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 .
Summary
This Final Office Action in response to the communication received on November 21, 2025.
Claims 1, 8, and 15 have been amended.
Claims 3, 10, and 17 have been cancelled
Claims 1-2, 4-9, 11-16, and 18-20 are pending.
The effective filing date of the claimed invention is April 28, 2022.
Response to Amendment
Amendments to Claims 1, 8, and 15 are acknowledged.
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, 4-9, 11-16, and 18-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed a judicial exception (i.e., an abstract idea) without significantly more.
Step 1 – Statutory Categories
As indicated in the preamble of the claim, the examiner finds the claim is directed to a process, machine, manufacture, or composition of matter.(Claims 1-7 are processes and Claims 8-20 are machines). Accordingly, step 1 is satisfied.
Step 2A – Prong 1: was there a Judicial Exception Recited
Claim 1 (and similarly Claims 8 and 15) recites the following abstract concepts that are found to include “abstract idea.” Any additional elements will be analyzed under Step 2A-Prong 2 and Step 2B:
A method for personalized customer dunning, performed by a centralized platform including at least one processor, wherein the method comprises:
monitoring a status of a plurality of invoices (See MPEP 2106.04(a)(2)(II)(A) - Bilski v. Kappos, 561 U.S. 593, 609, 95 USPQ2d 1001, 1009 (2010). The fundamental economic practice at issue was hedging or protecting against risk. The applicant in Bilski claimed “a series of steps instructing how to hedge risk,” i.e., how to protect against risk. 561 U.S. at 599, 95 USPQ2d at 1005. The method allowed energy suppliers and consumers to minimize the risks resulting from fluctuations in market demand for energy. The Supreme Court determined that hedging is “fundamental economic practice” and therefore is an “unpatentable abstract idea.” 561 U.S. at 611-12, 95 USPQ2d at 1010. and mitigating settlement risk, Alice Corp. v. CLS Bank, 573 U.S. 208, 218, 110 USPQ2d 1976, 1982 (2014), See MPEP 2106.04(a)(2)(III)(C) Claims can recite a mental process even if they are claimed as being performed on a computer. The Supreme Court recognized this in Benson, determining that a mathematical algorithm for converting binary coded decimal to pure binary within a computer’s shift register was an abstract idea. The Court concluded that the algorithm could be performed purely mentally even though the claimed procedures “can be carried out in existing computers long in use, no new machinery being necessary.” 409 U.S at 67, 175 USPQ at 675. See also Mortgage Grader, 811 F.3d at 1324, 117 USPQ2d at 1699 (concluding that concept of “anonymous loan shopping” recited in a computer system claim is an abstract idea because it could be “performed by humans without a computer”));
obtaining a customer score for a customer corresponding to an invoice of the plurality of invoices, based on the status of the invoice, wherein the customer score is previously determined based on customer data, and wherein the customer data comprises at least one of average revenue per user, customer type, tenure, or fraud score (See MPEP 2106.04(a)(2)(II)(A) - Bilski v. Kappos, 561 U.S. 593, 609, 95 USPQ2d 1001, 1009 (2010). The fundamental economic practice at issue was hedging or protecting against risk. The applicant in Bilski claimed “a series of steps instructing how to hedge risk,” i.e., how to protect against risk. 561 U.S. at 599, 95 USPQ2d at 1005. The method allowed energy suppliers and consumers to minimize the risks resulting from fluctuations in market demand for energy. The Supreme Court determined that hedging is “fundamental economic practice” and therefore is an “unpatentable abstract idea.” 561 U.S. at 611-12, 95 USPQ2d at 1010. and mitigating settlement risk, Alice Corp. v. CLS Bank, 573 U.S. 208, 218, 110 USPQ2d 1976, 1982 (2014));
receiving customer-specific data via a real time data ingestion pipeline from one or more customer data sources (See MPEP 2106.04(a)(2)(II)(A) - Bilski v. Kappos, 561 U.S. 593, 609, 95 USPQ2d 1001, 1009 (2010). The fundamental economic practice at issue was hedging or protecting against risk. The applicant in Bilski claimed “a series of steps instructing how to hedge risk,” i.e., how to protect against risk. 561 U.S. at 599, 95 USPQ2d at 1005. The method allowed energy suppliers and consumers to minimize the risks resulting from fluctuations in market demand for energy. The Supreme Court determined that hedging is “fundamental economic practice” and therefore is an “unpatentable abstract idea.” 561 U.S. at 611-12, 95 USPQ2d at 1010. and mitigating settlement risk, Alice Corp. v. CLS Bank, 573 U.S. 208, 218, 110 USPQ2d 1976, 1982 (2014), See MPEP 2106.04(a)(2)(III)(C) Claims can recite a mental process even if they are claimed as being performed on a computer. The Supreme Court recognized this in Benson, determining that a mathematical algorithm for converting binary coded decimal to pure binary within a computer’s shift register was an abstract idea. The Court concluded that the algorithm could be performed purely mentally even though the claimed procedures “can be carried out in existing computers long in use, no new machinery being necessary.” 409 U.S at 67, 175 USPQ at 675. See also Mortgage Grader, 811 F.3d at 1324, 117 USPQ2d at 1699 (concluding that concept of “anonymous loan shopping” recited in a computer system claim is an abstract idea because it could be “performed by humans without a computer”));
generating, in real time, a dunning score for the customer using a real time dunning decision model, wherein one or more parameters of the real time dunning decision model are dynamically configurable during runtime based on the received customer-specific data and the customer score (See MPEP 2106.04(a)(2)(II)(A) - Bilski v. Kappos, 561 U.S. 593, 609, 95 USPQ2d 1001, 1009 (2010). The fundamental economic practice at issue was hedging or protecting against risk. The applicant in Bilski claimed “a series of steps instructing how to hedge risk,” i.e., how to protect against risk. 561 U.S. at 599, 95 USPQ2d at 1005. The method allowed energy suppliers and consumers to minimize the risks resulting from fluctuations in market demand for energy. The Supreme Court determined that hedging is “fundamental economic practice” and therefore is an “unpatentable abstract idea.” 561 U.S. at 611-12, 95 USPQ2d at 1010. and mitigating settlement risk, Alice Corp. v. CLS Bank, 573 U.S. 208, 218, 110 USPQ2d 1976, 1982 (2014));
determining, in real time, a dunning action based on the dunning score (See MPEP 2106.04(a)(2)(II)(A) - Bilski v. Kappos, 561 U.S. 593, 609, 95 USPQ2d 1001, 1009 (2010). The fundamental economic practice at issue was hedging or protecting against risk. The applicant in Bilski claimed “a series of steps instructing how to hedge risk,” i.e., how to protect against risk. 561 U.S. at 599, 95 USPQ2d at 1005. The method allowed energy suppliers and consumers to minimize the risks resulting from fluctuations in market demand for energy. The Supreme Court determined that hedging is “fundamental economic practice” and therefore is an “unpatentable abstract idea.” 561 U.S. at 611-12, 95 USPQ2d at 1010. and mitigating settlement risk, Alice Corp. v. CLS Bank, 573 U.S. 208, 218, 110 USPQ2d 1976, 1982 (2014)),
wherein the dunning action comprises one of a suspension of a service, an cancellation of the service, or a removal from a service barring list (See MPEP 2106.04(a)(2)(II)(A) - Bilski v. Kappos, 561 U.S. 593, 609, 95 USPQ2d 1001, 1009 (2010). The fundamental economic practice at issue was hedging or protecting against risk. The applicant in Bilski claimed “a series of steps instructing how to hedge risk,” i.e., how to protect against risk. 561 U.S. at 599, 95 USPQ2d at 1005. The method allowed energy suppliers and consumers to minimize the risks resulting from fluctuations in market demand for energy. The Supreme Court determined that hedging is “fundamental economic practice” and therefore is an “unpatentable abstract idea.” 561 U.S. at 611-12, 95 USPQ2d at 1010. and mitigating settlement risk, Alice Corp. v. CLS Bank, 573 U.S. 208, 218, 110 USPQ2d 1976, 1982 (2014));
performing, in real time, the dunning action (See MPEP 2106.04(a)(2)(II)(A) - Bilski v. Kappos, 561 U.S. 593, 609, 95 USPQ2d 1001, 1009 (2010). The fundamental economic practice at issue was hedging or protecting against risk. The applicant in Bilski claimed “a series of steps instructing how to hedge risk,” i.e., how to protect against risk. 561 U.S. at 599, 95 USPQ2d at 1005. The method allowed energy suppliers and consumers to minimize the risks resulting from fluctuations in market demand for energy. The Supreme Court determined that hedging is “fundamental economic practice” and therefore is an “unpatentable abstract idea.” 561 U.S. at 611-12, 95 USPQ2d at 1010. and mitigating settlement risk, Alice Corp. v. CLS Bank, 573 U.S. 208, 218, 110 USPQ2d 1976, 1982 (2014)); and
notifying the customer of the performed dunning action via a first engagement channel (See MPEP 2106.04(a)(2)(II)(A) - Bilski v. Kappos, 561 U.S. 593, 609, 95 USPQ2d 1001, 1009 (2010). The fundamental economic practice at issue was hedging or protecting against risk. The applicant in Bilski claimed “a series of steps instructing how to hedge risk,” i.e., how to protect against risk. 561 U.S. at 599, 95 USPQ2d at 1005. The method allowed energy suppliers and consumers to minimize the risks resulting from fluctuations in market demand for energy. The Supreme Court determined that hedging is “fundamental economic practice” and therefore is an “unpatentable abstract idea.” 561 U.S. at 611-12, 95 USPQ2d at 1010. and mitigating settlement risk, Alice Corp. v. CLS Bank, 573 U.S. 208, 218, 110 USPQ2d 1976, 1982 (2014), See MPEP 2106.04(a)(2)(III)(C) Claims can recite a mental process even if they are claimed as being performed on a computer. The Supreme Court recognized this in Benson, determining that a mathematical algorithm for converting binary coded decimal to pure binary within a computer’s shift register was an abstract idea. The Court concluded that the algorithm could be performed purely mentally even though the claimed procedures “can be carried out in existing computers long in use, no new machinery being necessary.” 409 U.S at 67, 175 USPQ at 675. See also Mortgage Grader, 811 F.3d at 1324, 117 USPQ2d at 1699 (concluding that concept of “anonymous loan shopping” recited in a computer system claim is an abstract idea because it could be “performed by humans without a computer”)).
Claim 1 (and similarly Claims 8 and 15) is directed to a series of steps for performing personalized dunning actions, which is a commercial interaction and thus grouped as a certain method of organizing human interactions and being performed using mental processes. The mere nominal recitation of a centralized platform including at least one memory configured to store program code, at least one processor configured to read the program code and operate as instructed by the program code, and a first engagement channel, does not take the claim out of the method of organizing human interactions nor mental processes. Thus, Claim 1 (and similarly Claims 8 and 15) recites an abstract idea.
Step 2A – Prong 2: Can the Judicial Exception Recited be integrated into a practical application
Limitations that are indicative of integration into a practical application:
Improvements to the functioning of a computer, or to any other technology or technical field - see MPEP 2106.05(a)
Applying or using a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition – see Vanda Memo
Applying the judicial exception with, or by use of, a particular machine - see MPEP 2106.05(b)
Effecting a transformation or reduction of a particular article to a different state or thing - see MPEP 2106.05(c)
Applying or using the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception - see MPEP 2106.05(e) and Vanda Memo
Limitations that are not indicative of integration into a practical application:
Adding the words “apply it” (or an equivalent) 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)
Adding insignificant extra-solution activity to the judicial exception - see MPEP 2106.05(g)
Generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h)
The identified abstract idea of exemplary Claim 1 (and similarly Claims 8 and 15) is not integrated into a practical application, The additional. elements are: a centralized platform including at least one memory configured to store program code, at least one processor configured to read the program code and operate as instructed by the program code, and a first engagement channel, are merely generically recited computer elements that do not add a meaningful limitation to the abstract idea because they amount to merely using a computer as a tool to perform an abstract idea - see MPEP 2106.05(f).
Accordingly, alone and in combination, these additional elements do not integrate the abstract idea into a practical application. Claim 1 (and similarly Claims 8 and 15) is directed to an abstract idea.
Step 2B – Significantly More Analysis
Claim 1 (and similarly Claims 8 and 15) does not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when considered separately and in combination, a) monitoring a status; b) obtaining a customer score; c) receiving customer specific data via a real time data ingestion pipeline form customer data sources; d) generating, in real time, a dunning score using a real time dunning decision model; e) determining, in real time, a dunning action; f) performing, in real time, the dunning action; and g) notifying the customer via a first engagement channel, do not add significantly more to the exception because they amount to merely using a computer as a tool to perform an abstract idea - see MPEP 2106.05(f). Claim 1 (and similarly Claims 8 and 15) is ineligible.
Claim 2 (and similarly Claims 9 and 16) recites the abstract idea of mathematical concepts. See MPEP 2106.04(a)(2)(II).
Claim 4 (and similarly Claims 11 and 18) recites the abstract idea of mathematical concepts. See MPEP 2106.04(a)(2)(II).
Claim 5 (and similarly Claim 12) recites the abstract idea of mathematical concepts. See MPEP 2106.04(a)(2)(II).
Claim 6 (and similarly Claims 13 and 19) recites the abstract idea of mathematical concepts. See MPEP 2106.04(a)(2)(II).
Claim 7 (and similarly Claims 14 and 20) recites the abstract idea of mathematical concepts. See MPEP 2106.04(a)(2)(II).
Prior Art
The prior arts of record fail to teach the overall combination as claimed for Claims 1-2, 4-9, 11-16, and 18-20 in the instant application. Therefore, it would not have been obvious to one of ordinary skill in the art to modify the prior art to meet the combination above without unequivocal hindsight and one of ordinary skill would have no reason to do so. Exemplary claim 1 recites the following:
A method for personalized customer dunning, performed by a centralized platform including at least one processor, wherein the method comprises:
monitoring a status of a plurality of invoices;
obtaining a customer score for a customer corresponding to an invoice of the plurality of invoices, based on the status of the invoice, wherein the customer score is previously determined based on customer data, and wherein the customer data comprises at least one of average revenue per user, customer type, tenure, or fraud score;
receiving customer-specific data via a real time data ingestion pipeline from one or more customer data sources;
generating, in real time, a dunning score for the customer using a real time dunning decision model, wherein one or more parameters of the real time dunning decision model are dynamically configurable during the runtime based on the received customer-specific data and the customer score;
determining, in real time, a dunning action based on the dunning score,
wherein the dunning action comprises one of a suspension of a service, a cancellation of the service, or a removal from a service barring list;
performing, in real time, the dunning action; and
notifying the customer of the performed dunning action via a first engagement channel. (Emphasis added to highlight features that distinguish over the prior art).
As further explained below, the prior art of record, alone or in combination, neither anticipates, reasonably teaches, nor renders obvious the Applicant’s claimed invention.
US Pat Pub 2002/0026394 "Savage " discloses automatically assemble and aggregate account charges, such as usage charges, fees, finance charges, discounts, rebates and rewards, for the customer on the plurality of accounts. The system also automatically formats a combined bill for the customer from the aggregated account charges and renders the combined bill to the customer. The account charges are automatically calculated by a computer application from account data for the customer's accounts. Savage fails to disclose real time generation of a dunning score for the customer using a real time dunning decision model, wherein one or more parameters of the real time dunning decision model are dynamically configurable during runtime based on the received customer-specific data and a customer score and real time determination of a dunning action, wherein the dunning action comprises one of a suspension of service, a cancellation of the service, or a removal from a service barring list.
US Pat Pub 2020/0327552 "Seshan " teaches for each of a plurality of potential candidate retry time points, the one or more features and the potential candidate retry time point are fed into a dunning model, the dunning model trained via a machine-learning algorithm to produce a dunning score indicative of a likelihood that a retry attempt at an input retry time point will result in a successful payment processing. The dunning scores for the plurality of potential candidate retry time points are used to select a desired retry time point. Seshan fails to teach real time generation of a dunning score for the customer using a real time dunning decision model, wherein one or more parameters of the real time dunning decision model are dynamically configurable during runtime based on the received customer-specific data and a customer score and real time determination of a dunning action, wherein the dunning action comprises one of a suspension of service, a cancellation of the service, or a removal from a service barring list.
US Pat Pub 2019/0354250 "Jamison" teaches determining an active user subset of a group-based communication system user group based on the group-based activity data, comparing the active user subset to a predetermined user activity threshold, in circumstances where the active user subset satisfies the predetermined user activity threshold, render a trigger component to the group-based communication interface. Jamison fails to teach real time generation of a dunning score for the customer using a real time dunning decision model, wherein one or more parameters of the real time dunning decision model are dynamically configurable during runtime based on the received customer-specific data and a customer score and real time determination of a dunning action, wherein the dunning action comprises one of a suspension of service, a cancellation of the service, or a removal from a service barring list.
Response to Arguments
Applicant's arguments filed November 21, 2025 have been fully considered but they are not persuasive.
Applicant argues the judicial exception is integrated into a practical application of an improved automated dunning method, which automatically evaluates customers in real time, and performs a hard barring or removal of service based on the results of the customer evaluation. Thus, embodiments of the present invention represent an improvement to dunning systems by reducing the risk of both fraud and customer delinquency. Dunning is an abstract commercial concept (hard barring action/removal from a barring list in this case). See MPEP 2106.04(a)(2)(II)(B) Commercial or Legal Interactions as a form of Organizing Human Activity, mitigating settlement risk, Alice Corp. Pty. Ltd. v. CLS Bank Int'l, 573 U.S. 208, 218, 110 USPQ2d 1976, 1979 (2014).
Further, communicating in real time is also found to be the abstract idea of Mental Processes that are automated using generic computer components. See MPEP 2106.04(a)(2)(III)(C) Claims can recite a mental process even if they are claimed as being performed on a computer. The Supreme Court recognized this in Benson, determining that a mathematical algorithm for converting binary coded decimal to pure binary within a computer’s shift register was an abstract idea. The Court concluded that the algorithm could be performed purely mentally even though the claimed procedures “can be carried out in existing computers long in use, no new machinery being necessary.” 409 U.S at 67, 175 USPQ at 675. See also Mortgage Grader, 811 F.3d at 1324, 117 USPQ2d at 1699 (concluding that concept of “anonymous loan shopping” recited in a computer system claim is an abstract idea because it could be “performed by humans without a computer”).
Applicant further argues that the Office’s analysis also conflicts with Director Squires’ recent emphasis in Ex parte Desjardins that claims, as here, reciting a technological improvement requires patent-eligibility. However, the claims are not found to be a technological improvement. They are found to be an improvement to the abstract idea, but applied using computing technologies. Ex parte Desjardins identifies improvements in training the machine learning model itself. The claims of this application merely apply a real time dunning decision model. While this model might show improvements to creating dunning decisions, it does not create an improvement to a technology. The claims are found to be ineligible.
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.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to REVA R MOORE whose telephone number is (571)270-7942. The examiner can normally be reached M-Th: 9:00-6:00.
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/REVA R MOORE/Examiner, Art Unit 3627
/FAHD A OBEID/Supervisory Patent Examiner, Art Unit 3627