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 November 17, 2025. Amendments to claims 26, 33 and 39 have been entered. Claims 26-44 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 January 30, 2024 and hence not repeated here. The rejections and 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 26-44 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 distributed networked computer system comprising a distributed ledger for performing at least one operation regarding managing funding among a company seeking capital, a special purpose acquisition company, one or more subscribers and several modules (listed in the claims), which is considered a judicial exception because it falls under the category of certain of methods of organizing human activity such as commercial and/or legal interactions including agreements in the form of contracts 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 26 is directed to a system.
Step 2A – Prong One: The limitations of “A distributed networked computer system comprising a distributed ledger for performing at least one operation regarding managing funding among a company seeking capital, a special purpose acquisition company, and one or more subscribers, the system comprising:
a first networked node associated with the company seeking capital, the first networked node comprising a (distributed ledger technology) DLT platform on which one or more smart contracts and one or more private data sharing channels are implemented;
a second networked node associated with the special purpose acquisition company, the second networked node comprising a DLT platform on which one or more smart contracts and one or more private data sharing channels are implemented;
one or more third networked nodes respectively associated with the one or more subscribers, each of the third networked nodes comprising a DLT platform on which one or more smart contracts and one or more private data sharing channels are implemented; wherein the first, second and the one or more third networked nodes are in communication through a network;
a securities planning module, an administration module, and a financial transactions module, each comprising at least one processor and memory;
one or more processors and a computer readable storage medium having instructions embodied therewith, which when operated by the one or more processors, cause the one or more processors to:
receive notice via the second networked node of a funding event comprising establishment of a special purpose vehicle company configured to hold assets of the company seeking capital and establishment of an incubator financial entity to manage an initial public offering to fund the company seeking capital:
determine an amount of funding for establishing the incubator financial entity and funding activities associated with the initial public offering;
generate a first message related to an initial subscriber offering to fund the company seeking capital and the incubator financial entity;
send the first message to the one or more third networked nodes associated with the one or more subscribers of the distributed networked computer system;
receive, from the one or more third networked nodes, an expression of interest for one or more shares of the incubator financial entity from the one or more subscribers via the one or more third networked nodes;
determine the initial public offering of investment shares in the company seeking capital based in part on the expression of interest received from the one or more subscribers via the one or more third networked nodes;
generate a second message associated with establishing the incubator financial entity to manage the initial public offering:
receive bids to purchase funding tokens for shares of the incubator financial entity via the one or more third networked nodes from the one or more subscribers in response to the second message;
record bids for the funding tokens and respective allocated tokens to the distributed ledger;
generate, based on the initial public offering, a third message related to the initial public offering;
send the third message to the one or more third networked nodes associated with one or more owners of the funding tokens; wherein the message comprises informing the one or more owners that a pro rata share of the raised funds is payable after the initial public offering;
generate one or more smart contracts accessible to the one or more networked nodes, wherein the smart contract comprises
terms comprising a payout triggering event; and
a plurality of predetermined electronic actions for generating a smart contract output when the payout triggering event is met, wherein the smart contract is configured to transmit payout instructions and generate a payout to the one or more owners automatically when the payout event is triggered;
transmit, from the administration module, transactions to a special receiver address on the distributed ledger corresponding to bids, allocations, and investor information, each transaction comprising compiled code corresponding to a smart contract;
wherein the compiled immutable self-executing code is configured to: (i) detect recordation of the bids, allocations, and investor information; (ii) generate terms and conditions based on IPO structure and allocated shares; (iii) communicate the respective terms and conditions to the corresponding third networked nodes; (iv) detect a payout-triggering event; and (v) trigger electronic actions including transmitting payout instructions to the financial transactions module;
record execution of the smart contract to the distributed ledger; and
execute through the terms of the smart contract to generate the payout to the one or more owners automatically when the payout triggering event is met;
wherein the securities planning module, the administration module, and the financial transactions module are logically separate from the distributed ledger;
wherein the payout triggering event is completion of the initial public offering, and the payout is a pro rata share of the proceeds paid to the one or more owners, executed automatically without human intervention, with execution recorded immutably to the ledger” as drafted, when considered collectively as an ordered combination, without the italicized portions, is a process that, under the broadest reasonable interpretation, covers methods of organizing human activity such as commercial interactions including resolution of agreements in the form of contracts.
Funding of a company seeking capital is a fundamental economic practice. Initial Public Offerings using a special purpose vehicle company are a known economic practice for several decades. The steps of “receive notice via the second networked node of a funding event comprising establishment of a special purpose vehicle company configured to hold assets of the company seeking capital and establishment of an incubator financial entity to manage an initial public offering to fund the company seeking capital;
determine an amount of funding for establishing the incubator financial entity and funding activities associated with the initial public offering;
generate a first message related to an initial subscriber offering to fund the company seeking capital and the incubator financial entity;
send the first message to the one or more third networked nodes associated with the one or more subscribers of the distributed networked computer system;
receive, from the one or more third networked nodes, an expression of interest for one or more shares of the incubator financial entity from the one or more subscribers via the one or more third networked nodes;
determine the initial public offering of investment shares in the company seeking capital based in part on the expression of interest received from the one or more subscribers via the one or more third networked nodes:
generate a second message associated with establishing the incubator financial entity to manage the initial public offering:
receive bids to purchase funding tokens for shares of the incubator financial entity via the one or more third networked nodes from the one or more subscribers in response to the second message;
record bids for the funding tokens and respective allocated tokens to the distributed ledger;
generate, based on the initial public offering, a third message related to the initial public offering;
send the third message to the one or more third networked nodes associated with one or more owners of the funding tokens; wherein the message comprises informing the one or more owners that a pro rata share of the raised funds is payable after the initial public offering;
generate one or more smart contracts accessible to the one or more networked nodes, wherein the smart contract comprises
terms comprising a payout triggering event; and
a plurality of predetermined electronic actions for generating a smart contract output when the payout triggering event is met, wherein the smart contract is configured to transmit payout instructions and generate a payout to the one or more owners automatically when the payout event is triggered;
transmit, from the administration module, transactions to a special receiver address on the distributed ledger corresponding to bids, allocations, and investor information, each transaction comprising compiled code corresponding to a smart contract;
wherein the compiled immutable self-executing code is configured to: (i) detect recordation of the bids, allocations, and investor information; (ii) generate terms and conditions based on IPO structure and allocated shares; (iii) communicate the respective terms and conditions to the corresponding third networked nodes; (iv) detect a payout- triggering event; and (v) trigger electronic actions including transmitting payout instructions to the financial transactions module;
record execution of the smart contract to the distributed ledger; and
execute the smart contract through the terms of the smart contract to generate the payout to the one or more owners automatically when the payout triggering event is met;
wherein the securities planning module, the administration module, and the financial transactions module are logically separate from the distributed ledger;
wherein the payout triggering event is completion of the initial public offering, and the payout is a pro rata share of the proceeds paid to the one or more owners, executed automatically without human intervention, with execution recorded immutably to the ledger” considered collectively as an ordered combination is a form of commercial and/or legal interaction including fulfillment/resolution of agreements in the form of contracts.
That is, other than, a distributed network computer system comprising a distributed ledger, a first networked node associated with the company seeking capital, a second networked node associated with the special purpose acquisition company, a (distributed ledger technology) DLT platform on which one or more smart contracts and one or more private data sharing channels are implemented, a securities planning module, an administration module, and a financial transactions module, one or more third networked nodes respectively associated with the one or more subscribers, one or more processors, and a computer readable storage medium, funding tokens, a special receiver address on the distributed ledger transactions, smart contracts comprising immutable self-executing code and electronic actions, nothing in the claim precludes the steps from being performed as a method of organizing human activity. The additional elements in the claims are all broadly interpreted to correspond to generic components suitably programmed to perform their respective functions. 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 a distributed network computer system comprising a distributed ledger, a first networked node associated with the company seeking capital, a second networked node associated with the special purpose acquisition company, a (distributed ledger technology) DLT platform on which one or more smart contracts and one or more private data sharing channels are implemented, a securities planning module, an administration module, and a financial transactions module, one or more third networked nodes respectively associated with the one or more subscribers, one or more processors, and a computer readable storage medium, funding tokens, a special receiver address on the distributed ledger transactions, smart contracts comprising immutable self-executing code and electronic actions to perform all the steps. A plain reading of Figures 2A-3, and 6A-6B and descriptions in at least associated paragraphs including paragraphs [0097] – [0114] and [0121] – [0146] reveals that a computing system comprising a distributed ledger, the networked nodes associated with the various entities, a DLT platform on which one or more smart contracts and one or more private data sharing channels, are implemented are generic computer components suitably programmed to perform their respective functions. The one or more processors may be generic processors such as microprocessors, gate arrays, array processors, and secure microprocessors, etc. The one or more memories may be generic memories suitably programmed to store the associated data/ information. The modules including a securities planning module, an administration module, and a financial transactions module, (the modules listed in the dependent claims) including the securities planning module, the administration module, and the financial transactions module, are broadly interpreted to comprise generic computer components suitably programmed to perform their respective functions. The distributed ledger, the one or more networked nodes, funding tokens, and the smart contracts (comprising immutable self-executing code) are all generic computer components suitably programmed to perform their respective functions. The special receiver addresses (in the dependent claims) on the distributed ledger transactions are suitably programmed generic addresses associate with their respective transactions. The electronic actions are suitably programmed generic electronic actions. Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. These 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 26 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) 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 26 is not patent eligible. Independent claims 33 and 39 are also not patent eligible based on similar reasoning and rationale.
Dependent claims 27-32, 34-38 and 40-44, 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 27, 34 and 40, the steps “further comprising a securities planning module, an administration module and a financial transactions module; wherein
the securities planning module comprises at least one processor configured to
receive the notice of the funding event comprising establishment of the special purpose vehicle company configured to hold assets of the company seeking capital and the establishment of the incubator financial entity to manage the initial public offering to fund the company seeking capital;
determine an amount of funding for establishing the incubator financial entity and funding activities associated with the initial public offering;
determine a structure of the initial public offering, comprising offering of shares in the company seeking capital; and
transmit the structure of the initial public offering and the amount of funding to the administration module; wherein
the administration module comprises at least one processor configured to
generate the first message, the second message and the third message and send the first message, the second message, and the third message to the one or more third networked nodes associated with the one or more subscribers of the distributed networked computer system;
receive, from the one or more third networked nodes, the expressions of interest for one or more shares of the company seeking capital from the one or more subscribers in response to the first message;
receive the bids to purchase funding tokens for shares of the incubator financial entity from one of more investors among the one or more subscribers via the one or more third networked nodes;
determine the allocation of funding tokens to the one or more investors based on the bids;
determine fractional amounts of shares of the incubator financial entity to allocate to each of the one or more investors based on the one or more bids received from the one or more investors;
allocate the fractional amounts of shares to the one or more investors;
transmit instructions to the financial transactions module, wherein
the financial transactions module comprises at least one processor configured to automatically receive and disburse payments, to automatically collect payments from each of the one or more investors based on their respective bids and respective allocated shares; and automatically disburse payments to acquisition company for the shares in the incubator financial entity; and generate the payout to the one or more owners automatically when the payout triggering event is met” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity such as commercial interactions because these steps further describe the underlying process. The additional elements of a securities planning module, an administration module and a financial transactions module each comprising at least one processor are broadly interpreted to comprise generic computer components suitably programmed to perform their respective functions. These additional elements perform their respective 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 claims 28, 35 and 41, the steps “wherein the administration module is further configured to
transmit to a special receiver address on the distributed ledger transactions corresponding to the one or more bids for the one or more shares of the incubator financial entity, shares allocated to each of the one or more investors and information corresponding to each of the one or more investors;
wherein each transaction comprises compiled code corresponding to a smart contract, each smart contract comprising immutable self-executing code configured to execute in response to one or more conditions relating to the shares;
wherein the self-executing code of each smart contract is configured to:
detect recordation of the one or more bids, shares allocated to each of the one or more investors and information corresponding to each of the one or more investors;
generate sets of terms and conditions between each of the one or more investors and the special purpose acquisition company for disposition of the shares of the incubator financial entity based on the structure of the initial public offering and the shares allocated to each investor;
communicate each respective set of terms and conditions to each of the third networked nodes corresponding to each of the investors to initialize each respective set of terms and conditions associated with each investor;
detect the payout triggering event relating to the initial public offering;
trigger a plurality of electronic actions in response to detecting the payout triggering event, the plurality of electronic actions including
transmitting a payout communication to each of the one or more networked nodes associated with the one or more investors; and
transmitting instructions to the financial transactions module to execute a payout to each of the one or more investors based on the respective terms and conditions associated with each of the one or more investors; and
record execution of each smart contract to the distributed ledger” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity such as commercial interactions, because these steps further describe the functions of the administration module in the underlying process. The additional elements of compiled codes corresponding to the smart contract, each smart contract comprising immutable self-executing code are broadly interpreted to comprise generic computer components suitably programmed to perform their respective functions. These additional elements perform their respective 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 claim 29, the step “wherein the securities planning module, the administration module, and the financial transactions module are separate from the distributed ledger” under the broadest reasonable interpretation, is a further refinement of methods of organizing human activity such as commercial interactions, because this step further describes the attributes of the modules used in the underlying process. The additional elements of the various modules (in the claim) are broadly interpreted to comprise generic computer components suitably programmed to perform their respective functions. These additional elements perform their respective 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 claims 30, 36 and 42, the step “wherein the payout triggering event is completion of the initial public offering for the company seeking capital” under the broadest reasonable interpretation, is a further refinement of methods of organizing human activity such as commercial interactions, because this step further describes the intermediate/final step of the underlying process.
In claims 31, 37 and 43, the step “wherein the payout is a pro rata share of the proceeds of the initial public offering paid to the one or more owners of shares in the incubator financial entity” under the broadest reasonable interpretation, is a further refinement of methods of organizing human activity such as commercial interactions, because this step further describes the payout criterion in the intermediate step of the underlying process.
In claims 32, 38 and 44, the step “wherein a prior funding event comprises a prior initial public offering for establishment of a special purpose acquisition company to identify and acquire the company seeking capital” under the broadest reasonable interpretation, is a further refinement of methods of organizing human activity such as commercial interactions, because this step further describes an intermediate step of the underlying process.
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 17-22 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 claims recite a distributed networked computer system comprising a distributed ledger for performing at least one operation regarding managing funding among a company seeking capital, a special purpose acquisition company, one or more subscribers and several modules (listed in the claims), which is considered a judicial exception because it falls under the category of certain of methods of organizing human activity such as commercial and/or legal interactions including agreements in the form of contracts as discussed, which is considered a judicial exception because it falls under the category of certain of methods of organizing human activity such as commercial and/or legal interactions including agreements in the form of contracts as discussed in the rejection.
Funding of a company seeking capital is a fundamental economic practice. Initial Public Offerings using a special purpose vehicle company are a known economic practice for several decades. “receive notice via the second networked node of a funding event comprising establishment of a special purpose vehicle company configured to hold assets of the
company seeking capital and establishment of an incubator financial entity to manage an initial public offering to fund the company seeking capital;
determine an amount of funding for establishing the incubator financial entity and funding activities associated with the initial public offering;
generate a first message related to an initial subscriber offering to fund the company seeking capital and the incubator financial entity;
send the first message to the one or more third networked nodes associated with the one or more subscribers of the distributed networked computer system;
receive, from the one or more third networked nodes, an expression of interest for one or more shares of the incubator financial entity from the one or more subscribers via the one or more third networked nodes;
determine the initial public offering of investment shares in the company seeking capital based in part on the expression of interest received from the one or more subscribers via the one or more third networked nodes:
generate a second message associated with establishing the incubator financial entity to manage the initial public offering:
receive bids to purchase funding tokens for shares of the incubator financial entity via the one or more third networked nodes from the one or more subscribers in response to the second message;
record bids for the funding tokens and respective allocated tokens to the distributed ledger;
generate, based on the initial public offering, a third message related to the initial public offering;
send the third message to the one or more third networked nodes associated with one or more owners of the funding tokens; wherein the message comprises informing the one or more owners that a pro rata share of the raised funds is payable after the initial public offering;
generate one or more smart contracts accessible to the one or more networked nodes, wherein the smart contract comprises
terms comprising a payout triggering event; and
a plurality of predetermined electronic actions for generating a smart contract output when the payout triggering event is met, wherein the smart contract is configured to generate a payout to the one or more owners automatically when the payout event is triggered,
record execution of the smart contract to the distributed ledger; and
execute the smart contract through the terms of the smart contract to generate the payout to the one or more owners automatically when the payout triggering event is met” considered collectively as an ordered combination is a form of commercial and/or legal interaction including fulfillment/resolution of agreements in the form of contracts.
That is, other than, a distributed network computer system comprising a distributed ledger, a first networked node associated with the company seeking capital, a second networked node associated with the special purpose acquisition company, a (distributed ledger technology) DLT platform on which one or more smart contracts and one or more private data sharing channels are implemented, one or more third networked nodes respectively associated with the one or more subscribers, one or more processors, and a computer readable storage medium, funding tokens, a special receiver address on the distributed ledger transactions, a securities planning module, an administration module, and a financial transactions module, smart contracts comprising immutable self-executing code and electronic actions, nothing in the claim precludes the steps from being performed as a method of organizing human activity. The additional elements in the claims are all broadly interpreted to correspond to generic components suitably programmed to perform their respective functions. 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, as discussed in the rejection). The additional elements in the claims are used as tools in their ordinary capacity to apply the abstract idea. Accordingly, the claim recites an abstract idea.
The alleged claimed improvements such as “Ensuring correctness and determinism of state transitions tied to discrete, ledger-recorded events (bid recordation, allocations, IPO completion). Enforcing isolation between security design/configuration and ledger-visible transactional effects via module separation and private data channels. Eliminating human-in-the-loop payout execution by integrating compiled smart-contract code and a financial transactions module configured to execute automatically upon detection of the triggering event. and recording all execution immutably to the ledger to create a verifiable audit trail resistant to tampering or accidental exceptions” are due to improvements in the abstract idea of a smart contract execution of funding of a company seeking capital using the additional elements as tools in their ordinary capacity. 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). Therefore, the Applicants’ arguments are not persuasive.
Response to Applicants’ arguments regarding Step 2A – Prong two:
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 a distributed network computer system comprising a distributed ledger, a first networked node associated with the company seeking capital, a second networked node associated with the special purpose acquisition company, a (distributed ledger technology) DLT platform on which one or more smart contracts and one or more private data sharing channels are implemented, a securities planning module, an administration module, and a financial transactions module, one or more third networked nodes respectively associated with the one or more subscribers, one or more processors, and a computer readable storage medium, funding tokens, a special receiver address on the distributed ledger transactions, smart contracts comprising immutable self-executing code and electronic actions to perform all the steps. A plain reading of Figures 2A-3, and 6A-6B and descriptions in at least associated paragraphs including paragraphs [0097] – [0114] and [0121] – [0146] reveals that a computing system comprising a distributed ledger, the networked nodes associated with the various entities, a DLT platform on which one or more smart contracts and one or more private data sharing channels, are implemented are generic computer components suitably programmed to perform their respective functions. The one or more processors may be generic processors such as microprocessors, gate arrays, array processors, and secure microprocessors, etc. The one or more memories may be generic memories suitably programmed to store the associated data/ information. The modules including a securities planning module, an administration module, and a financial transactions module, (the modules listed in the dependent claims) including the securities planning module, the administration module, and the financial transactions module, are broadly interpreted to comprise generic computer components suitably programmed to perform their respective functions. The distributed ledger, the one or more networked nodes, funding tokens, and the smart contracts (comprising immutable self-executing code) are all generic computer components suitably programmed to perform their respective functions. The special receiver addresses (in the dependent claims) on the distributed ledger transactions are suitably programmed generic addresses associate with their respective transactions. The electronic actions are suitably programmed generic electronic actions. As discussed in the rejection, these additional elements are generic computer components suitably programmed to apply the abstract idea. Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. These 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, the claims are directed to an abstract idea.
The claimed features, may at best, be characterized, as an improvement in the abstract idea of a smart contract execution of funding of a company seeking capital, using suitably programmed generic computer components as tools in their normal capacity. The alleged advantages such as “The smart contract architecture and private data channels enforce correctness, determinism, and isolation in a multi-node DLT environment; compiled code routed via a special receiver address ensures consistent deployment; and automatic payout execution reduces latency, human error, and the need for trusted intermediaries. These are improvements to the functioning of distributed computer systems and smart-contract platforms.
"The operations are performed using a specific DLT platform at each node, with private channels and compiled smart-contract code that executes within the constraints of the underlying ledger protocol. The special receiver address, private channels, and immutable recording are not off-ledger abstractions; they are protocol-bound mechanisms within the particular distributed computing environment; and The claims require specific data flows (compiled code to special receiver addresses), structured module interactions (securities planning, administration, financial transactions), and deterministic execution recorded immutably …. imposing concrete, non-trivial constraints on how the processes are implemented” are due to improvements in the abstract idea of a smart contract execution of funding of a company seeking capital. 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 in their normal 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. Therefore, the Applicants’ arguments are not persuasive.
Response to Applicants’ arguments regarding Step 2B
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) 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.
The claimed features including “the distributed arrangement of issuer/SPAC, incubator/SPV, and subscribers, each operating a DLT platform with private data sharing channels, interacting via compiled smart-contract code routed to a special receiver address, with deterministic event detection and automatic payout via a financial transactions module ….. A special receiver address on the distributed ledger to which compiled smart-contract code is transmitted, ensuring controlled deployment and on-ledger traceability …. Immutable self-executing code configured to detect specific on-ledger events (bids/allocations/payout triggers) and to automatically trigger electronic actions, including payout instructions to the financial transactions module …. Separation of security design from ledger-executing components (module/ledger separation), coupled with immutably recorded execution to ensure verifiability and correctness” may be considered an improvement in the abstract idea of a smart contract execution of funding of a company seeking capital, using the additional elements and their combination in their normal capacity, to apply the abstract idea. 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). The Applicants’ invention is a business solution, using computers, to a problem rooted in an abstract idea.
The Applicant’s claims do not involve any improvements to another technology, technical field, or improvements to the functioning of the computer itself. The alleged advantages of the Applicant’s invention such as “correctness, isolation, and automated execution challenges in distributed ledgers ….. a particular implementation for smart-contract-based payout orchestration across multiple nodes through private channels and special receiver addresses, yielding deterministic, immutable execution without human intervention ….. smart contract execution correctness, deterministic on-ledger event handling, isolation via private channels, and automatic payout by a transactions module” are due to an improvement in the smart contract execution of funding of a company seeking capital, using the additional elements and their combination as tools in their ordinary capacity. The Applicant’s claims do not recite sufficient subject matter to take them from being in the realm of what is encompassed as an abstract idea into patentable subject matter and fail to add significantly more to “transform” the nature of the claims. Therefore, the 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) Wolfberg; Darren (US Pub. 2025/0069144 A1) discloses methods, systems and apparatus for using blockchain distributed ledgers to build and maintain infrastructure projects utilizing smart meters and smart contracts to increase information flow in the securitization of digital securities which are issued to fund and administer the infrastructure projects and to provide transparent and predictable returns to investors and efficient capital formation and infrastructure management to the digital security Issuers.
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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
December 7, 2025