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
The following is Office Action on the merits in response to the communication received on 1/27/26.
Claim status:
Amended claims: 1, 12, 14 and 21
Canceled claims: none
Added New claims: None
Pending claims: 1-2 and 4-21
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 1-2 and 4-21 are rejected under 35 U.S.C. § 101 because the claimed invention is not directed to statutory subject matter. Specifically, the invention of claims 1-2 and 4-21 is directed to an abstract idea without significantly more.
Independent claims 1, and 12 are directed to a method (claims 1), and a processing server computer (claim 12). Therefore on its face, each of claims 1, and 12 is directed to a statutory category of invention under Step 1 of the 2019 PEG. However each of claims 1, and 12 is also directed to an abstract idea without significantly more, under Step 2A (Prong One and Prong Two) and Step 2B of the 2019 PEG, which is a judicial exception to 35 U.S.C. 101, as detailed below. Using the language of independent claim 1 to illustrate the claim recites the limitations of, (i) prior to initiation of a transaction with an entity, receiving, an account update message from an issuer of an account, the account update message including updated information associated with the account, wherein the account update message identifies one or more entities that are authorized to obtain the updated information; (ii) storing, the updated information associated with the account, and the one or more entities that are authorized to obtain the updated information; (iii) storing including: associating the account with a flag, wherein the flag signals presence of the updated information for the account, (iv) updating in real time upon receipt of the account update message; (v) upon the initiation of the transaction with the entity: receiving an authorization request message from the entity for the transaction using the account, the authorization request message including information associated with the account; (vi) querying, (vii) determining, presence of the updated information for the account based on the flag during transaction processing; (viii) discarding, the information associated with the account provided in the authorization request message as outdated account information, (ix) retrieving, the updated information, (x) generating, an authorization response message including the updated information instead of the outdated account information, a first indicator indicating that the account has been modified, and a second indicator indicating whether the transaction is approved or denied based on the updated information; (xi) completing the transaction processing by: prior to sending the authorization response message including the updated information to the entity, determining, that the entity is among the one or more entities identified in the account update message as being authorized to receive the updated information; and (xii) reducing a message traffic, (xiii) transmitting, to the entity after confirming that the entity is authorized to receive the updated information, the authorization response message as a single message including the updated information and the second indicator indicating whether the transaction is approved or denied based on the updated information, without receiving a request from the entity for the updated information under the broadest reasonable interpretation covers methods of organizing human activity: commercial or legal interactions - legal obligations, but for the recitation of generic computers but for the recitation of generic computers and generic computer components. (Independent claims 12 recites similar limitations and the analysis is the same).
That is, other than reciting a processing server computer, an account update message, an issuer, a database nothing in the claim precludes the steps from being directed to methods of organizing human activity specifically commercial or legal interactions, but for the recitation of generic computers. If a claim limitation under its BRI, covers methods of organizing human activity but for the recitation of generic computer components, then the limitations fall within the “methods of organizing human activity” grouping of abstract ideas. Therefore, claim 1 recites an abstract idea under Step 2A Prong One of the Revised Patent Subject Matter Eligibility Guidance 84 Fed.Reg 50 (“2019 PEG”).
This “methods of organizing human activity” is not integrated into a practical application under Step 2A prong Two of the 2019 PEG. In particular claim 1 recites the following additional elements of, a processing server computer, an account update message, an issuer, a database. This judicial exception is not integrated into a practical application. In particular, the claim only recites the additional elements – a processing server computer, an account update message, an issuer, a database.
The processing server computer, account update message, issuer, database are recited at a high-level or generality (i.e. as a generic computer performing generic computer functions) such that, they amount to no more than instructions to apply the abstract idea with a general computer (see MPEP 2106.05(h). 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. The claims are directed to an abstract idea.
Under Step 2B of the 2019 PEG independent claim 1 does not include additional elements that are sufficient to amount to significantly more than the abstract idea. The claim(s) 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 of using a processing server computer, an account update message, an issuer, a database, prior to initiation of a transaction with an entity, receiving, an account update message from an issuer of an account, the account update message including updated information associated with the account, wherein the account update message identifies one or more entities that are authorized to obtain the updated information; storing, the updated information associated with the account, and the one or more entities that are authorized to obtain the updated information; storing including: associating the account with a flag, wherein the flag signals presence of the updated information for the account, updating in real time upon receipt of the account update message; upon the initiation of the transaction with the entity: receiving an authorization request message from the entity for the transaction using the account, the authorization request message including information associated with the account; querying, determining, presence of the updated information for the account based on the flag during transaction processing; discarding, the information associated with the account provided in the authorization request message as outdated account information, retrieving, the updated information, generating, an authorization response message including the updated information instead of the outdated account information, a first indicator indicating that the account has been modified, and a second indicator indicating whether the transaction is approved or denied based on the updated information; completing the transaction processing by: prior to sending the authorization response message including the updated information to the entity, determining, that the entity is among the one or more entities identified in the account update message as being authorized to receive the updated information; and reducing a message traffic, transmitting, to the entity after confirming that the entity is authorized to receive the updated information, the authorization response message as a single message including the updated information and the second indicator indicating whether the transaction is approved or denied based on the updated information, without receiving a request from the entity for the updated information, amount to than instructions to apply the abstract idea with a general computer. The claims are not patent eligible.
The dependent claims have been given the full two part analysis including analyzing the additional limitations individually. The Dependent claim(s) when analyzed individually are also held to be patent ineligible under 35 U.S.C. 101 because for the same reasoning as above and the additional recited limitation(s) fail to establish that the claim(s) are not directed to an abstract idea. The additional limitations of the dependent claim(s) when considered individually do not amount to significantly more than the abstract idea. Claims 2, 4-11 and 13-21 merely further explains the abstract idea.
When viewed individually the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea. Accordingly claims 1-2 and 4-21 are ineligible.
Response to Arguments
Applicant's arguments filed 1/27/26 have been fully considered but they are not persuasive.
The Applicant states “The claims, as now amended, are not directed to a mere abstract idea or method of organizing human activity, but rather to a specific, technology-rooted solution to a problem that arises uniquely in the context of electronic transaction processing systems” (page 9). The Examiner disagrees with the sentence because the claims are an improvement of the abstract idea only. It is a business solution to a business problem of updating account information. The applicant has not shown how the claims improve a computer or other technology, invoke a particular machine, transform matter, or provide more than a general link between the abstraction and the technology, MPEP 2106.05(a)-(c) & (e). The Examiner disagrees that “The claims therefore are integrated into a practical application under the controlling USPTO guidance.” (page 12). The claims do not provide an improvement over prior systems and only add details (e.g., discarding old information when updating account information) to the abstract idea, they do not address a problem particular to the Internet and merely applies the abstract idea on a general computer. The amended claims make the abstract idea more specific, and updating account information is not an unconventional activity. The invention uses conventional components arranged in a conventional manner to perform a conventional process. Applicant’s remarks about why these limitations provide a practical application fail to surface any technical improvement identified in the spec, therefore this is not an inventive concept and significantly more.
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.
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/M.H./Examiner, Art Unit 3694
/BENNETT M SIGMOND/Supervisory Patent Examiner, Art Unit 3694