DETAILED ACTION
Status of Claims
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
This final Office Action is in response to the amendments filed 25 November 2025.
Applicant’s amendments to Claims 1, 2, 4, 7, 9, 10, 11, 13, 14, 15, 18, 19 and 20 have been received and are acknowledged.
Claims 1-20 are pending and have been examined.
Response to Arguments
Applicant's arguments filed 25 November 2025 have been fully considered but they are not persuasive.
With regard to the rejections under 35 USC 101, Applicant argues: (1) That
“…the patentability of the claims are at issue, not the specification….the following statements in the Office Action are irrelevant to the patentability of the claimed subject matter: ….As noted in the rejection below, Applicant's own Specification describes the invention as 'a method of bill presentment' (Specification, [3]) As such, the claims are categorized as methods of organizing human activity (Office Action, pp. 2-3). Bill presentment is categorized in/akin to the abstract idea subject matter grouping of: methods of organizing human activity . . . As such, the claims include an abstract idea. (Office Action, p. 5, 16). … (Applicant’s response 8)
Applicant further asserts that:
“….Claims 1-20 claim a new, useful, man-made tool as a process (claims 1-9), a machine (claims 10-19), and an article of manufacture (claim 20) entirely consistent with the requirements of 35 U.S.C. § 101 …The practical application articulated…. in claims 1-20,… is consumers utilizing a real-time (e.g., instant) messaging app accessible via their computing device to access, review, and pay bills while bypassing time-consuming setup and login access to each website of each biller and the consumer's financial institution (e.g., bank)… the practical application of the tool is accomplished by an interface that adapts/repurposes a real-time (e.g., instant) messaging system to also provide consumers with bill access, review, and payment, thereby bypassing consumer access to each biller and financial institution associated with the consumers typically needed to access and pay bills. The interface can be implemented in a variety of ways in a variety of locations, but, regardless of implementation details, the practical application of the tool conserves computing resources and/or user time….claimed man-made tool implemented with the use of programmed computers is designed to save people time with financial matters like paying bills…” (Applicant’s response 8-9)
Applicant then analogizes the claimed invention to use of other man-made tools such as the lawn-mower, a tractor, a blender, a vehicle, an electric can opener, a communication device “and so on” stating that these also ‘save time.’ (Applicant’s response 9-10) Noting that the Specification “cannot be read into the claims… Instead, it provides context…”, Applicant references the Specification, Fig. 1, (Specification, [2, 13-14, 16, 25 and 30]) and further argues that:
“…the claimed practical application involving an interface that adapts/repurposes a real-time messaging application for bill access, review, and payment processing …the man-made tool provides numerous advantages, such as simplifying automated billing, simplifying automated bill access, review, and payment; reducing online time; reducing consumption of computing resources (e.g., storage and processing); reducing energy use; reducing the number of online account setups; reducing the number of online account names and passwords; reducing the number of account accesses; reducing the number of account access credential authentications; reducing the number of account access denials and authorizations, etc. … the subject matter in claims 1-20 are limited to a new, useful, man-made tool…“ (Applicant’s response 10-13)
Applicant further argues that:
“…The claimed subject matter is new. Novelty required by 35 U.S.C. § 101 is addressed based on the requirements of 35 U.S.C. §§ 102 and 103, as detailed below… The claimed subject matter is useful. The claimed subject matter recites a useful/practical application that improves the technical fields of real-time/instant messaging and automated billing, access, review, and payment. Claims 1-20 are directed to a novel use of a real-time (e.g., instant) messaging system adapted/repurposed by the claimed interface to also provide consumers with bill access, review, and payment, thereby bypassing consumer access to each biller and financial institution associated with the consumers needed to access and pay bills, which can conserve computing resources and/or user time….” (Applicant’s response, 13-15)
Applicant additionally argues that:
“…The claimed subject matter is a man-made machine or machine-implemented process….The claimed invention is an automated solution to a real problem that cannot be solved manually, meaning there is no human equivalent to the claimed invention. The problem and solution arise in the realm of computer networks… to improve automated billing and payment systems and processes and/or real-time (e.g., instant) messaging systems (i.e., computer functionality directed by executable software), claims 1-20 recite limitations that adapt/repurpose a real-time (e.g., instant) messaging system into an automated billing and payment processing system….” (Applicant’s response, 15-16)
Examiner respectfully disagrees. As noted in the rejection below and previously, Applicant’s own Specification describes the invention as “a method of bill presentment” (Specification, [3]). The amended claims also recite “billing.” Applicant’s own arguments characterize the claims as solving a problem in “billing and payment processing” using instant messaging technology. “Billing” and “payment processing” are clearly a commercial or legal interaction. As such, the claims are categorized as methods of organizing human activity [organizing human activity (commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations). The computing device, processor, memory, display and network integrator interface in each step is recited at a high-level of generality (i.e., as generic computer components performing a generic computer function of receiving and transmitting billing data) such that it amounts no more than mere instructions to apply the exception using a generic computer component. Accordingly, these additional elements do not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. At most, this is apply-it (See MPEP 2106.05(f) (2) … Use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) or simply adding a general purpose computer or computer components after the fact to an abstract idea (e.g., a fundamental economic practice or mathematical equation) does not integrate a judicial exception into a practical application or provide significantly more. See Affinity Labs v. DirecTV, 838 F.3d 1253, 1262, 120 USPQ2d 1201, 1207(Fed. Cir. 2016) (cellular telephone); TLI Communications LLC v. AV Auto, LLC, 823 F.3d 607, 613, 118 USPQ2d 1744,1748 (Fed. Cir. 2016) (computer server and telephone unit). Similarly, "claiming the improved speed or efficiency inherent with applying the abstract idea on a computer" does not integrate a judicial exception into a practical application or provide an inventive concept. Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 1367, 115 USPQ2d 1636, 1639 (Fed. Cir. 2015).)
Additionally the recited 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 of using a computing device, processor, memory, display and network integrator interface to perform the receiving, matching and providing 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. (See also MPEP 2106.05 (a) (I) Improvements to computer functionality. Examples that the courts have indicated may not be sufficient to show an improvement to computer functionality: … ii. Accelerating a process of analyzing audit log data when the increased speed comes solely from the capabilities of a general-purpose computer, FairWarning IP, LLC v. Iatric Sys., 839 F.3d 1089, 1095, 120 USPQ2d 1293, 1296(Fed. Cir. 2016); iii. Mere automation of manual processes, such as using a generic computer to process an application for financing a purchase, Credit Acceptance Corp. v. Westlake Services, 859 F.3d 1044, 1055, 123 USPQ2d 1100, 1108-09(Fed. Cir. 2017) or speeding up a loan-application process by enabling borrowers to avoid physically going to or calling each lender and filling out a loan application, LendingTree, LLC v. Zillow, Inc., 656 Fed. App'x 991, 996-97 (Fed. Cir. 2016) (non-precedential);… v. Affixing a barcode to a mail object in order to more reliably identify the sender and speed up mail processing, without any limitations specifying the technical details of the barcode or how it is generated or processed, Secured Mail Solutions, LLC v. Universal Wilde, Inc., 873 F.3d 905, 910-11, 124 USPQ2d 1502, 1505-06 (Fed. Cir. 2017); vi. Instructions to display two sets of information on a computer display in a non-interfering manner, without any limitations specifying how to achieve the desired result, Interval Licensing LLC v. AOL, Inc., 896 F.3d 1335, 1344-45, 127 USPQ2d 1553, 1559-60 (Fed. Cir. 2018))
Therefore, the claim is not patent eligible. Further, as previously stated, matters of novelty are discussed are handled under 35 U.S.C. 102 and 103, not 35 U.S.C. 101. Applicant’s arguments are not persuasive. All dependent claims can be addressed with the same rationale.
Regarding the 35 U.S.C. 102 & 103 rejections, Applicant’s arguments have been fully considered but are not persuasive. Applicant argues Iyer does not teach the newly amended subject matter. Examiner respectfully disagrees as cited in the rejection below. Examiner notes that Iyer clearly discloses a “real-time messaging system” as a component of the bill pay exchange computing system (See at least Iyer, [23]). Therefore, Applicant’s arguments are not persuasive. All dependent claims can be addressed with the same rationale.
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.
Claim 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter.
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.
(1) In the instant case, the claims are directed towards a method, non-transitory computer readable medium, and the system of bill presentment (Specification, [3]) . In the instant case, Claims 1-9 are directed to a process. Claims10-19 are directed to a system. Claims 19-20 are directed to a non-transitory computer readable medium.
(2a) Prong 1: Bill presentment is categorized in/akin to the abstract idea subject matter grouping of: methods of organizing human activity [organizing human activity (commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations)]. As such, the claims include an abstract idea.
The specific limitations of the invention are (a) identified to encompass the abstract idea include:
(Currently Amended) A method comprising:
providinq a network integrator interface that enables access to billinq data of one or more biller systems associated with a consumer via a real-time messaqinq system accessible by a computinq device used by the consumer
…, …authentication or transaction data associated with the consumer using …,;
matching, …, the authentication or transaction data associated with the consumer with the billing data … associated with the consumer; and
providing, …, the billing data to the consumer …
10. (Currently Amended) A computer …, comprising:
…; and
… comprising:
providinq a network integrator interface that enables access to billinq data of one or more biller systems associated with a consumer via a real-time messaqinq system accessible by a computinq device used by the consumer
… authentication or transaction data associated with the consumer via the real-time messaging system accessed by the computing device;
matching the authentication or transaction data associated with the consumer with the billing data …associated with the consumer; and
providing the billing data to the consumer.
20.(Currently Amended) A …… instructions that, when executed by a processor, cause the processor to:
provide a network integrator interface that enables access to billinq data of one or more biller systems associated with a consumer via a real-time messaqinq system accessible by a computinq device used by the consumer
… authentication or transaction data associated with the consumer via the real-time messaging …;
match the authentication or transaction data associated with the consumer with the billing data associated with the consumer; and
provide the billing data to the consumer ….
As stated above, this abstract idea falls into the (b) subject matter grouping of: methods of organizing human activity .
Prong 2: When considered individually and in combination, the instant claims are do not integrate the exception into a practical application because the steps of providing… matching… providing ….- 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. the abstract idea).
The instant recited claims including additional elements (i.e. providing.. [displaying]….receiving…, providing [ displaying]…) 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 recite: “apply it” (or an equivalent) or merely include instructions to implement an abstract idea on a computer or merely uses a computer as a tool to perform an abstract idea or merely add insignificant extra-solution activity to the judicial exception (See MPEP 2106.05 (f) and (g)) Accordingly, these additional elements do not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea.
(2b) In the instant case, Claims 1-9 are directed to a process. Claims10-19 are directed to a system. Claims 19-20 are directed to a non-transitory computer readable medium.
Additionally, the claims (independent and dependent) do not include additional elements that individually or in combination are sufficient to amount to significantly more than the judicial exception of abstract idea (i.e. provide an inventive concept). As discussed above with respect to integration of the abstract idea into a practical application, the additional element(s) of: (computing device, processor, memory, display and network integrator interface ) merely uses a computer as a tool to perform an abstract idea or merely add insignificant extra-solution activity to the judicial exception or merely uses generic computing elements to perform well known, routine, and conventional functions. (See MPEP 2106.05 (d), (f) and (g)) (SPECIFICATION, [18-19] Fig.1; [20- 23] electronic device 110 (i.e., computing device may include any mobile computer device and/or phone or other computing device…a laptop computer, a hand-held computer, phone, or tablet, etc. In various implementations, the electronic device may include one or more processors, memory, and a display for a consumer 102
to interact with the messaging system 120 and the network integrator interface…messaging system )
The dependent claims have also been examined and do not correct the deficiencies of the independent claims.
It is noted that claims 2-9 and 11-19 introduce the additional element of further steps: providing…(Claims 2, 11 ); providing… ( Claims 3, 12); providing… retrieving… transmitting… (Claims 8 , 17 ); receiving… displaying.. (Claims 9, 18) and wherein clauses further defining elements: network integrator interface, (Claims 4, 5, 7, 13, 14, 15); …data… ( Claims 6, 16 )… computer system… coupled with… biller systems (Claim 19) ; These elements are not a practical application of the judicial exception because the limitations merely recite: “apply it” (or an equivalent) or merely include instructions to implement an abstract idea on a computer or merely uses a computer as a tool to perform an abstract idea or merely add insignificant extra-solution activity to the judicial exception (See MPEP 2106.05 (f) and (g)) Further these limitations taken alone or in combination with the abstract do not amount to significantly more than the abstract idea alone because these elements amount to mere use of a computer as a tool to perform an abstract idea or merely add insignificant extra-solution activity to the judicial exception or merely uses generic computing elements to perform well known, routine, and conventional functions. See MPEP 2106.05 (d), (f) and (g)) (SPECIFICATION, [18-19] Fig.1; [20- 23] electronic device 110 (i.e., computing device may include any mobile computer device and/or phone or other computing device…a laptop computer, a hand-held computer, phone, or tablet, etc. In various implementations, the electronic device may include one or more processors, memory, and a display for a consumer 102
to interact with the messaging system 120 and the network integrator interface…messaging system )
Therefore, claims 1-20 are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter.
Claim Rejections - 35 USC § 102
The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
A person shall be entitled to a patent unless –
(a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention.
Claims 1-4, 6-13, and 15-20 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Iyer et al. (US 2021/0133705).
Regarding claim 1, Iyer teaches A method comprising:
providinq a network integrator interface that enables access to billinq data of one or more biller systems associated with a consumer via a real-time messaqinq system accessible by a computinq device used by the consumer( See at least Iyer, [23] bill payment computer system… real-time messaging system… [41-43] retrieves bill ….includes bill data… prompts user to select their preferred form of payment; [48] BSP… manage billing services for biller…[65] bill for presentment to user… biller… transmits … bill data… [77-78] biller… response…forwards the response to CFI to complete the user-biller link… link validates… user’s account information to biller… enables biller to send messages to user… once user… is authenticated by biller…bill data )
receiving, by the network integrator interface, authentication or transaction data associated with the consumer (Paragraph [0076] teaches a BPX (bill pay exchange) system (reads on network integrator interface) and a request including security answers to security questions (reads on authentication data), a bill reference number, a user identifier (e.g. account number), payment credentials (reads on transaction data), etc.), via the real-time messaging system accessed by the computing device (Paragraph [23] bill payment computer system… real-time messaging system… [0076] teaches a BPX (bill pay exchange) system (reads on network integrator interface) and a request including security answers to security questions (reads on authentication data), a bill reference number, a user identifier (e.g. account number), payment credentials (reads on transaction data), etc.; Abstract teaches the system utilizes real-time payment messaging including initiation messages and confirmation messages; Paragraphs [0041]-[0042] teaches a bill system accessible to the user);
matching, by the network integrator interface, the authentication or transaction data associated with the consumer with the billing data associated with the consumer (Paragraphs [0076]-[0079]; Paragraph [0008], [77] biller… response…forwards the response to CFI to complete the user-biller link… link validates… user’s account information to biller… enables biller to send messages to user… once user… is authenticated by biller…]); and
providing, by the network integrator interface, the billing data to the consumer via the real-time messaging system (Paragraphs [0076]-[0079]; Paragraph [0008]; [0023]).
Regarding claim 2, Iyer teaches The method of claim 1. Iyer further teaches:
providing, by the network integrator interface, payment transaction authorization data to the real-time messaging system or the one or more billing systems, wherein the payment transaction authorization data comprises data associated with payment authorization or a scheduled date for payment (Paragraphs [0076]-[0079]).
Regarding claim 3, Iyer teaches The method of claim 1. Iyer further teaches
in response to payment transaction or scheduling confirmation data received, providing, by the network integrator interface, confirmation of payment or scheduled payment to the consumer (Paragraphs [0070], [0082] and [0083].
Regarding claim 4, Iyer teaches The method of claim 1. Iyer further teaches wherein the network integrator interface comprises a messaging interface integrated within the real-time messaging application (Paragraph [23] bill payment computer system… real-time messaging system… [0076] teaches the BPX computing system 102 containing a message processor 104; Paragraph [0082]).
Regarding claim 6, Iyer teaches The method of claim 1. Iyer further teaches wherein the authentication or transaction data comprises card number data, expiry date data, name data, account number data, bill transaction data, consumer personal data, or combinations thereof (Paragraph [0076] teaches a BPX (bill pay exchange) system (reads on network integrator interface) and a request including security answers to security questions (reads on authentication data), a bill reference number (reads on bill transaction data), a user identifier (e.g. account number), payment credentials (reads on transaction data), etc.).
Regarding claim 7, Iyer teaches The method of claim 1. Iyer further teaches wherein the network integrator interface is accessed from one or more first servers or networks, and wherein the real-time messaging system is accessed from one or more second servers or networks (Paragraph [23] bill payment computer system… real-time messaging system… [0091] teaches using multiple server systems).
Regarding claim 8, Iyer teaches The method of claim 1. Iyer further teaches wherein matching the authentication or transaction data of the consumer with the billing data comprises:
providing, by one or more application programming interfaces transmitted by a network aggregator system, the authentication or transaction data to the one or more biller systems (Paragraphs [0076]-[0079]);
retrieving, by the one or more application programming interfaces from the one or more biller systems or the network aggregator system, the billing data corresponding to the consumer (Paragraphs [0076]-[0079]); and
transmitting the billing data to the network integrator interface (Paragraphs [0076]-[0079]).
Regarding claim 9, Iyer teaches The method of claim 1. Iyer further teaches wherein providing the billing data to the consumer comprises:
Receiving, at the network integrator interface, the billing data from a network aggregator system (Paragraphs [0076]-[0079]), and
displaying, by the network integrator interface using the real-time messaging system accessed on the computing device, the billing data retrieved at the computing device (Paragraphs[23] bill payment computer system… real-time messaging system… [0076]-[0079]).
Regarding Claims 10-13 & 15-19, all limitations as recited have been analyzed and rejected with respect to claims 1-4 & 6-9. Claims 10-13 & 15-19 pertain to a computer system having associated instructions corresponding to the method of claims 1-4 & 6-9. Claims 10-13 & 15-19 do not teach or define any new limitations beyond claims 1-4 & 6-9, therefore they are rejected under the same rationale.
Regarding Claim 20, all limitations as recited have been analyzed and rejected with respect to claims 1. Claim 20 pertains to a non-transitory computer-readable storage device having associated instructions corresponding to the method of claims 1. Claim 20 does not teach or define any new limitations beyond claim 1, therefore they are rejected under the same rationale.
Claim Rejections - 35 USC § 103
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
1. Determining the scope and contents of the prior art.
2. Ascertaining the differences between the prior art and the claims at issue.
3. Resolving the level of ordinary skill in the pertinent art.
4. Considering objective evidence present in the application indicating obviousness or nonobviousness.
Claims 5 & 14 are rejected under 35 U.S.C. 103 as being unpatentable over Iyer et al. (US 2021/0133705) in view of Jafar Ali et al. (US 2019/0132264).
Regarding claim 5, Iyer teaches The method of claim 4. Iyer does not teach, however, wherein the network integrator interface is a natural language interface (Paragraphs [0001]-[0004] teaches a chatbot) configured for at least one of consumer authentication and bill presentment Paragraphs [0036]-[0037] teaches a chatbot utilized in billing).
It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify the system taught by Iyer to include the chatbots as taught by Jafar to improve efficiency, accessibility and convenience in bill payment systems.
Regarding claim 14, all limitations as recited have been analyzed and rejected with respect to claim 5. Claim 14 pertains to a computer system having associated instructions corresponding to the method of claim 5. Claim 14 does not teach or define any new limitations beyond claim 5, therefore they are rejected under the same rationale.
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). 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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/ASHA PUTTAIA H/Primary Examiner, Art Unit 3691