Prosecution Insights
Last updated: April 19, 2026
Application No. 17/809,875

VIRTUAL TRANSACTION MANAGEMENT

Final Rejection §101§103
Filed
Jun 29, 2022
Examiner
PATEL, DIVESH
Art Unit
3696
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
BILLGO, INC.
OA Round
4 (Final)
53%
Grant Probability
Moderate
5-6
OA Rounds
3y 0m
To Grant
92%
With Interview

Examiner Intelligence

Grants 53% of resolved cases
53%
Career Allow Rate
64 granted / 120 resolved
+1.3% vs TC avg
Strong +39% interview lift
Without
With
+39.1%
Interview Lift
resolved cases with interview
Typical timeline
3y 0m
Avg Prosecution
19 currently pending
Career history
139
Total Applications
across all art units

Statute-Specific Performance

§101
42.6%
+2.6% vs TC avg
§103
38.7%
-1.3% vs TC avg
§102
3.4%
-36.6% vs TC avg
§112
11.2%
-28.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 120 resolved cases

Office Action

§101 §103
DETAILED ACTION Notice of 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 This action is in reply to the first amendment to non-final filed on December 10, 2025. Claims 1, 8, and 15 have been amended and are hereby entered. Claims 21–25 have been added. Claims 5, 9–11, and 18 have been canceled. Claims 1–4, 6–8, 12–17, and 19–25 are currently pending and have been examined. This action is made FINAL. Response to Amendment The amendment filed December 10, 2025 has been entered. Claims 1–4, 6–8, 12–17, and 19–25 remain pending in the application. Claim Rejections - 35 USC § 101 The following is a quotation of 35 U.S.C. 101: 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 1–4, 6–8, 12–17, and 19–25 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. First of all, claims must be directed to one or more of the following statutory categories: a process, a machine, a manufacture, or a composition of matter. Claims 1–4, 6, 7, and 21–23 are directed to a machine (“A system”), and claims 8, 12–17, 19, 20, 24, and 25are directed to a process (“A method”). Thus, claims 1–4, 6–8, 12–17, and 19–25 satisfy Step One because they are all within one of the four statutory categories of eligible subject matter. Claims 1–4, 6–8, 12–17, and 19–25, however, are directed to an abstract idea without significantly more. For claim 1, the specific limitations that recite an abstract idea are: receiving, from . . . a user, an indication of a transaction request for a transaction to a recipient from the user, wherein the transaction request indicates the recipient of the transaction; determining an alias associated with the user; generating a set of transaction instructions comprising an indication of the determined alias and a transaction agent associated with the user; transmitting, to . . . the transaction recipient . . ., the set of transaction instructions; receiving, from . . . a transaction agent resulting from execution of the set of transaction instructions, a transaction verification request; processing the transaction verification request to determine whether to confirm the transaction; and when it is determined not to automatically confirm the transaction: requesting, from . . . the user, a user indication whether to confirm the transaction; receiving, from . . . the user, the user indication; and providing, in response to the received transaction verification request, an indication to . . . the transaction agent according to the user indication received from . . . the user. Claims 1–4, 6, 7, and 21–23, therefore, recite requesting and verifying a transaction, which is the abstract idea of certain methods of organizing human activity because they recite a commercial interaction and the fundamental economic practice of mitigating risk. For claim 8, the specific limitations that recite an abstract idea are: receiving, an indication of a transaction request for a transaction from a user to a recipient, the indication comprising an indication of the recipient of the transaction, wherein the transaction is to transfer a resource of the user at a resource manager to the transaction recipient; determining an alias associated with the user; generating a set of transaction instructions comprising an indication of the determined alias an associated routing transaction number, and an indication of a transaction agent associated with the routing transaction number; and transmitting, to . . . the transaction recipient . . ., the set of transaction instructions, thereby causing execution of the set of transaction instructions to transfer the resource to the transaction recipient receiving, from . . . the transaction agent associated with the routing transaction number as a result of the execution of the set of transaction instructions, a transaction verification request; providing, to a user . . . a request to confirm the transaction; receiving, in response to the request to confirm the transaction, a user indication whether to confirm the transaction; and providing, to . . . the transaction agent, the user indication whether to confirm the transaction. Claims 8, 12–14, 24, and 25, therefore, recite requesting a transaction, which is the abstract idea of certain methods of organizing human activity because they recite a commercial interaction. For claim 15, the specific limitations that recite an abstract idea are: receiving, from a resource manager: a transaction request indicating a transaction from a user to a recipient, wherein the transaction request comprises an indication of the recipient of the transaction; and the resource associated with the transaction; updating a ledger associated with the resource manager to indicate the received resource; determining an alias associated with the user; generating a set of transaction instructions comprising an indication of the determined alias and a transaction agent associated with the user; transmitting, to . . . the transaction recipient . . ., the set of transaction instructions; receiving, from . . . a transaction agent resulting from execution of the set of transaction instructions, a transaction verification request; processing the transaction verification request to determine whether to automatically confirm the transaction; and when it is determined not to automatically confirm the transaction, requesting, from . . . the user, a user indication whether to confirm the transaction; providing, in response to the received transaction verification request, an indication to confirm the transaction based on the received user indication to confirm the transaction; and updating the ledger to indicate the resource was transferred to the transaction recipient. Claims 15–17, 19, and 20, therefore, recite requesting, verifying, performing, and recording a transaction, which is the abstract idea of certain methods of organizing human activity because they recite a commercial interaction and the fundamental economic practice of mitigating risk. The judicial exceptions recited above are not integrated into a practical application. The additional elements of the claims are various generic technologies and computer components to implement these abstract ideas (“processor”, “memory”, “system”, “computing device”, “application programming interface”, and “data store”). These additional elements are not integrated into a practical application because the invention merely applies the abstract idea to generic computer technology, using the computer to receive transaction instructions and store user information. Because the invention is using the computer simply as a tool to perform the abstract idea on, the judicial exceptions are not integrated into a practical application. Finally, the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exceptions because, as discussed above, the additional elements in combination are at a high level of generality such that they amount to no more than mere instructions to apply the abstract idea using generic components. Because merely “applying” the exception using generic computer components cannot provide an inventive concept, the additional elements do not recite significantly more than the judicial exceptions. Thus, claims 1, 8, and 15 are not patent eligible. Dependent claims 2–4, 6, 7, 12–14, 16, 17, and 19–25 have been given the full two part analysis, analyzing the additional limitations both individually and in combination. The dependent claims, when analyzed individually and in combination, are also held to be patent ineligible under 35 U.S.C. 101. For claims 2, 3, 12, 13, 16, and 17, the additional recited limitations of these claims merely further narrow the abstract idea discussed above. These dependent claims only narrow the transaction recited in claims 1, 8, and 15 by further specifying how the alias is determined—“accessing a data store”, “generating an alias”, “associating the alias with the user”, and “based . . . on an association . . . with the transaction recipient”. The limitations of these claims fail to integrate the abstract idea into a practical application because these claims do not introduce additional elements other than the generic components discussed above. These claims do recite a data store, but again, this is also merely being used as a tool to store information. These dependent claims, therefore, also amount to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitations of these dependent claims fail to establish that the claims provide an inventive concept because claims that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept. For claims 4 and 14, the additional recited limitations of these claims are merely directed to an abstract idea. These dependent claims only recite receiving a resource and updating a ledger for the transaction, which is the abstract idea of certain methods of organizing human activity because they recite a commercial interaction. The limitations of these claims fail to integrate the abstract idea into a practical application because these claims do not introduce additional elements other than the generic components discussed above. These claims do recite a data store, but again, this is also merely being used as a tool to store information. These dependent claims, therefore, also amount to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitations of these dependent claims fail to establish that the claims provide an inventive concept because claims that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept. For claims 6 and 19, the additional recited limitations of these claims merely further narrow the abstract idea discussed above. These dependent claims only narrow the transaction recited in claims 1 and 15 by further specifying the transaction instructions—“routing transaction number”. For claims 7 and 20, the additional recited limitations of these claims merely further narrow the abstract idea discussed above. These dependent claims only narrow the transaction recited in claims 1 and 15 by further specifying how the verification request is received—“from a transaction agent”. For claims 21, 22, 24, and 25, the additional recited limitations of these claims merely further narrow the abstract idea discussed above. These dependent claims only narrow the transaction recited in claims 1 and 8 by further specifying the user indication and response—“confirmation” and “rejection”. For claim 23, the additional recited limitations of this claim are merely directed to an abstract idea. This dependent claim only recites processing transaction information, which is the abstract idea of certain methods of organizing human activity because it recites a commercial interaction. Response to Arguments Claim Rejections Under 35 U.S.C. § 101 Applicant’s arguments filed on December 10, 2025 have been fully considered but they are not persuasive. Applicant argues that the claims are integrated into a practical application and recite significantly more than any judicial exception because they recite a technological improvement. Applicant cites to the newly amended limitations of the claims, and explains that the claims execute transaction instructions to automatically verify the transaction and prompt a user confirmation if not automatically verified. Applicant therefore argues that the claims improve the functioning of a computer by achieving this improved electronic transaction processing by a group of connected computing devices. The improvement cited by Applicant, however, is verification of a transaction by prompting a user for input. This is merely an improvement to the transaction recited, by using the technology as a tool to request user confirmation. The claims are therefore merely applying the technology to make the transaction more secure and efficient, rather than improving the technology itself in any way. Thus, claims 1–4, 6–8, 12–17, and 19–25 do not include additional elements sufficient to integrate the claims into a practical application or recite significantly more than the judicial exception. Claim Rejections Under 35 U.S.C. § 103 The rejections of claims 1–4, 6–8, 12–17, 19, and 20 under 35 U.S.C. 103 have been withdrawn in light of Applicant’s amendments and arguments. The following limitations of claim 1 are not taught by the previously cited prior art: generating a set of transaction instructions comprising an indication of the determined alias and a transaction agent associated with the user. The prior art reference of record that is most closely related to the claim limitation recited above is Greenberger, U.S. Patent App. No. 2019/0164154 (“Greenberger”), which discusses transaction instructions that are associated with an agent device. Greenberger, however, discusses requesting and receiving transaction instructions including information relating to agent information, but does not disclose generating transaction instructions indicating a transaction agent associated with the user, as in the claimed invention. And, no reference could be found for generating instructions in this way, nor would it necessarily have been obvious to combine such a reference with the existing references, or to combine so many references, to disclose the claimed limitations. Independent claims 8 and 15 include substantially the same features as claim 1. Accordingly, the prior rejections of claims 1–4, 6–8, 12–17, 19, and 20 under 35 U.S.C. 103 have been withdrawn. Prior Art Not Relied Upon The prior art made of record and not relied upon is considered pertinent to Applicant’s disclosure. Those prior art references are as follows: Campbell et al., U.S. Patent App. No. 2012/0197795, discloses a payment transaction using payment instructions and a payer ID. Davis et al., U.S. Patent App. No. 2018/0365680, discloses application programming interfaces for payment transactions. Friesen, U.S. Patent App. No. 2009/0234764, discloses a transfer agent for authenticating a transfer. Ong, U.S. Patent App. No. 2005/0246293, discloses an online transaction with a transaction manager. 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. Any inquiry concerning this communication or earlier communications from the examiner should be directed to DIVESH PATEL whose telephone number is (571) 272–3430. The examiner can normally be reached on Monday and Thursday 10:00 AM–8:00 PM EST. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Matthew Gart can be reached on (571) 272–3955. The fax phone number for the organization where this application or proceeding is assigned is 571–273–8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /DIVESH PATEL/Examiner, Art Unit 3696
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Prosecution Timeline

Jun 29, 2022
Application Filed
Apr 18, 2024
Non-Final Rejection — §101, §103
Sep 23, 2024
Response Filed
Dec 27, 2024
Final Rejection — §101, §103
Jun 30, 2025
Request for Continued Examination
Jul 03, 2025
Response after Non-Final Action
Jul 08, 2025
Non-Final Rejection — §101, §103
Dec 10, 2025
Response Filed
Mar 17, 2026
Final Rejection — §101, §103 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

5-6
Expected OA Rounds
53%
Grant Probability
92%
With Interview (+39.1%)
3y 0m
Median Time to Grant
High
PTA Risk
Based on 120 resolved cases by this examiner. Grant probability derived from career allow rate.

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