DETAILED ACTION
1. The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . This Office action is in response to Applicant’s communication filed on October 17, 2025. Amendments to claims 1, 8, and 14, have been entered. Claims 1, 3-9, 11-14, 16, 17 and 19-24 are pending and have been examined. The statement of reasons for the indication of allowable subject matter over prior art was already discussed in the Office action mailed on September 5, 2024 and hence not repeated here. The rejections and the response to arguments are stated below.
Claim Rejections - 35 USC § 101
2. 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.
3. Claims 1, 3-9, 11-14, 16, 17 and 19-24 are rejected under 35 U.S.C. § 101 because the claimed invention is directed to an abstract idea without significantly more.
The claim(s) recite(s) a system/method for intelligent processing of automatic transaction requests, which is considered a judicial exception because it falls under the category of “Certain Methods of organizing human activity” such as fundamental economic practice as well as commercial or legal interactions including agreements as discussed below. This judicial exception is not integrated into a practical application as discussed below. The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception as discussed below.
Analysis
Step 1: In the instant case, exemplary claim 1 is directed to a system (apparatus).
Step 2A – Prong One: The limitations of “A system for intelligent decisioning and routing for automatic transaction requests, the system comprising:
one or more memories; and
one or more processors, communicatively coupled to the one or more memories, configured to:
receive, from a user device, information to identify one or more alternative accounts to be used in one or more automatic transactions to prevent a value associated with a main account from failing to satisfy a threshold,
wherein a payment from the main account is linked via a transaction backend system to a bank account from which funds are withdrawn via automated clearing house (ACH) transfer;
receive multiple automatic transaction requests that are each associated with a respective amount to be transferred from the value associated with the main account;
determine that transferring an aggregate amount associated with the multiple automatic transaction requests from the main account would cause the value associated with the main account to fail to satisfy the threshold;
determine, using a machine learning model, relative priorities for the multiple automatic transaction requests,
wherein the machine learning model determines a priority based on consumption data associated with a first automatic transaction request, of the multiple automatic transaction requests, and a second automatic transaction request, of the multiple automatic transaction requests,
wherein the consumption data is determined via devices tracking usage of services associated with the multiple automatic transaction requests;
wherein the devices are configured to automatically communicate consumption metrics to the system, and
wherein the devices include at least one of:
an augmented reality device,
an activity tracker, or
a wearable device;
process, via the transaction backend system and based on the machine learning model, the first automatic transaction request, included among the multiple automatic transaction requests, using the main account; and
process, and based on the machine learning model, the second automatic transaction request, using the one or more alternative accounts or using the main account after the value of the main account has changed to a level that is sufficient to satisfy the threshold and to cover the respective amount associated with the second automatic transaction request,
wherein the one or more processors, to process the second automatic transaction request, are to:
re-route an ACH-only automatic payment to an alternative bank account that supports the ACH transfer to the one or more alternative accounts,
wherein the re-routing is performed automatically based on dynamic consumption data received from the devices and output of machine learning model, and
wherein the system applies a recency bias to the consumption data to prioritize automatic transaction requests”
as drafted, when considered collectively as an ordered combination without the italicized portions, is a process that, under the broadest reasonable interpretation, covers the category of “Certain Methods of organizing human activity” such as fundamental economic practice as well as commercial or legal interactions including agreements.
Processing one or more automatic transaction requests is a fundamental economic practice such as authorizing a creditor to withdraw payments from a bank account and/or charge payments to a credit card account (See Specification [0001]). Also, the steps of the claim considered collectively as an ordered combination, is fulfilling agreements in the form of contracts between the user and a creditor (e.g., a lender, a merchant, or the like). Hence, the steps of the claim, considered collectively as an ordered combination without the italicized portions, covers the abstract category of “Certain Methods of organizing human activity”.
That is, other than, a system comprising one or more memories and one or more processors, a transaction backend system, an automated clearing house (ACH), a user device, a machine learning model and devices tracking usage of services (including at least one of: an augmented reality device, an activity tracker, or a wearable device), nothing in the claim precludes the steps from being performed as a method of organizing human activity. If the claim limitations, under the broadest reasonable interpretation, covers methods of organizing human activity but for the recitation of generic computer components, then it falls within the “Certain methods of organizing human activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
Step 2A – Prong Two: The judicial exception is not integrated into a practical application. In particular, the claim only recites the additional elements of one or more memories and one or more processors, a transaction backend system, an automated clearing house (ACH), a user device, a machine learning model and devices tracking usage of services (including an augmented reality device, an activity tracker, or a wearable device) to perform all the steps. A plain reading of at least Figures 1, 3 and 4, and descriptions in at least paragraphs [0054] – [0060] reveals that the memories may be generic memories suitably programmed to store associated data/information. The transaction backend system is broadly interpreted to include a suitably programmed generic transaction backend system and the ACH is the industry standard ACH system. The user device and the devices tracking usage of services (including an augmented reality device, an activity tracker, or a wearable device) may be generic computer devices suitably programmed to perform the corresponding functions. The machine learning model is broadly interpreted to correspond to generic software suitably programmed to perform the corresponding functions. The one or more processors may be generic processors (such as a central processing unit, a graphics processing unit, a microprocessor, a controller, a microcontroller etc.) suitably programmed to perform the claimed functions. Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. The additional elements in all the steps are recited at a high-level of generality (i.e., as generic computer components performing generic computer functions) such that it amounts no more than mere instructions to apply the exception using generic computer components. Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Hence, claim 1 is directed to an abstract idea.
Step 2B: The claim does 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, using the additional elements (identified above) to perform the claimed steps amounts to no more than mere instructions to apply the exception using a generic computer component. The additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Hence, independent claim 1 is not patent eligible. Independent claims 8 and 14 are also not patent eligible based on similar reasoning and rationale.
Dependent claims 3-7, 11-13, 16, 17 and 19-24, when analyzed as a whole are held to be patent ineligible under 35 U.S.C. 101 because the additional recited limitations only refine the abstract idea further.
For instance, in claims 3-6, 16, 17 and 19 the steps
“wherein the first set of automatic transaction requests are processed using the main account based on the machine learning model assigning a priority to the first set of automatic transaction requests that is higher than priorities assigned to the second set of automatic transaction requests and the third set of automatic transaction requests”,
“wherein the machine learning model is trained to assign the relative priorities to the multiple automatic transaction requests based on one or more features that relate to criticality, penalty avoidance, interest avoidance, or an impending change to the value of the main account”, “wherein the machine learning model is trained to assign the relative priorities to the multiple automatic transaction requests based on consumption data for respective services associated with the multiple automatic transaction requests”, and
“wherein the machine learning model is trained to apply a recency bias to the consumption data for the respective services associated with the multiple automatic transaction requests”,
under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the intermediate steps of the underlying process.
In claim 7, the step “wherein the first automatic transaction request is processed using the main account based on the first automatic transaction request having a type that is ineligible to delay or redirect to the one or more alternative accounts” under the broadest reasonable interpretation, is a further refinement of methods of organizing human activity because this step describes the accounts used in the intermediate step of the underlying process.
In claims 9, and 11-13, the steps “further comprising: receiving, from a user device, information to identify the one or more alternative accounts to be used to prevent the value associated with the main account from failing to satisfy the threshold”,
“wherein the automatic transaction request is processed according to the alternative transaction processing instruction based on the priority associated with the automatic transaction request being lower than a priority associated with another automatic transaction request”, “wherein the priority associated with the automatic transaction request is based on a criticality of the automatic transaction request, avoidance of a penalty associated with non-payment or delayed payment of the automatic transaction request, avoidance of interest incurred by non-payment or delayed payment of the automatic transaction request, an impending change to the value of the main account, or consumption data associated for a service associated with the automatic transaction request”, and
“wherein the automatic transaction request is processed according to the alternative transaction processing instruction based on the automatic transaction request having a type that is eligible to delay or redirect to the one or more alternative accounts”
under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the rules used in the intermediate steps of the underlying process.
In claim 20, the step “wherein the first set of automatic transaction requests include one or more automatic transaction requests that are ineligible to be delayed or redirected to the one or more alternative accounts” under the broadest reasonable interpretation, is a further refinement of methods of organizing human activity because these steps describe the rules used in an intermediate step of the underlying process.
In claims 21 - 24, the steps
“wherein a devices, of the devices, is an augmented reality device”,
“wherein the device is an activity tracker”, and
“wherein a device, of the devices, is a wearable device”
under the broadest reasonable interpretation, is a further refinement of methods of organizing human activity because these steps describe the devices used in an intermediate step of the underlying process. The additional elements of an augmented reality device, an activity tracker and a wearable device are broadly interpreted to include generic devices suitably programmed to perform the corresponding functions. The additional elements of the augmented reality device, an activity tracker and a wearable device, perform their traditional functions recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using generic computer components.
In all the dependent claims, the judicial exception is not integrated into a practical application because the limitations are recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using generic computer components. Also, the claims do not affect an improvement to another technology or technical field; the claims do not amount to an improvement to the functioning of a computer system itself; the claims do not affect a transformation or reduction of a particular article to a different state or thing; and the claims do not move beyond a general link of the use of an abstract idea to a particular technological environment. In addition, the dependent claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. The additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. The claims as a whole, do not amount to significantly more than the abstract idea itself. For these reasons, the dependent claims also are not patent eligible.
Response to Arguments
4. In response to Applicants arguments on pages 13-23 of the Applicant’s remarks that the claims are patent-eligible under 35 USC 101 when considered under MPEP 2106, the Examiner respectfully disagrees.
The fact that the claims are Patent-Ineligible when considered under the MPEP 2106 has already been addressed in the rejection and hence not all the details of the rejection are repeated here.
Response to Applicants’ arguments regarding Step 2A – Prong one:
The claim(s) recite(s) a system/method for intelligent processing of automatic transaction requests, which is considered a judicial exception because it falls under the category of “Certain Methods of organizing human activity” such as fundamental economic practice as well as commercial or legal interactions including agreements as discussed in the rejection. Processing one or more automatic transaction requests is a fundamental economic practice such as authorizing a creditor to withdraw payments from a bank account and/or charge payments to a credit card account (See Specification [0001]). Also, the steps of the claim considered collectively as an ordered combination, is fulfilling agreements in the form of contracts between the user and a creditor (e.g., a lender, a merchant, or the like). Hence, the steps of the claim, considered collectively as an ordered combination without the italicized portions, covers the abstract category of “Certain Methods of organizing human activity”.
The claimed features including those recited on pages 14-15 of the remarks such as “receive, from a user device, information to identify one or more alternative accounts to be used in one or more automatic transactions to prevent a value associated with a main account from failing to satisfy a threshold, wherein a payment from the main account is linked via a transaction backend system to a bank account from which funds are withdrawn via automated clearing house (ACH) transfer," "receive multiple automatic transaction requests that are each associated with a respective amount to be transferred from the value associated with the main account," "determine that transferring an aggregate amount associated with the multiple automatic transaction requests from the main account would cause the value associated with the main account to fail to satisfy the threshold," determine, using a machine learning model, relative priorities for the multiple automatic transaction requests, wherein the machine learning model determines a priority based on consumption data associated with a first automatic transaction request, of the multiple automatic transaction requests, and a second automatic transaction request, of the multiple automatic transaction requests, wherein the consumption data is determined via devices tracking usage of services associated with the multiple automatic transaction requests, wherein the consumption data is determined via devices tracking usage of services associated with the multiple automatic transaction requests, wherein the device are configured to automatically communicate consumption metrics to the system, and wherein the devices include at least one of. an augmented reality device, an activity tracker, or a wearable device," process, via the transaction backend system and based on the machine learning model, the first automatic transaction request, included among the multiple automatic transaction requests, using the main account," and "process, and based on the machine learning model, the second automatic transaction request using the one or more alternative accounts or using the main account after the value of the main account has changed to a level that is sufficient to satisfy the threshold and to cover the respective amount associated with the second automatic transaction request, wherein the one or more processors, to process the second automatic transaction request, are to: re-route an ACH-only automatic payment to an alternative bank account that supports the ACH transfer to the one or more alternative accounts, wherein the re- routing is performed automatically based on dynamic consumption data received from the devices and output of machine learning model, and wherein the system applies a recency bias to the consumption data to prioritize automatic transaction requests" are details that further define the abstract idea of a method for intelligent processing of automatic transaction requests. The additional elements in these steps are suitably programmed generic computer components that are used to apply the abstract idea. Hence, the claims recite an abstract idea.
Response to Applicants’ arguments regarding Step 2A – Prong two and Step 2B
According to MPEP 2106, limitations that are indicative of integration into a practical application include:
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
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).
In the instant case, the judicial exception is not integrated into a practical application, because none of the above criteria is met. The additional elements in the claims are one or more memories and one or more processors, a transaction backend system, an automated clearing house (ACH), a user device, a machine learning model and devices tracking usage of services (including an augmented reality device, an activity tracker, or a wearable device) to perform all the steps. A plain reading of at least Figures 1, 3 and 4, and descriptions in at least paragraphs [0054] – [0060] reveals that the memories may be generic memories suitably programmed to store associated data/information. The transaction backend system is broadly interpreted to include a suitably programmed generic transaction backend system and the ACH is the industry standard ACH system. The user device and the devices tracking usage of services (including an augmented reality device, an activity tracker, or a wearable device) may be generic computer devices suitably programmed to perform the corresponding functions. The machine learning model is broadly interpreted to correspond to generic software suitably programmed to perform the corresponding functions. The one or more processors may be generic processors (such as a central processing unit, a graphics processing unit, a microprocessor, a controller, a microcontroller etc.) suitably programmed to perform the claimed functions. Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. The additional elements in all the steps are recited at a high-level of generality (i.e., as generic computer components performing generic computer functions) such that it amounts no more than mere instructions to apply the exception using generic computer components. Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Hence, claim 1 is directed to an abstract idea.
The claimed features and those recited on pages 16-23 of the remarks and in paragraphs [0013] – [0014] and [0022] - [0025] of the Specification such as “determining where to route the transfer of funds by determining priorities of the automatic transaction requests using a machine learning model that prioritizes based on consumption data that is determined via devices tracking usage of services associated with the multiple automatic transaction requests ….. routing/re-routing, based on the priorities, of an ACH transfer of funds from a main account to an alternative account which processes the automatic transaction requests via the transaction backend system ….. determining, using a machine learning model, priorities associated with the automatic truncation requests based on consumption data that is determined via devices tracking usage of services associated with the multiple automatic transaction requests …… wherein the machine learning model determines a priority based on consumption data associated with a first automatic transaction request, of the multiple automatic transaction requests, and a second automatic transaction request, of the multiple automatic transaction requests, wherein the consumption data is determined via devices tracking usage of services associated with the multiple automatic transaction requests, wherein the device are configured to automatically communicate consumption metrics to the system, and wherein the devices include at least one of: an augmented reality device, an activity tracker, or a wearable device," "process, via the transaction backend system and based on the machine learning model, the first automatic transaction request, included among the multiple automatic transaction requests, using the main account," and "process, and based on the machine learning model, the second automatic transaction request using the one or more alternative accounts or using the main account after the value of the main account has changed to a level that is sufficient to satisfy the threshold and to cover the respective amount associated with the second automatic transaction request, wherein the one or more processors, to process the second automatic transaction request, are to: re-route an ACH- only automatic payment to an alternative bank account that supports the ACH transfer to the one or more alternative accounts, wherein the re-routing is performed automatically based on dynamic consumption data received from the devices and output of machine learning model, and wherein the system applies a recency bias to the consumption data to prioritize automatic transaction requests” only further refine the abstract idea of a method for intelligent processing of automatic transaction requests using the additional elements as tools, in their normal capacity. These claimed features may at best be characterized as an improvement in the abstract idea of a method for intelligent processing of automatic transaction requests. An improvement in abstract idea is still abstract (SAP America v. Investpic *2-3 (“We may assume that the techniques claimed are “groundbreaking, innovative, or even brilliant,” but that is not enough for eligibility. Association for Molecular Pathology v. Myriad Genetics, Inc., 569 U.S. 576, 591 (2013); accord buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1352 (Fed. Cir. 2014). Nor is it enough for subject-matter eligibility that claimed techniques be novel and nonobvious in light of prior art, passing muster under 35 U.S.C. §§ 102 and 103. See Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66, 89–90 (2012); Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 1151 (Fed. Cir. 2016) (“A claim for a new abstract idea is still an abstract idea). The additional elements (identified in the rejection) are generic computer components used, as tools in their ordinary capacity, to apply the abstract idea. It does not involve any improvements to another technology, technical field, or improvements to the functioning of the computer itself. The alleged advantages such as “conserving computing resources that would otherwise be incurred by one or more devices and/or resources being used to discontinue one or more services associated with the failed automatic payment(s) ….. creating various routing techniques to various accounts for payment using a machine learning model provides a meaningful benefit to the automatic payment system ” are due to improvements in the abstract idea of a method for intelligent processing of automatic transaction requests. It does not involve any improvements to another technology, technical field, or improvements to the functioning of the computer itself. Therefore, the Applicants’ arguments are not persuasive.
As discussed in the rejection, the 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, using the additional elements (identified in the rejection) to perform the claimed steps, amount to no more than mere instructions to apply the exception using a generic computer component. The additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Hence, the claims are not patent eligible. Therefore, Applicants’ arguments are not persuasive.
For these reasons and those discussed in the rejection, the rejections under 35 USC § 101 are maintained.
Conclusion
5. The prior art made of record and not relied upon is considered pertinent to applicant's disclosure:
(a) Chen; Hsiao (US Patent 10467689 B2) discloses systems and method for unified payment account establishment and incorporation in a main payment account. A service provider, such as a payment provider, may offer merchants with a development kit that unifies payment methods between various merchants and the service provider so that users are provided with more easily established payment accounts with the merchants. The development kit may include an account establishment interface that may be utilized in a merchant ordering and payment application for a merchant. The interface may provide for establishment of a payment account with the merchant. When initially establishing the payment account, the user may generate a provisional account, which may be synchronized to a payment account the user has with the service provider. When synchronizing the two accounts, the user may transfer information to the merchant, which may be redacted to prevent the merchant from receiving sensitive information.
6. 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 extension fee 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 date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to Narayanswamy Subramanian whose telephone number is (571) 272-6751. The examiner can normally be reached Monday-Friday from 9:00 AM to 5:00 PM. If attempts to reach the examiner by telephone are unsuccessful, the examiner's supervisor, Abhishek Vyas can be reached at (571) 270-1836. The fax number for Formal or Official faxes and Draft to the Patent Office is (571) 273-8300.
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/Narayanswamy Subramanian/
Primary Examiner
Art Unit 3691
November 15, 2025