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 .
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 07/20/2026 has been entered.
The following is a non-final office action in response to the request for continued examination of 07/20/2026.
Status of Claims
Claims 1-20, as originally filed 07/20/2026, are pending and have been examined on the merits (claims 1, 10, and 16 being independent). Claims 1, 10, and 16 have been amended.
Response to Arguments
Applicant’s arguments and amendments filed 07/20/2026 have been fully considered but they are not persuasive.
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 USC 101 have been maintained and clarified in view of the USPTO MPEP 2106.
Applicant’s arguments (see Applicant’s remarks, pages 13-15)
Step 2A - Prong 1
(1) Applicant’s arguments that “Contrary to the Office's position, the claims are not directed to a method of organizing human activity, a fundamental economic principle, or a commercial interaction. Rather, the claimed invention is directed to a specific, technical machine-learning architecture and multi model data processing pipeline that solves technical problems inherent in network-transaction security systems.” (see page 13), are not found persuasive.
Examiner’s responses (1): Under Step 2 A, Prong 1 of the 2019 Revised § 101 Guidance, it is determined whether the claims are directed to a judicial exception such as a law of nature, a natural phenomenon, or an abstract idea (See Alice, 134 S. Ct. at 2355) by identify the specific limitation(s) in the claim that recites abstract idea(s); and then determine whether the identified limitation(s) falls within at least one of the groupings of abstract ideas enumerated in the MPEP 2106.04.
The cited limitations as drafted are systems and methods that, under their broadest reasonable interpretation, covers performance of a method of organizing human activity, but for the recitation of the generic computer components. Further, 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 at least one processor. Managing a dispute request associated with disputed transactions within a user account is a fundamental economic practice long prevalent in commerce systems. If a claim limitation, under its broadest reasonable interpretation, covers a fundamental economic principle or practice but for the general linking to a technological environment, then it falls within the organizing human activity grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
Step 2A - Prong 2
(2) Applicant’s arguments that “Assuming, arguendo, that an abstract idea is recited, the claims nevertheless integrate any alleged abstract idea into a practical application by improving the functioning of the computer and network-transaction-security system itself.” (see page 14), are not found persuasive.
Examiner’s responses (2): Under Step 2A Prong 2, 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.
Step 2B - Inventive Concept
(3) Applicant’s arguments that “Additionally, under Step 2B, Applicant respectfully submits that, even if the claims were considered to involve an abstract idea, the amended claims recite "significantly more" by virtue of the non-conventional and non-generic combination of specific technical features.” (see page 15), are not found persuasive.
Examiner’s responses (3): Under Step 2B, 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 into a practical application, the additional elements 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. 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, in response to ……, a dispute request; accessing, from ……, one or more feature groups comprising information associated with a user account corresponding to ….., the one or more feature groups including one or more of a user account description feature group, a disputed transactions feature group, …… attribute data feature group, and a user account history information feature group; generating an initial likelihood of approval score by utilizing …… to process one or more feature groups relevant to the initial likelihood of approval score, wherein …… is trained by: encoding the one or more training feature groups using a target encoding to compute a target mean for each feature group, wherein the target mean comprises a weighted sum of a sample target average, wherein a weight of the weighted sum is based on a number of observations for the feature group represented as a sigmoid function utilizing a minimum sampling parameter and a smoothing parameter; adding random noise to the weighted sum of the sample target average to prevent overfitting; prompting …… with one or more training feature groups to generate a predicted likelihood of approval score; generating a training loss value by comparing the predicted likelihood of approval score with a predefined approval label corresponding to the one or more training feature groups; generating ….. by performing model fitting on ….. according to the training loss value by adding a new weak learner to ….. for each successive training iteration and scaling gradients of errors determined by the training loss value to emphasize corrections to under-represented classes; generating a fraud prediction score using …..; generating a rule-based score by using ….. to determine a set of rules by analyzing correlation of the one or more feature groups; generating an adjusted likelihood of approval score based on adjusting the initial likelihood of approval score by: determining a fraud prediction score weight based on determining the fraud prediction score falls within a fraud score range from a plurality of fraud score ranges, wherein a given fraud score range from the plurality of fraud score ranges is associated with a given fraud prediction score weight; determining a rule-based score weight based on determining the rule-based score falls within a rule-based score range from a plurality of rule-based score ranges, wherein a given rule-based score range from the plurality of rule- based score ranges is associated with a given rule-based score weight; determining a transaction factor weight based on a plurality of weighted factors comprising one or more of a transaction amount of the one or more disputed transactions, a merchant associated with the one or more disputed transactions, and a user account status; generating a combined weight by selectively combining the fraud prediction score weight, the rule-based score weight, and the transaction factor weight according to at least one predetermined factor associated with at least one of the fraud prediction score weight, the rule-based score weight, and the transaction factor weight; applying the combined weight to the initial likelihood of approval score to generate the adjusted likelihood of approval score; based on the adjusted likelihood of approval score satisfying a predetermined threshold, generating a notification to ……, indicating that a provisional credit corresponding to the dispute request has been granted.}
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 as managing a dispute request associated with disputed transactions within a user account and providing a provisional credit corresponding to the disputed request has been granted.
Step (2A) Prong 2: The instant claims do not integrate the exception into a practical application because additional elements: 1) “a client device” and “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 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 and provide a provisional credit corresponding to the disputed request has been granted 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.
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/YONGSIK PARK/Examiner, Art Unit 3694
July 30, 2026
/BENNETT M SIGMOND/Supervisory Patent Examiner, Art Unit 3694
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