DETAILED ACTION
Status of Application
This action is a Non-Final Rejection. This action is in response to the request for continued examination filed on February 16, 2026.
Claims 1-11, 19, and 20 have been canceled.
Claims 12 has been amended.
Claims 12-18 are rejected in this Office action.
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
Response to Applicant’s Response to 105 Requirement for Information
On July 30, 2024, a Requirement for Information under 37 CFR 1.105 was mailed because the support in the Specification for the amendments made to claim 12 was not apparent based on a review of paragraphs 12 and 13 and a search of the Specification. Applicant has responded on September 9, 2024 by pointing to specific statements in the Specification and providing some limited explanations. Applicant’s response is being accepted as providing sufficient support for these limitations. The limitations are interpreted in light of Applicant’s response.
Information Disclosure Statement
The information disclosure statement (IDS) submitted on February 16, 2026 has been considered by the examiner.
Response to Arguments
Regarding the rejection under 35 U.S.C. 101, Applicant argues that “[t]he Director’s analysis and the technological improvements present in Desjardins are directly parallel to the instant case.” Remarks at 6. Applicant alleges that the instant claims solve a concrete technological problem similar to Desjardins. Id. In Desjardins, the problem being addressed was catastrophic forgetting in continual learning systems. In contrast, the problem of delays in funds transfers is a business problem, i.e., an abstract idea.
Applicant next asserts that the instant claims reduce storage requirements and system complexity similar to Desjardins. Remarks at 7. However, the reduced storage requirements and reduced complexity were the result of the improved machine learning model. In contrast, eliminating the need for FIs to maintain separate cryptocurrency holdings and infrastructure is a business benefit and not an improvement to technology. Any reduction in storage requirements is due to implementing the abstract idea and not, for example, to improving a machine learning model.
Applicant next asserts that the instant claims provide a “sequential architecture [that] preserves transaction integrity and blockchain immutability (the ‘first task’) while enabling near-instantaneous user-facing processing (the ‘second task’)—precisely the type of sequential operation improvement found in Desjardins. Remarks at 8. However, the first and second operations described on pages 7 and 8 of the Remarks are abstract ideas and not sequential operations of a machine learning model.
Applicant further argues that “[t]he Examiner dismisses the dual-step processing mechanism, pooled custodial wallet architecture, and blockchain-integrated ledger system as merely ‘using existing technology to perform a transaction’ and ‘known components.’” Remarks at 8. Applicant asserts that the amended claims “recite a specific architectural solution: (1) crediting funds via ledger updates before BC confirmation, (2) initiating BC operations asynchronously, (3) processing value transfers near-instantaneously through pooled wallet funding, and (4) properly reflecting transfers upon BC confirmation.” Id. at 8-9. However, Applicant is describing an abstract idea. Each step is part of the abstract idea even if it is being performed by a computer.
Applicant further argues that asserting that the claimed improvements are to a business process and not to technology contradicts Desjardins. Remarks at 9. However, Desjardins is distinct from the instant application. For example, the instant application does not recite features of training a machine learning model.
Applicant further argues that the claimed dual-step processing mechanism improves blockchain transaction technology. Remarks at 10. However, the improvement itself is not to blockchain technology but instead to the transaction.
Applicant further argues that the claims provide a technological improvement by providing asynchronous crediting architecture, dual-step processing architecture, integrated multi-service architecture, real-time verification with blockchain logging, and automated compliance through blockchain functionalities. Remarks at 10-12. However, the described benefits of these features are benefits to the transaction and not improvements to technology.
Applicant further argues that the amended crediting element distinguishes the claims from conventional blockchain implementations. Remarks at 12. However, Applicant is describing alleged differences between existing blockchain transactions and Applicant’s invention.
Applicant further argues that the abstract idea is not merely being linked to a blockchain environment. Remarks at 13. Applicant asserts that this contradicts Desjardins, which did not characterize “the claims as ‘merely linking the abstract idea of learning to the technological environment of neural networks.’” Id. However, in Desjardins there was an improved way of training a machine learning model. A similar improvement is not found in the instant claims.
Applicant further argues that the claims are eligible per the USPTO’s 2024 guidance on AI and emerging technologies. Remarks at 15. However, the examples in that guidance are not similar to the instant claims.
Applicant further provides policy considerations from Desjardins and asserts that the reasoning from Desjardins applies to blockchain and financial technology innovations. Remarks at 14-15. However, the memorandum issued on December 5, 2025 regarding “Advance notice of change to the MPEP in light of Ex Parte Desjardins” emphasizes that Desjardins is mainly applicable to machine learning or artificial intelligence. See December 5, 2025 memo, page 1 (“As such, Examiners are expected to consider existing precedent like Enfish, as discussed in MPEP § 2106, in addition to these updates when assessing eligibility under 35 U.S.C. § 101, particularly when evaluating claims related to machine learning or artificial intelligence.”). Additionally, Desjardins discusses an improvement to how the machine learning model is trained and not to how the machine learning model is used. The instant claims are more comparable to the latter.
As such, the rejection under 35 U.S.C. 101 is maintained.
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 12-18 are rejected under 35 U.S.C. § 101 as being directed to non-statutory subject matter because the claimed invention is directed to an abstract idea without significantly more.
Step 1: Does the Claim Fall within a Statutory Category? (see MPEP 2106.03)
Yes, with respect to claims 12-18, which recite a method and, therefore, are directed to the statutory class of process.
Step 2A, Prong One: Is a Judicial Exception Recited? (see MPEP 2106.04(a))
The following claims identify the limitations that recite additional elements in bold and abstract idea in regular text:
12. A method, comprising:
maintaining a pooled custodial Financial Institution (FI) wallet comprising United States Dollar (USD) coins representing government- backed funds deposited by a FI into the pooled custodial FI wallet, wherein the USD coins are managed through blockchain technology to ensure real-time verification and secure transaction logging;
managing fund inflows and fund outflows of the pooled custodial FI wallet through a first cloud-based ledger on behalf of the FI and first customers of the FI;
maintaining a pooled custodial customer wallet comprising cryptocurrency for particular first customers of Centralized Financial (CeFi) services associated with the Fl, wherein the particular first customers are customers of both the FI and the CeFi services;
managing cryptocurrency inflows and cryptocurrency outflows of the pooled custodial customer wallet through a second cloud-based ledger and via customer wallets for the particular first customers;
providing Decentralized Financial (DeFi) operations to the customers through a FI application (app) associated with the FI by interacting with DeFi services using Blockchain (BC) application programming interfaces (APIs), the customer wallets, the pooled custodial customer wallet, the pooled custodial FI wallet, the first cloud-based ledger, and the second cloud-based ledger, wherein the DeFi operations include real-time transaction settlements and automated compliance checks using blockchain functionalities;
crediting funds from the pooled custodial customer wallet to a corresponding customer custodial wallet by updating the second cloud-based ledger while initiating a BC operation for transferring cryptocurrency into the pooled custodial customer wallet, wherein the funds are credited before the BC operation confirms completion of the transfer;
processing value transfers near instantaneously by funding the value transfers through the pooled custodial customer wallet and by updating the second cloud-based ledger to indicate that funds in the pooled custodial customer wallet belong to a corresponding customer custodial wallet; and
upon confirmation from the BC operations of transfer completion, performing and properly reflecting the value transfers within the pooled custodial customer wallet; and
integrating FI services of the FI, the CeFi services, and the DeFi services for the particular first customers through the FI app using the pooled custodial customer wallet, the pooled custodial FI wallet, the first cloud-based ledger, the second cloud-based ledger, the BC APIs, and the blockchain functionalities over a BC without the FI holding any cryptocurrency and maintaining governmental compliance on behalf of the FI with respect to cryptocurrency.
13. The method of claim 12, wherein maintaining the pooled custodial FI wallet further comprises, receiving the government-backed funds in a financial account, initiating a BC operation to purchase an equivalent amount of the USD coins, and receiving the USD coins in the pooled custodial FI wallet when the BC operation confirms completion.
14. The method of claim 13, wherein managing the cryptocurrency inflows and the cryptocurrency outflows further includes maintaining account identifiers and balance totals within the first cloud-based ledger for each account of each particular first customer with each CeFi service.
15. The method of claim 14 further comprising, updating a given customer wallet balance total within the second cloud-based ledger when a given DeFi service adds or removes cryptocurrency to the pooled custodial customer wallet indicating that a given customer corresponding to the given customer wallet balance experienced a gain or a loss with the given DeFi service.
16. The method of claim 14 further comprising, notifying a given CeFi service with a given account identifier when a given customer transfers a first amount of funds out of the given CeFi service for use with a given DeFi service and updating the first cloud-based ledger.
17. The method of claim 16, wherein notifying further includes transferring the USD coins corresponding to the first amount of funds from the pooled custodial FI wallet into the pooled custodial customer wallet and updating the second cloud-based ledger to reflect an addition of the first amount of USD coins into a corresponding customer wallet for the given customer.
18. The method of claim 17, wherein transferring further includes using the pooled custodial customer wallet and the BC APIs to interact with a given DeFi service based on instructions received from the given customer within the FI app and updating the cloud-based second ledger showing a result of the instructions in the corresponding customer wallet.
Yes. But for the recited additional elements as shown above in bold, the remaining limitations of the claims recite certain methods of organizing human activity. The claims are directed to a method for managing the transfer of value/currency. This type of method of organizing human activity is similar to a fundamental economic practice such as a payment, or a commercial interaction such as legal obligations, sales activities or behaviors, or business relations. Thus, the claims recite an abstract idea.
Step 2A, Prong Two: Is the Abstract Idea Integrated into a Practical Application? (see MPEP 2106.04(d))
No. The claims as a whole merely use known computer related technology as a tool to perform the abstract idea. The computing components (i.e., additional elements that are in bold above) are recited at a high level of generality and are merely invoked as a tool to perform the abstract idea. Simply implementing the abstract idea using generic computers or devices or software is not a practical application of the abstract idea. Moreover, the abstract idea is merely being linked to a particular technological environment, i.e., blockchain. Employing well known technology with a blockchain environment to execute the abstract idea, even when limiting the use of the abstract idea to this environment, does not integrate the exception into a practical application or add significantly more. Additionally, there is no improvement to the functioning of a computer or technology. Therefore, the abstract idea is not integrated into a practical application.
Step 2B: Does the Claim Provide an Inventive Concept? (see MPEP 2106.05)
No. As discussed with respect to Step 2A, Prong 2, the additional elements in the claims, both individually and in combination, amount to no more than tools to perform the abstract idea. Merely performing the abstract idea using a computer cannot provide an inventive concept. Therefore, the claims do not provide an inventive concept.
As such, the claims are not patent eligible.
Relevant Prior Art
Hamasni et al., U.S. Patent Application Publication Number 2019/0303922 A1. This reference teaches a system and method for cryptographic transactions. See paragraph 0061.
Zhou et al., U.S. Patent Application Publication Number 2021/0326844 A1. This reference teaches systems and methods for facilitating fund transfers using blockchain networks.
Gaur et al., U.S. Patent Application Publication Number 2021/0350343 A1. This reference teaches blockchain compliance checks.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ELIZABETH H ROSEN whose telephone number is (571) 270-1850 and email address is elizabeth.rosen@uspto.gov. The examiner can normally be reached Monday - Friday, 10 AM ET - 7 PM ET.
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/ELIZABETH H ROSEN/Primary Examiner, 3693
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