DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Status of Claims
This action is in reply to the amendment filed 12/15/2025.
Claims 1-2, 4, 6, 10-11, 13, 16, and 18 have been amended. Claims 1-20 are pending and have been examined on the merits (claims 1, 10, and 16 being independent).
The amendment filed 12/15/2025 to the claims has been entered.
Response to Arguments
Applicant’s arguments and amendments filed 12/15/2025 have been fully considered.
Applicants assert that the pending claims fully comply with the requirement of 35 U.S.C. 101. Examiner respectfully disagrees. Applicant’s argument and amendments have been considered and are not persuasive. The rejections under 35 U.S.C. 101 have been maintained and clarified in view of the USPTO MPEP 2106.
Applicant’s arguments (see Applicant’s remarks, pages 15-23)
(1) Applicant’s arguments that “Currently amended independent claims 1, 10, and 16 contain patentable subject matter as they present limitations that integrate the alleged abstract idea into a practical application by improving the functioning of a network-transaction-security system by utilizing a trained dispute evaluator machine-learning model to more accurately predict likelihood of dispute request approval, thereby improving computing processing and efficiency within the network-transaction security system.” (see page 16), are not found persuasive.
Examiner responses: As set forth in the previous Office Action, it is determined whether the claim is directed to the abstract concept itself or whether it is instead directed to some technological implementation or application of, or improvement to, this concept, i.e., integrated into a practical application. See, e.g., Alice, 573 U.S. at 223, discussing Diamond v. Diehr, 450 U.S. 175 (1981 ). The mere introduction of a computer or generic computer technology into the claims need not alter the analysis. See Alice, 573 U.S. at 223-24. "[T]he relevant question is whether the claims here do more than simply instruct the practitioner to implement the abstract idea on a generic computer." Alice, 573 U.S. at 225.
In the instant application, Examiner considers that the claim limitations are not indicative of integration into a practical application by claiming an improvement to the functioning of the computer or to any other technology or technical field. Further, the claim limitations are not indicative of integration into a practical application by applying or using the judicial exception in some other meaningful way. In particular the claim limits of 1) “from a client device” and “utilizing a dispute-evaluator machine-learning model” amount to simply applying the abstract idea to a computer component. (e.g. “apply it”) 2) “storing instructions that, when executed by at least one processor, cause a computer system to” describes transmitting generic instructions to a generic device, and therefore also amounts to simply applying the abstract idea to a generic processor. (e.g. “apply it” or the equivalent), and (3) “a dispute-evaluator machine-learning model”, “a fraud prediction machine learning model”, and “a rule-based model” (e.g. “apply it”) are claimed and described at a high level of generality and are functions any general purpose computer performs such that it amount no more than mere instruction to apply the exception to a particular technological environment. Furthermore, none of the limitations recite technological implementations details for any of the steps but, instead, only recite broad functional language being performed by the generic use of a computer component. The claim limits also recite the use of a client device, a user account device, a dispute-evaluator machine-learning model, a fraud prediction machine learning model, a rule-based model, processor, and a network transaction system as additional elements. However, the use of these additionally elements, described at a high level of generality, perform generic computer functions such that it amounts to no more than mere instruction to apply the exception to a particular technological environment. Accordingly, these additional elements do not integrate the abstract idea into a practical application because it does not impose any meaning limits on practicing the abstract idea. Thus, Applicant’s arguments are not persuasive.
(2) Applicant’s arguments that “Currently amended dependent claims 2, 4, 6, 11, 13, and 18 further contain patentable subject matter as they present limitations that reduce network traffic and preserve computing resources within a network-transaction-security system, thereby improving computing processing and efficiency and integrating the alleged abstract idea into a practical application.” (see page 20), are not found persuasive.
Examiner responses: As set forth in response above, none of the limitations recite technological implementations details for any of the steps but, instead, only recite broad functional language being performed by the generic use of a computer component. The claim limits also recite the use of a client device, a user account device, a dispute-evaluator machine-learning model, a fraud prediction machine learning model, a rule-based model, processor, and a network transaction system as additional elements. However, the use of these additionally elements, described at a high level of generality, perform generic computer functions such that it amounts to no more than mere instruction to apply the exception to a particular technological environment. Accordingly, these additional elements do not integrate the abstract idea into a practical application because it does not impose any meaning limits on practicing the abstract idea. Further, there is no evidence to show how the additional limitations reduce network traffic and improve the computing processing. Thus, Applicant’s arguments are not persuasive.
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter without significantly more.
When considering subject matter eligibility under 35 U.S.C. 101, (1) it must be determined whether the claim is directed to one of the four statutory categories of invention, i.e., process, machine, manufacture, or composition of matter. If the claim does fall within one of the statutory categories, (2a) it must then be determined whether the claim is directed to a judicial exception (i.e., law of nature, natural phenomenon, and abstract idea), and if so (2b), it must additionally be determined whether the claim is a patent-eligible application of the exception. If an abstract idea is present in the claim, any element or combination of elements in the claim must be sufficient to ensure that the claim amounts to significantly more than the abstract idea itself. Examples of abstract ideas include fundamental economic practices; certain methods of organizing human activities; an idea itself; and mathematical relationships/formulas. Alice Corporation Pty. Ltd. v. CLS Bank International, et al., 573 U.S. (2014).
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. In the instant case, the claim(s) as a whole, considering all claim elements both individually and in combination, do not amount to significantly more than an abstract idea.
Step (1): In the instant case, the claims are directed towards to a method for managing a dispute request associated with disputed transactions within a user account which contains the steps of receiving, accessing, generating, prompting, determining, applying, and generating. The claim recites a series of steps and, therefore, is a process. The claims do fall within at least one of the four categories of patent eligible subject matter because claim 1 is direct to a computer-implemented method, claim 10 is direct to a non-transitory computer-readable medium, and claim 16 is direct to a system, i.e. machines programmed to carrying out process steps, Step 1-yes.
Step (2A) Prong 1: A method for managing a dispute request associated with disputed transactions within a user account is akin to the abstract idea subject matter grouping of: Certain Methods of Organizing Human Activity as fundamental economic principles or practices and commercial or legal interactions. As such, the claims include an abstract idea.
The specific limitations of the invention are (a) identified to encompass the abstract idea include: receiving… a dispute request…, accessing… one or more feature groups…, generating… approval score…, prompting… training feature group…, generating… training loss value…, generating… fraud prediction score…, generating… rule-base score…, generating… an adjusted likelihood of approval score…, determining… fraud prediction score weight…, determining… rule-based score weight…, determining… transaction factor weight…, generating… combined weight…, applying… combined weight…, and generating… a notification…
As stated above, this abstract idea falls into the (b) subject matter grouping of: Certain Methods of Organizing Human Activity as fundamental economic principles or practices and commercial or legal interactions.
Step (2A) Prong 2: The instant claims do not integrate the exception into a practical application because additional elements: 1) “from a client device” and “utilizing a dispute-evaluator machine-learning model” amount to simply applying the abstract idea to a computer component. (e.g. “apply it”) 2) “storing instructions that, when executed by at least one processor, cause a computer system to” describes transmitting generic instructions to a generic device, and therefore also amounts to simply applying the abstract idea to a generic processor. (e.g. “apply it” or the equivalent), and (3) “a dispute-evaluator machine-learning model”, “a fraud prediction machine learning model”, and “a rule-based model” (e.g. “apply it”) do not apply, rely on, or use the judicial exception in a manner that that imposes a meaningful limitation on the judicial exception (i.e. generally linking the use of the judicial exception to a particular technological environment or field of use - see MPEP 2106.05(h) or apply it 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)).
The instant recited claims including additional elements (e.g., a client device, a user account device, a dispute-evaluator machine-learning model, a fraud prediction machine learning model, a rule-based model, processor, and a network transaction system) do not improve the functioning of the computer or improve another technology or technical field nor do they recite meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment. The limitations merely use a generic computing technology (Specification paragraph [0159]: computer hardware, processors, computer-executable instructions, and computing devices) as apply it 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)). Therefore, the claims are directed to an abstract idea.
Step (2B): The claims do 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 elements (Claims: e.g., a client device, a user account device, a dispute-evaluator machine-learning model, a fraud prediction machine learning model, a rule-based model, processor, and a network transaction system) amount to no more than mere instructions to apply the exactly using generic computer component. The claim elements when considered separately and in an ordered combination, do not add significantly more than implementing the abstract idea over a generic computer (e.g., a processor/a client device)
The computer is merely a platform on which the abstract idea is implemented. Simply executing an abstract concept on a computer does not render a computer “specialized,” nor does it transform a patent-ineligible claim into a patent-eligible one. See Bancorp Servs., LLC v. Sun Life Assurance Co. of Can., 687 F.3d 1266, 1280 (Fed. Cir. 2012). There are no improvements to another technology or technical field, no improvements to the functioning of the computer itself, transformation or reduction of a particular article to a different state or thing or any other meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment as a result of performing the claimed method. Also, the addition of merely novel or non-routine components to the claimed idea does not necessarily turn an abstraction into something concrete (See Ultramercial, Inc. v. Hulu, LLC, _ F.3d_, 2014 WL 5904902, (Fed. Cir. Nov. 14, 2014). Hence, the claims do not recite significantly more than an abstract idea. In conclusion, merely “linking/applying” the exception using generic computer components does not constitute ‘significantly more’ than the abstract idea. (MPEP 2106.05 (f)(h)). Therefore, the claims are not patent eligible under 35 USC 101.
Dependent claims 2-9, 11-15, and 17-20 when analyzed as a whole and in an ordered combination are held to be patent ineligible under 35 U.S.C. 101 because the additional recited limitation(s) fail(s) to establish that the claim(s) is/are not directed to an abstract idea, as detailed below. The additional recited limitations in the dependent claims only refine the abstract idea.
For instance, in claim 2, the step of “… processing the dispute request; if the dispute request is approved, converting the provisional credit into final credit;...” (i.e., processing a dispute request), in claims 3, the step of “… generating, … the likelihood of approval score….” (i.e., generating a score), in claim 4, the step of “… granting final credit automatically when an output … satisfies a final credit threshold...” (i.e., allowing a credit), in claims 5 and 12, the step of “… generating the notification…… ” (i.e., making a notification), in claims 6, 13, and 18, the step of “… generating a user account quality score; and determining a provisional credit limit ...” (i.e., determining a provisional credit limit), in claims 7, 14, and 19, the step of “… generating,… the likelihood of approval score...” (i.e., generating a score), in claim 8, the step of “… assigning a weight to each of the plurality of feature groups....” (i.e., assigning a weight), in claims 9, 15, and 20, the step of “… determining an age of the user account; determining a dormant status of the user account; comparing a merchant of the dispute request to a list of predetermined merchants;...” (i.e., determining a status of a user account), and in claims 11 and 17, the step of “… wherein generating, the adjusted likelihood of approval score further comprises weighting the rule-based score with a first weight and the fraud prediction score with a second weight to generate the adjusted likelihood of approval score.....” (i.e., updating a score) are all processes that, under its broadest reasonable interpretation, covers performance of a fundamental economic practice but for the recitation of a generic computer component. Processing a dispute request associated with disputed transactions within a user account is a most fundamental commercial process.
This is an abstract concept with nothing more and is also considered mere instructions to apply an exception akin to a commonplace business method or mathematical algorithm being applied on a general purpose computer, Alice Corp. Pty. Ltd.; Gottschalk and Versata Dev. Group, Inc.; see MPEP 2106.05(f)(2).
In dependent claims 2-9, 11-15, and 17-20, the step claimed are rejected under the same analysis and rationale as the independent claims 1, 10, and 16 above. Merely claiming the same process using a dispute-evaluator machine-learning model to process a dispute request associated with disputed transactions within a user account does not change the abstract idea without an inventive concept or significantly more. Clearly, the additional recited limitations in the dependent claims only refine the abstract idea further. Further refinement of an abstract idea does not convert an abstract idea into something concrete.
Therefore, claims 1-20 are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter.
Conclusion
The prior art made of record but not relied upon herein but pertinent to Applicant’s disclosure is listed in the enclosed PTO-892.
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 extension fee 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 YONG S PARK whose telephone number is (571)272-8349. The examiner can normally be reached on M-F 9:00-5:00 PM, EST.
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/YONGSIK PARK/Examiner, Art Unit 3694
February 13, 2026
/BENNETT M SIGMOND/Supervisory Patent Examiner, Art Unit 3694