DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Status of Claims
Claims 19-23, 25-26, 28-30, 34-40 and 42-43 are pending in this application per claim amendments and remarks filed on 02/02/2026, wherein Claims 19, 20 and 26 have been amended, and Claims 1-18, 24, 27, 31-33 and 41 are shown as cancelled. Claims 19 and 20 are independent claims reciting system and non-transitory computer readable medium claims. Claims 21-23/25-26/28-30/34-37/42-43 and 38-40 are respective dependent claims.
This Office Action is a final rejection in response to the claim amendments and the remarks filed on 02 FEBRUARY 2026 for its original application of 26 AUGUST
2022 that is titled: “Digital Status Tracking of Funds”.
Accordingly, amended claims 19-23, 25-26, 28-30, 34-40 and 42-43 are now being rejected herein.
Claim Rejections - 35 USC §101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
(NOTE: Latest ‘amendments to the claims’ filed by the Applicant on 02/02/2026 are shown as bold and underlined additions, and all deletions may not be shown, or may not be underlined when stricken through. Underlined amendments to the claims that are shown below are from previously submitted claim amendments by the Applicant.)
Claims 19-23, 25-26, 28-30, 34-40 and 42-43 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (abstract idea) without significantly more, wherein Claims 19 and 20 are independent system and non-transitory computer readable medium claims respectively.
Exemplary Analysis.
Claim 19: Ineligible.
The claim recites a series of steps. The claim is directed to a system reciting a series of steps, which is a statutory category of invention (Step 1 -- YES).
The claim is analyzed to determine whether it is directed to a judicial exception.
The claim recites the limitations of: accepting a request from a pre-registered buyer to transfer funds to a pre-registered beneficiary, the funds being in settlement of at least a portion of the real estate transaction; pre-verifying the beneficiary by validating a link of the beneficiary to a valid bank account; pre-verifying the buyer by validating a link of the buyer to a valid bank account and validating that the buyer's bank account includes sufficient funds to cover the settlement amount, wherein the pre-verified participants include the pre-verified beneficiary and buyer; initiating a corresponding payment request through one of a plurality of digital payment channels; decoding a first automated message as a confirmation of the initiation of the payment request; and decoding a second automated message as a completion of the payment request. In other words, the claim describes a procedure for closed loop payment processing. These limitations, as drafted, are steps of a system which perform a method that, under its broadest reasonable interpretation, covers performance of the limitations via a method of organizing human activity such as fundamental economic principles or practices (including hedging, insurance, mitigating risk), and/or commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations), and/or managing behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions), but for the recitation of generic computer/s and/or computer component/s such as the devices/ mobile devices. These limitations fall under the “certain methods of organizing human activity” group (Step 2A1 -- YES).
Next, the claim is analyzed to determine if it is integrated into a practical application. The claim recites additional elements of: wherein the real estate transaction portal is limited to pre-verified participants ……; receiving particulars of the real estate transaction through the interface, including a settlement amount, ……; on receipt of ……… the one of the plurality of digital payment channels, determining a first encoding of the first automated message and decoding, based on the identified first encoding, the first automated message at least part of the first human readable message ……… that indicates a confirmation of the initiation of the payment request; and updating in real time, a graphical status indicator showing at least part of the first human readable message and that is displayed ……… on the second and third system terminals, respectively; and on receipt of …….. one of the plurality of digital payment channels, determining a second encoding of the second automated message and decoding, based on the identified second encoding, the second automated message into a second human readable message that indicates a completion of the payment request; and updating in real time, the graphical status indicator showing at least part of the second human readable message to display ………… that the payment has been completed; wherein the automated messages are in Society for Worldwide Interbank Financial Telecommunications (SWIFT) or International Standards Organization (ISO) encoding, wherein the first automated message comprises a PAIN.001 message (Payments Initiation message under ISO 20022 in respect of a credit transfer initiation) and the second automated message comprises a PAIN.002 message (Payments Initiation message under ISO 20022 in respect of a payment status report), wherein the PAIN.002 message comprises a transaction status field indicating whether the payment has been accepted, and wherein the graphical status indicator is updated: responsive to the PAIN.001 message, to display a first visual indication that the payment has been sent, wherein the first visual indication comprises a change in at least one of colour or illumination of a first symbol within the first visual indication; and then responsive to the transaction status field of the PAIN.002 message indicating the payment has been accepted, to display a second visual indication that the payment has been received, wherein the second visual indication comprises a change in at least one of colour or illumination of a second symbol within the graphical status indicator. These additional elements are considered extra-solution activities. The payment channels, interfaces, terminals and devices for graphical status indicator in the steps are recited at a high level of generality, i.e., as generic processors performing generic computer/s functions of processing data. These generic processors are no more than mere instructions to apply the exception using generic computer/s and/or computer component/s. 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. Thus, the claim is directed to the abstract idea (Step 2A2 -- NO).
Next, the claim is analyzed to determine if there are additional elements in this claim that individually, or as an ordered combination, ensure that the claim amounts to significantly more than the abstract ideas (whether claim provides inventive concept). As discussed with respect to Step 2A2 above, the additional elements in the claim amount to no more than mere instructions to apply the exception using generic computer/s and/or computer component/s. The same analysis applies here in Step 2B, i.e., mere instructions to apply an exception using a generic computer and/or computer components over a network cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. Because the additional elements described above were considered to be extra-solution activities in Step 2A, they are re-evaluated in Step 2B to determine if they are more than what is well-understood, routine and conventional in the field. The disclosure does not provide any indication that these devices (processors) are anything other than generic processors and the Symantec, TLI, and OIP Techs. court decisions (MPEP 2106.05 (d) (II)) indicate that mere collection or receipt of data over a network is a well‐understood, routine, and conventional function when it is claimed in a merely generic manner (as it is here). Also, paras [0073]-[0078] of the Applicant’s own Specification describe these additional elements performing extra-solution activities ---
{“[0073] FIG. 13 provides a summary of a method 1300 for digital status tracking of funds, according to an example embodiment. To begin, a request for funds transfer is received through a real estate transaction portal (block 1310). The payment request is initiated through a digital payment channel connected to (in communication with) the portal (block 1320). A first automated message is received (see, e.g., PAIN 001 described above) (block 1330). A graphical status indicator is displayed in real time on the portal to show the initiation (block 1340). This graphical status indicator is updated in real time (block 1360) to show completion of the payment once the second automated message is received (see, e.g., PAIN 002 described above) (block 1350). …………………………………………………………………………………………………………………………..
[0074] Various types of graphical status indicators may be provided. Although radio-button style indicators are shown along a simplified timeline in the sample screen shots, it will be appreciated that this could likewise be any type of status bar or other type of graphical symbol readily understood to end users. Preferably, the symbols use at least one colour that is converted (or filled in) when the status is updated. There may be other status indications besides "initiated" and "confirmed" or "received". For example, these could include "delayed" or "error" messages10 or other "flagged" type indications. These may generated in response to payment channel messages or in the absence of payment channel messages (e.g. if a period of time has elapsed without a message or an expected deadline has passed). Further, the system may provide further detail on the status as determined from the payment messages, limited only by the information conveyed in such messages. In addition to PAIN 001 and PAIN 002 messages, other payment messages may be received and decoded by the system. Further, the decoding may include filling in truncated information based on what is already known from the transaction, account and party particulars. This may be particularly relevant for traditional EFT (SWIFT) messages, which included character limits. ………………………………………………………………..
[0075] It will be appreciated that different graphical status indicators may be provided to each party (or representative) separately. For example, errors may be flagged differently for payees vs. payors and different corrective or informative options may be presented. ………………………..
[0076] Further, it will be appreciated that in addition to graphical status indicators, status updates may directly notified to end users using various communication channels, such as email or text message, or by providing notifications in another application, such as an online banking application. …………………………………………………………………………………………………………………………….
[0077] The foregoing examples in FIGS. 6-12 are illustrative of an embodiment within a multi-functional real estate transaction portal (everything in one place). It will be appreciated that the payment status tracker may be provided as a standalone application, and the end users need not include all parties described above, but may be limited in some embodiments to just the payor or just the payee, as the case may be. ……………………………………………………………………
[0078] Referring now to FIG. 14, there is shown a block diagram 1400 of the system for digital status tracking of funds illustrating the technology stack used to implement the system, according to an example embodiment. More particularly, a browser 1402 runs on the system terminal 110 and is used to display the interfaces as shown in FIGS. 6-12. The browser 1402 implements the user interface by running React.JS 1404 and the Material UI component library 1406.”} ---
and indicate that the concept described by the extra-solution additional elements is conventional. Accordingly, a conclusion that the aforementioned extra-solution additional elements are well-understood, routine and conventional activity is supported under Berkheimer options 2 and 3, respectively.
Viewing the limitations as an ordered combination does not add anything further than looking at the limitations individually. When viewed either individually, or as an ordered combination, the additional elements do not amount to a claim as a whole that is significantly more than the abstract idea itself. Therefore, the claim does not amount to significantly more than the recited abstract idea (Step 2B -- NO), and the claim is not patent eligible.
The analysis above applies to all statutory categories of the invention including independent non-transitory computer readable medium Claim 20, which perform the steps similar to those of the independent system Claim 19. And the limitations of newly added Claims 38-40 further narrow the independent non-transitory computer readable medium Claim 20 with additional steps and limitations. Furthermore, the limitations of dependent system Claims 21-23, 25-26, 28-30, 34-37 and 42-43, further narrow the independent system Claim 19 with additional steps and limitations (e.g., sending messages, decoding, encoding, displaying message/s, receiving particulars of the real estate transaction, pre-verified by validating a link, transfer of funds, message comprises a transaction status field………, to display a first visual indication that the payment has been sent,…………. etc.), and do not resolve the issues raised in rejection of the independent system Claim 19.
Therefore, said Claims 19-23, 25-26, 28-30, 34-40 and 42-43 are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter.
Response to Arguments
Applicant's claim amendments and remarks (on pages 8-11), both dated 02 FEBRUARY 2026, with respect to the rejection of amended Claims 19-23, 25-26, 28-30, 34-40 and 42-43 have been carefully considered, but they are not persuasive and do not put these amended claims in a condition ready for Allowance. Thus, the rejection of amended Claims 19-23, 25-26, 28-30, 34-40 and 42-43 under 35 USC 101, as described above, is being maintained herein with some modifications in this Office Action, where needed to provide clarification in response to the Applicant’s claim amendments and remarks by maintaining the 101 rejection in response to the Applicant’s claim amendments of 02/02/2026).
In response to the Applicant’s 02/02/2026 arguments traversing 101 rejection, Examiner respectfully disagrees. Examiner notes that the only conversion is recited in dependent Claim 26 as {“wherein the decoding of the first and second automated messages comprises conversion of one encoding to another.”}. Furthermore, it was noted in para 14. below that “encoding and decoding” are well known and not a technological improvement. Additionally, Examiner notes that the claims listing of 02/02/2026 does not recite synonyms for “conversion”, like modify, arrange, rearrange, etc. therein.
In further response to the Applicant’s 02/02/2026 arguments traversing 101 rejection, Examiner respectfully disagrees. Examiner notes that SWIFT protocol that includes PAIN messages have been well-defined decades ago per para 14. below, and the “updating” of PAIN messages is not a technological invention; wherein “updating” refers to change of color as in --- {“comprises a change in at least one of colour or illumination of a first symbol within the first visual indication”}, and these limitations are at best a business solution, but it is not a technological solution (which will overcome the 35 USC 101 rejection).
Applicant’s citation of Example 42 in Remarks of 02/02/2026 is non-persuasive, because the claims at issue in Example 42 are readily distinguishable over the instant claims. In Example 42, Claim 1 the claim as a whole integrates the method of organizing human activity into a practical application. Specifically, the additional elements recite a specific improvement over prior art systems by allowing remote users to share information in real time in a standardized format regardless of the format in which the information was input by the user. Additionally, the instant claims do not attempt to solve an unconventional technological solution. Using the processor as a tool to implement the abstract idea and the way the information is processed does not make it less abstract. Examiner also incorporates previous answers given in para 15. with respect to Example 42 citation.
In response to the Applicant’s RCE 10/02/2025 arguments traversing 101 rejection, Examiner respectfully disagrees. Examiner notes that encoding and decoding technology is well-known in the art (see google search on this topic attached herewith as Appendix), and the instant application does not show an improvement in this technology. Furthermore, Examiner notes that PAIN messages in SWIFT payments are also part of well-known and published ISO 20022 standard (see google search on this topic attached herewith as Appendix), and thus the instant application is not a novel way to communicate these PAIN messages.
NOTE: Examiner notes that the previous Responses to Arguments from more than one previous Office Action/s are incorporated herein as described below, some of which may be similar to and repeated as RCE arguments on 10/02/2025.
In response to the Applicant’s 04/25/2025 arguments citing similarity to example 42, Claim 1, Examiner respectfully disagrees. Examiner notes that Example 42, Claim 1 was found eligible for patent because {“The claim recites a combination of additional elements including storing information, providing remote access over a network, converting updated information that was input by a user in a non-standardized form to a standardized format, automatically generating a message whenever updated information is stored, and transmitting the message to all of the users. The claim as a whole integrates the method of organizing human activity into a practical application. Specifically, the additional elements recite a specific improvement over prior art systems by allowing remote users to share information in real time in a standardized format regardless of the format in which the information was input by the user.”}; Examiner notes that the instant application instead is similar to Example 42, Claim 2 which was not found eligible because {“The claim as a whole merely describes how to generally “apply” the concept of storing and updating patient information in a computer environment. The claimed computer components are recited at a high level of generality and are merely invoked as tools to perform an existing medical records update process. Simply implementing the abstract idea on a generic computer is not a practical application of the abstract idea.”} Thus, the instant application’s claims as a whole merely describes how to generally “apply” the concept of updating records in a computer environment. Therefore, the instant application’s claims are still rejected under 35 USC 101.
In response to the Applicant’s arguments of 04/25/2025 against the rejection under 35 USC 101, under the 2019 PEG, Step 2A, integration into a practical application (prong two) requires an additional element(s) or a combination of additional elements in the claim to apply, rely on, or use the judicial exception in a manner that imposes a meaningful limit on the judicial exception, such that the claim is more than a drafting effort designed to monopolize the exception. Limitations that are not indicative of integration into a practical application are those that are mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea --- see MPEP 2106.05(f). The instant claims do not attempt to provide an unconventional technological solution. The payment channels, interfaces and devices for graphical status indicator are recited as generic processor/s as a tool to implement the abstract idea and the way the information is processed and displayed does not make it less abstract. The claimed use of generic processors (as payment channels, interfaces and devices for graphical status indicator) recited at a high level of generality is an attempt to limit the abstract idea to a particular technological environment. 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.
Examiner respectfully disagrees with further arguments of 04/25 traversing the 101 rejection. Also, Examiner clarifies that the instant application is nothing more than an improvement of an abstract idea, wherein using technology/ computers to execute an abstract idea is at most an improvement to the abstract idea.
In response to the Applicant’s arguments of 04/25/2025 against the rejection under 35 USC 101, Step 2B, Examiner respectfully disagrees. Also, Examiner notes that if the claims are directed to a patent-ineligible concept, for Step 2B we must “look with more specificity at what the claim elements add, in order to determine ‘whether they identify an “inventive concept” in the application of the ineligible subject matter’ to which the claim is directed.” Affinity Labs of Texas, LLC v. DIRECTV, LLC, 838 F.3d 1253, 1258 (Fed. Cir. 2016) (quoting Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d 1350 (Fed. Cir. 2016)). We look to see whether there are any “additional features” in the claims that constitute an “inventive concept,” thereby rendering the claims eligible for patenting even if they are directed to an abstract idea. Alice, 573 U.S. at 221. Examiner notes that Applicant’s claims as a whole, including claim amendments of 04/25/2025 (as well as on 08/01/2024 previously), do not amount to significantly more than the abstract idea itself. The processor limitations in the instant application do not add significantly more, because they are simply an attempt to limit the abstract idea to a particular technological environment. A generic recitation of a processor performing its generic computer functions does not make the claims less abstract. Also, the use of a particular machine and transformation to a different state or thing are not relevant to the instant application.
A claim may be found to be eligible if it integrates a judicial exception into a practical application as cited by Applicant. However, examiner notes that "claiming the improved efficiency inherent with applying the abstract idea on a computer" does not provide an inventive concept (see MPEP §2106.05(f)(2).) Claiming improved data processing efficiency inherent with applying any improvement to the judicial exception itself on a computer does not provide an inventive concept. The claims do not integrate the judicial exception into a practical application.
The Court gave examples, which included an improvement to another technology or technical field; improvement to the function of the computer itself; or some other meaningful limitation beyond generally linking the use of an abstract idea to a particular technological environment. Such as in Diamond v. Diehr, the claims were found statutory in which the Arrhenius equation is used to improve a process of controlling the operation of a mold in curing rubber parts.
As found by the courts “In order for the addition of a machine to impose a meaningful limit on the scope of a claim, it must play a significant part in permitting the claimed method to be performed, rather than function solely as an obvious mechanism for permitting a solution to be achieved more quickly . . ..” SiRF Tech., Inc. v. Int'l Trade Comm'n, 601 F.3d 1319, 1333 (Fed. Cir. 2010); see also Content Extraction, 2013 WL 3964909, at *12 (“the mere use of a computer to more quickly and efficiently . . . accomplish a given task does not create meaningful limitation on an otherwise abstract and wide-ranging concept”).
Examiner notes that the processor limitations and the claim as a whole do not add significantly more than the abstract idea itself, because the claim does not amount to an improvement to the functioning of a computer itself; and the claim does not move beyond a general link of the use of an abstract idea to a particular technological environment. A generic recitation of a processor/device performing its generic computer functions does not make the claims less abstract.
Examiner submits that under the current 35 USC 101 examining practice, the existence of such novel features would still not cure the deficiencies with respect to the abstract idea. See for example: Ultramercial, Inc. v. Hulu, LLC, 112 USPQ2d 1750, U.S. Court of Appeals Federal Circuit, No. 2010-1544, Decided November 14, 2014, 2014 BL 320546, 772 F.3d 709, Page 1754 last two ¶ : “We do not agree with Ultramercial that the addition of merely novel or non-routine components to the claimed idea necessarily turns an abstraction into something concrete”. Indeed, in this in instant case, the limitations simply narrow or limit the abstract idea without providing anything significantly more than the abstract idea itself.
For these reasons (as stated above), the rejection under 35 USC § 101 directed to non-statutory subject matter set forth in this office action is maintained.
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office Action. Accordingly, THIS ACTION IS MADE FINAL. See at least 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.
The prior art made of record and not relied upon, listed in Form 892, that is considered pertinent to the Applicant's disclosure and review for not traversing already issued patents and/or claimed inventions by the claims of the current invention of the Applicant. Please Note that Form 892 contains more references than those cited in the rejection above under 35 USC 103, and all the references cited on said Form 892 are relevant to this application that form a part of the body of prior art.
Any inquiry concerning this communication or earlier communications from the Examiner should be directed to Sanjeev Malhotra whose telephone number is (571) 272-7292. The Examiner can normally be reached during Monday-Friday between 8:30-17:00 hours on a Flexible schedule.
Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, the Applicant is encouraged to contact the Examiner directly.
If attempts to reach the Examiner by telephone are unsuccessful, the examiner’s supervisor, Abhishek Vyas, can be reached on (571) 270-1836. The facsimile/fax phone number for the organization, where this application or proceeding is assigned, is 571-273-8300.
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Electronic Communications
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/S.M./
Examiner, Art Unit 3691
sanjeev.malhotra@uspto.gov
/ABHISHEK VYAS/Supervisory Patent Examiner, Art Unit 3691
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