12, 14-19, and 21-23 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Regarding Step 1 of the Alice/Mayo framework, Claims 1-5, 7, and 21-23 are directed to a system comprising at least a processor and memory (a machine), Claims 8-12 and 14 are directed to a method (a process), which each fall within one of the four statutory categories of inventions. Claims 15-19 recite a “computer program product comprising a computer readable storage medium,” and para. 0045 of the instant specification states: “A computer readable storage medium, as used herein, is not to be construed as being transitory signals per se, such as radio waves or other freely propagating electromagnetic waves, electromagnetic waves propagating through a waveguide or other transmission media (e.g., light pulses passing through a fiber-optic cable), or electrical signals transmitted through a wire.” Therefore, the broadest reasonable interpretation of “computer readable storage medium” in view of the specification excludes transitory signals per se, and therefore claims 15-29 are not being interpreted as “signals per se” and are considered to be an article of manufacture, which is one of the four statutory categories of inventions.
Regarding Claim 1
Step 2A, prong 1 (Is the claim directed to a law of nature, a natural phenomenon or an abstract idea).
Claim 1 recites the following mental processes, that in each case under the broadest reasonable interpretation, covers performance of the limitation in the mind (including an observation, evaluation, judgment, opinion) or with the aid of pencil and paper but for the recitation of generic computer components (e.g., “memory”, “processor”).
convert the network data into a dynamic network graph, wherein the dynamic network graph comprises a plurality of nodes; (under the broadest reasonable interpretation, this limitation be can be performed mentally, for example, a human can mentally (or using pencil and paper) formulate a dynamic network graph from network data, such as a dynamic network graph having 3 nodes between 3 different bank accounts from the network data)
determine at least one node from the plurality of nodes as an origination node; (under the broadest reasonable interpretation, this limitation be can be performed mentally, for example, a human can mentally (or using pencil and paper) determine that one of the nodes is an origination node)
select the origination node; (under the broadest reasonable interpretation, this limitation be can be performed mentally, for example, a human can mentally (or using pencil and paper) select the origination node as a node to start a random walk traversal from)
deploy at least one random walk simulation on the dynamic network graph from the origination node to one or more other nodes; (under the broadest reasonable interpretation, this limitation be can be performed mentally, for example, a human can simulate a random walk over the dynamic network graph, by mentally moving between different nodes starting from the origination node to different nodes along a path)
determine, from results of the at least one random walk simulation, a convergence node for the at least one random walk simulation (under the broadest reasonable interpretation, this limitation be can be performed mentally, for example, a human can determine, from the results of at least 2 random walk simulations, any common nodes along multiple paths)
determine that the convergence node has a number of simulation instances above a threshold number of simulation instances; (under the broadest reasonable interpretation, this limitation be can be performed mentally, for example, a human can review the simulation results and mentally confirm that the convergence node was in a threshold number of simulation instances (random walks performed mentally))
flag the convergence node as a suspicious node upon determining that the convergence node has the number of simulation instances above the threshold number of simulation instances (under the broadest reasonable interpretation, this limitation be can be performed mentally, for example, a human can mentally flag a node as being suspicious if it has a number of simulation instances above a threshold number of simulation instances)
responsive to flagging the convergence node as the suspicious node, identify transfers associated with the suspicious node as suspected illicit transfers. (under the broadest reasonable interpretation, this limitation be can be performed mentally, for example, a human can mentally flag a node as being suspicious if it has a number of simulation instances above a threshold number of simulation instances, and based upon such flagging, identify particular transactions (e.g. edges leaving from said node) as suspected illicit transfers)
Step 2A, prong 2 (Does the claim recite additional elements that integrate the judicial exception into a practical application?).
The judicial exception is not integrated into a practical application. In particular, the claim recites the additional elements (e.g., “memory”, “processor”) which are recited at a high-level of generality such that they amount to no more than mere instructions to apply the exception using a generic computer component (See MPEP 2106.05(f)).
Regarding the “A system comprising: a memory; and a processor in communication with the memory, the processor being configured to” limitation, such limitations are recited at a high-level of generality and amount to no more than adding the words “apply it” (or an equivalent) with the judicial exception. In particular, the claim only recites the additional elements of a processor and memory. These additional elements are recited at a high-level of generality and amount to no more than mere instructions to apply the exception using generic computer components (a processor and memory). Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea (See MPEP 2106.05(f)).
Regarding the “receive network data” limitation, such additional element of a data gathering step is recited at a high level of generality and amounts to extra-solution activity of receiving data, i.e. pre-solution activity of gathering data for use in the claimed process (see MPEP 2106.05(g)).
Accordingly, at Step 2A, prong two, after considering all claim elements individually and as an ordered combination, it is determined that the claims do not integrate the judicial exception into a practical application.
Step 2B (Does the claim recite additional elements that amount to significantly more than the judicial exception?)
In accordance with Step 2B, the claim does not include additional elements that are sufficient to amount to significantly more that the judicial exception. As discussed above, the additional elements (e.g., “memory”, “processor”) are recited at a high-level of generality such that they amount to no more than mere instructions to apply the exception using a generic computer component (See MPEP 2106.05(f)).
Regarding the “A system comprising: a memory; and a processor in communication with the memory, the processor being configured to” limitation, such limitation is recited at a high-level of generality and amounts to no more than adding the words “apply it” (or an equivalent) with the judicial exception, because the limitation merely provides instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea. Accordingly, this additional element does not add significantly more than the judicial exception. (See MPEP 2106.05(f)).
Regarding the “receive network data” limitation, as discussed above, the additional element of a data gathering step is recited at a high level of generality and amounts to extra-solution activity of receiving data, i.e. pre-solution activity of gathering data for use in the claimed process. The courts have found limitations directed to obtaining information electronically, recited at a high level of generality, to be well-understood, routine, and conventional (see MPEP 2106.05(d)(II), “receiving or transmitting data over a network”, "electronic record keeping," and "storing and retrieving information in memory").
Accordingly, at Step 2B after considering all claim elements individually and as an ordered combination, it is determined that the claims do not integrate the judicial exception into a practical application.
Regarding Claim 2
Step 2A, Prong 1
identify nodes with numbers of transfers more than a threshold number of transfers and with a percentage of transfers under a transfer limit. (under the broadest reasonable interpretation, this limitation be can be performed mentally, for example, a human can mentally identify nodes associated with more than a threshold number of transfers and where a percentage of transfers are under a transfer limit by reviewing data of the graph)
Regarding Step 2A, Prong 2, the claim does not include any additional elements that integrate the judicial exception into a practical application and regarding Step 2B, there are no additional elements recited that amount to significantly more than the judicial exception.
Regarding Claim 3
Step 2A, Prong 1
identify candidate transfers that fall within a time period and under a certain transfer limit. (under the broadest reasonable interpretation, this limitation be can be performed mentally, for example, a human can mentally identify candidate transfers using the recited criteria by mentally reviewing data associated with the graph)
Regarding Step 2A, Prong 2, the claim does not include any additional elements that integrate the judicial exception into a practical application and regarding Step 2B, there are no additional elements recited that amount to significantly more than the judicial exception.
Regarding Claim 4
Step 2A, Prong 1
randomly select a transfer from a current node; (under the broadest reasonable interpretation, this limitation be can be performed mentally, for example, a human can mentally review the graph and randomly select a transfer (or an edge) from a current node)
determine a recipient node that receives the transfer. (under the broadest reasonable interpretation, this limitation be can be performed mentally, for example, a human can mentally review the graph and determine a neighboring node that is connected to the current node via the randomly selected edge)
Regarding Step 2A, Prong 2, the claim does not include any additional elements that integrate the judicial exception into a practical application and regarding Step 2B, there are no additional elements recited that amount to significantly more than the judicial exception.
Regarding Claim 5
Step 2A, Prong 1
set the recipient node as the current node; (under the broadest reasonable interpretation, this limitation be can be performed mentally, for example, a human can traverse from a current node, using an edge, to a neighboring node (recipient node))
repeating the randomly selection of the transfer from the current node and the determination of the recipient node, up to a set number of times. (under the broadest reasonable interpretation, this limitation be can be performed mentally, for example, a human can repeat the randomly selecting and determining steps (of claim 4), and such repetitions can be performed mentally)
Regarding Step 2A, Prong 2, the claim does not include any additional elements that integrate the judicial exception into a practical application and regarding Step 2B, there are no additional elements recited that amount to significantly more than the judicial exception.
Regarding Claim 7
Step 2A, Prong 1
wherein the threshold number of simulation instances is more than 50% of the total simulation instances. (under the broadest reasonable interpretation, this limitation be can be performed mentally, for example, a human can review the simulation results and mentally confirm that the convergence node was in at least 50% of simulation instances (random walks performed mentally))
Regarding Step 2A, Prong 2, the claim does not include any additional elements that integrate the judicial exception into a practical application and regarding Step 2B, there are no additional elements recited that amount to significantly more than the judicial exception.
Regarding Claim 8
Step 2A, Prong 1
Claim 8 recites a method that corresponds to the system of claim 1, and therefore the analysis under Step 2A, Prong 1 with respect to claim 1 also applies to this claim 8.
Step 2A, Prong 2
Claim 8 recites a method that corresponds to the system of claim 1, and therefore the analysis under Step 2A, Prong 2 with respect to claim 1 also applies to this claim 8.
Step 2B
Claim 8 recites a method that corresponds to the system of claim 1, and therefore the analysis under Step 2B with respect to claim 1 also applies to this claim 8.
Claims 9-12 and 14 depend from claim 8, and correspond to the systems of claims 2-5 and 7, respectively, and are therefore rejected for the same reasons explained above with respect to claim 8 and to claims 2-5 and 7, respectively.
Regarding Claim 15
Step 2A, Prong 1
Claim 15 recites a computer program product that corresponds to the system of claim 1, and therefore the analysis under Step 2A, Prong 1 with respect to claim 1 also applies to this claim 15. While claim 15 recites additional generic computing components (“computer program product”, “computer readable storage medium”, “processor”, “program instructions”), such additional generic computing components do not change the analysis under Step 2A, Prong 1.
Step 2A, Prong 2
Claim 15 recites a computer program product that corresponds to the system of claim 1, and therefore the analysis under Step 2A, Prong 2 with respect to claim 1 also applies to this claim 15. While claim 15 recites additional generic computing components (“computer program product”, “computer readable storage medium”, “processor”, “program instructions”), such additional generic computing components do not change the analysis under Step 2A, Prong 2.
Step 2B
Claim 15 recites a computer program product that corresponds to the system of claim 1, and therefore the analysis under Step 2B with respect to claim 1 also applies to this claim 15. While claim 15 recites additional generic computing components (“computer program product”, “computer readable storage medium”, “processor”, “program instructions”), such additional generic computing components do not change the analysis under Step 2B.
Claims 16-19 depend from claim 15, and correspond to the systems of claims 2-5, respectively, and are therefore rejected for the same reasons explained above with respect to claim 15 and to claims 2-5, respectively.
Regarding Claim 21
Step 2A, Prong 1
wherein the transfers comprise transfers of money, cryptocurrency, data, or messages between nodes. (under the broadest reasonable interpretation, this limitation be can be performed mentally, for example, a human can mentally flag a node as being suspicious if it has a number of simulation instances above a threshold number of simulation instances, and based upon such flagging, identify particular transactions concerning money, crypto, data, or messages (e.g. edges leaving from said node) as suspected illicit transfers)
Regarding Claim 22
Step 2A, Prong 1
wherein the suspected illicit transfers correspond to instances of money laundering or data hijacking (under the broadest reasonable interpretation, this limitation be can be performed mentally, for example, a human can mentally flag a node as being suspicious if it has a number of simulation instances above a threshold number of simulation instances, and based upon such flagging, identify particular transactions suspected of money laundering or data hijacking (e.g. edges leaving from said node) as suspected illicit transfers)
Regarding Claim 23
Step 2A, Prong 1
wherein the threshold number of simulation instances varies according to a type of suspected illicit activity (under the broadest reasonable interpretation, this limitation be can be performed mentally, for example, a human can mentally flag a node as being suspicious if it has a number of simulation instances above a threshold number of simulation instances, where such threshold can be lower, for example, for suspected money laundering and higher for other types of illicit activity)
Allowable Subject Matter
Claims 1-5, 7-12, 14-19, and 21-23 would be allowed if the rejections under 35 U.S.C. 101 are overcome.
The following is a statement of reasons for the indication of allowable subject matter:
Claim 1 would be allowed, if the rejections under 35 U.S.C. 101 are overcome, because none of the references of record either alone or in combination fairly disclose or suggest the combination of limitations specified in the claim, including at least:
determine that the convergence node has a number of simulation instances above a threshold number of simulation instances;
flag the convergence node as a suspicious node upon determining that the convergence node has the number of simulation instances above the threshold number of simulation instances.
The closest prior art of record discloses:
Zhong, Ming, et al. "The convergence-guaranteed random walk and its applications in peer-to-peer networks." IEEE Transactions on Computers 57.5 (2008): pp. 619-633, hereinafter referenced as ZHONG, teaches a peer-to-peer random walking technique where a node with a “highest visitation probability” is determined with respect to an originating node.
US 20230252491 A1, hereinafter referenced as SHI, discloses random walking techniques over a graph representing merchant transactions, where a high volume merchant node exceeds a threshold number of transactions with different accounts. (paras. 0028, 0045). SHI further discloses identifying suspicious accounts. (para. 0103). But SHI does not explicitly teach that a high volume account is “suspicious.”
US 10671672 B1, hereinafter referenced as EKSOMBATCHAI, discloses node graph traversal methods where a visit count is compared to a visit count threshold. (col. 2, lines 36-43).
US 20220198471 A1, hereinafter referenced as SILVA, discloses that “if a transaction amount is more than a specified threshold and/or an entity is from a specified list of countries, then the corresponding node may be labeled as suspicious and act as a stopping point in a random walk.” (para. 0034). However, the labeling of a node as suspicious is based on transaction amount and not explicitly based on a number of simulation instances.
Moreau, Antoine. “How to Perform Fraud Detection with Personalized Page Rank” (April 8, 2022) (submitted in Applicant’s 9/9/2025 IDS) discloses an application of the Page Rank algorithm (which utilizes random walks) to fraud detection. (See pp. 6-7). However, this article does not specifically teach determining a number of simulation instances above a threshold number of simulation instances.
However, the examiner has found that the distinct feature of the Applicant's claimed invention over the prior art is the explicit claiming of the aforementioned limitations in combination with all the other limitations as specified in claim 1. Specifically, one of ordinary skill would not combine the ZHONG reference with the other referenced cited above in the manner specifically recited in claim 1, where the random walking technique determines a convergence node that “has a number of simulation instances above a threshold number of simulation instances” and then flags such “convergence node” as being suspicious, without the hindsight aid of Applicant’s disclosure. It would not have been obvious to one of skill in the art that such a convergence node would also be suspicious, as SHI teaches that such a common node is more likely to be a large, valid merchant. Therefore, because the prior art of record does not anticipate nor make obvious the limitations recited in claim 1, claim 1 would be allowable over the prior art, provided that the rejections under 35 U.S.C. 101 are overcome.
Dependent claims 2-5, 7, and 21-23 depend from claim 1, and would be allowed for depending from an allowed independent base claim, provided that the rejections under 35 U.S.C. 101 are overcome.
Claim 8 recites a method that corresponds to the system of claim 1, and would be allowed for the same reasons explained above with respect to claim 1, provided that the rejections under 35 U.S.C. 101 are overcome.
Dependent claims 9-12 and 14 depend from claim 8, and would be allowed for depending from an allowed independent base claim, provided that the rejections under 35 U.S.C. 101 are overcome.
Claim 15 recites a computer program product comprising a computer readable storage medium that corresponds to the system of claim 1, and would be allowed for the same reasons explained above with respect to claim 1, provided that the rejections under 35 U.S.C. 101 are overcome.
Dependent claims 16-19 depend from claim 15, and would be allowed for depending from an allowed independent base claim, provided that the rejections under 35 U.S.C. 101 are overcome.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to MICHAEL C LEE whose telephone number is (571)272-4933. The examiner can normally be reached M-F 12:00 pm - 8:00 pm ET.
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, Omar Fernandez Rivas can be reached at 571-272-2589. 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.
/MICHAEL C. LEE/Examiner, Art Unit 2128
Prosecution Insights