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 .
Continued Examination Under 37 CFR 1.114
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 3/5/2026 has been entered.
Response to Amendments
Claims 3, 10, and 17 have been cancelled.
Claims 1, 8, and 15 have been amended.
The rejection under 35 USC 101 has been updated in view of applicant’s amendments.
The rejection under 35 USC 103 was previously vacated. The prior art of record does not disclose storing a status of each of the plurality of virtual accounts, the status being at least one of assigned or not assigned.
Response to Arguments
The attorney does not provide arguments that are persuasive regarding the rejection under 35 USC 101.
The independent claims as amended require receiving, “by the at least one processor of a Business Support System (BSS)” from a third-party bank system, information on a plurality of virtual accounts linked to a bank account… This amendment does clarify aspects of the receiving step, but does not include anything more than simple data receiving functionality. It does not detail any specific structure outside a generic processor of the Business Support System. These new amendments do not add any element or feature of the Business Support System that provides an integration into a practical application by providing a technological solution to a technological problem or by technologically improving any recited additional element (which is simply being used to carry out the abstract idea as a “tool” under Step 2A, Prong 2), or include any element or feature that is significantly more than the recited abstract idea (i.e., a technological inventive concept under Step 2B). (See MPEP §§2106.04, 2106.05).
The claims were also amended to include, receive, “at the BSS via an API call”. The specification as originally filed merely refers to an API call as name and does not add anything beyond the known structured process of communicating with a client device. The claims do not specify how the API mechanism technically improves computer functionality or another technology. At a high level, an API call is ordinarily just a conventional way of: requesting data, receiving data, and passing the data. A generic API call is a well-understood, routine, and conventional way for software systems to exchange information. The applicant did not claim a particular non-conventional API-based mechanism that improves system performance, reliability, security, interoperability, or another technical function, the added limitation is just conventional computer activity appended to the abstract idea.
As noted previously, the recited additional elements, such as: an “apparatus” for bill management of various customer accounts, at least one “processor”, and at least one “memory” or a “computer readable medium” storing executable program code or instructions to accomplish various functions, do not amount to an inventive concept since the claims are simply using each of these additional elements, which are recited in the claims at a high degree of generality. There is no recitation of a specific improvement to computer functionality (e.g., novel data structures, memory management, protocol-level control, reduced network round trips via defined mechanisms).
The Applicant argues, that the claims provide a technical solution to a technical problem, because the virtual account is assigned to a single billing account allocated for a particular transaction
Applicant respectfully submits that the claims provide a technological solution to a technological problem. Because the virtual account is assigned to a single billing account allocated for a particular transaction and/or service provided, the telco operating system is able to immediately (or within the predetermined time) reflect a processed payment made in a VBA to the appropriate billing account without requiring, e.g., an auditing process which is prone to error (as-filed Specification, paragraph [0078]). The amended claims address this technical problem through the specific architecture of API-based communication between the banking system and BSS, combined with automated database retrieval.
The Examiner notes, the specific architecture is merely recited at a high level and merely invokes generic computer tools. The claims remain directed to an abstract idea. The fact that the claimed process is implement with a Bill Management system using virtual accounts does not convert a billing problem into a technical problem.
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 to non-statutory patent ineligible subject matter. (See, Alice and MPEP §2106)
In sum, the claims are rejected under 35 U.S.C. §101 because the claimed invention recites and is directed to a judicial exception to patentability (i.e., an abstract idea) and does not provide an integration of the recited abstract idea into a practical application nor include an inventive concept that is “significantly more” than the recited abstract idea to which the claim is directed. (MPEP §2106)
In determining subject matter eligibility in an Alice rejection under 35 U.S.C. §101, it is first determined as Step 1 whether the claims are directed to one of the four statutory categories of an invention (i.e., a process, a machine, a manufacture, or a composition of matter) (MPEP §2106.03). Here, the claims are directed to the statutory category of a process (claims 1-7), a machine (claims 8-14) and a manufacture (claims 15-20). Therefore, we proceed to Step 2A, Prong 1. (MPEP §2106)
Under a Step 2A, Prong 1 analysis, it must be determined whether the claims recite an abstract idea that falls within one or more enumerated categories of patent ineligible subject matter that amounts to a judicial exception to patentability. (MPEP §2106.04). The independent claims, at their core, recite the abstract idea of:
A method for bill management of a business to business (B2B) customer account comprising one or more billing accounts, comprising: receiving, information on a plurality of virtual accounts linked to a bank account, of a service provider; assigning a billing account, of a customer of the service provider, to a virtual account among the plurality of virtual accounts, the assigning comprising linking an identifier of the billing account with an identifier of the virtual account; receiving, a notification of a payment made to the bank account via the virtual account, the notification being sent in response to the payment and prior to a confirmation of the payment being received, and the notification indicating the identifier of the virtual account; identifying the billing account, from among the one or more billing accounts, assigned to the virtual account based on the identifier of the virtual account indicated in the notification; and crediting the identified billing account for the payment prior to the confirmation from the third-party bank system, wherein the method further comprises storing a status of each of the plurality of virtual accounts, the status being at least one of assigned or not assigned.
Here, the recited abstract idea falls within one or more of the three enumerated categories of patent ineligible subject matter (MPEP §2106.04), to wit: certain methods of organizing human activity, which includes the sub-category of commercial interactions involving sales activities or behaviors (e.g., in the claims: processing various payment transactions by various customers to a respective billing account having a related bank account of a service provider via the customers’ payments to respective virtual accounts that are each respectively linked to the service provider’s bank account where the respective billing accounts are credited with the respective payments made by the various customers).
Under Step 2A, Prong 2 the recited additional elements are evaluated to determine whether they provide an integration of the recited abstract idea into a practical application. (i.e., whether they provide a technological solution). (MPEP §2106.04) Here, the recited additional elements, such as: an “apparatus” for bill management of various customer accounts, at least one “processor”, and at least one “memory” or a “computer readable medium” storing executable program code or instructions to accomplish various functions, a Business Support System (BSS), a database… do not amount to an inventive concept since the claims are simply using each of these additional elements, which are recited in the claims at a high degree of generality, as a tool to carry out the recited abstract idea (i.e., “apply it”) on a computer, using a memory device and/or a database, on a data or communication network, on a display device or user interface, or on another computing device listed above, and/or via software programming, where the additional elements are not being technologically improved but simply perform generic computer data receipt and processing/analysis steps, data storage and communication steps, and/or outputting/displaying steps such as those typically used in a general purpose computer, a computing system, a display or user interface, and/or a computer or communication network. Thus, the claims do not provide an integration into a practical application.
Under the Step 2B analysis, it is determined whether the recited additional elements amount to something “significantly more” than the recited abstract idea to which the claims are directed. (i.e., provide an inventive concept). (MPEP §2106.05) Here, the recited additional elements, identified above in the Step 2A, Prong 2 analysis, do not amount to an inventive concept since, as stated above in the Step 2A, Prong 2 analysis, where the additional elements are not being technologically improved, but rather, the claims are simply using the additional elements as a tool to carry out the abstract idea (i.e., “apply it”) on a computer, using a memory device and/or a database, on a data or communication network, or on another computing device listed above, and/or via software programming, where the additional elements are specified at a high level of generality as simply facilitating and/or performing generic computer data receipt and processing/analysis steps, data inputting steps, data storage and communication steps, and/or data outputting/displaying steps such as those typically used in a general purpose computer, a computing system, a display or user interface, and/or a computer or communication network, where the additional elements are being used in the claims to simply implement the abstract idea and are not themselves being technologically improved, and therefore do not provide something “significantly more.” (See e.g., MPEP §2106.05 I.A.)
The dependent claims simply further refine and limit the abstract idea recited by the independent claims, from which these claims respectively directly or indirectly depend, where the abstract idea is described above.
Claims 2, 5-7, 9, 12-14, 16 and 19-20 simply further refine the abstract idea by requiring a payment acknowledgement, a payment report, a billing report, or a payment amount and identification of the payment, where are all payment data, and these claims do not add any element or feature that provides an integration into a practical application by providing a technological solution to a technological problem or by technologically improving any recited additional element (which is simply being used to carry out the abstract idea as a “tool” under Step 2A, Prong 2), or include any element or feature that is significantly more than the recited abstract idea (i.e., a technological inventive concept under Step 2B). (See MPEP §§2106.04, 2106.05)
Claims 4, 11 and 18 simply further refine the abstract idea by requiring that a billing account balance is obtained and is used to credit the billing account, which are simply functions of obtaining payment data and providing that data as a credit to a financial account, and these claims do not add any element or feature that provides an integration into a practical application by providing a technological solution to a technological problem or by technologically improving any recited additional element (which is simply being used to carry out the abstract idea as a “tool” under Step 2A, Prong 2), or include any element or feature that is significantly more than the recited abstract idea (i.e., a technological inventive concept under Step 2B). (See MPEP §§2106.04, 2106.05)
Thus, neither the independent claims nor the dependent claims, viewed individually and as a whole, including consideration of all the limitations of each claim viewed both individually and in combination, add any additional element or provide any subject matter that provides a technological improvement (i.e., an integration into a practical application) that results in the claims being directed to patent eligible subject matter, nor do the claims provide something significantly more than the recited abstract idea to which the claims are directed.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Hilt et al., 6,032,133, Feb. 29, 2000, discloses an Electronic Bill Pay System
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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/MATTHEW S GART/Supervisory Patent Examiner, Art Unit 3696
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