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 .
Response to Amendment
The examiner acknowledges applicant’s arguments in the Response dated November 3, 2025 directed to the Non-Final Office Action dated August 5, 2025. Claims 1-20 are pending in the application and subject to examination as part of this office action.
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
The determination of subject matter eligibility under 35 USC 101, relies on the Mayo/Alice two-step analysis.
In step 1 of the analysis, the claims are evaluated to determine whether they fall within one of the four statutory categories (i.e., process, machine, manufacture, or composition of matter). In the present case, claims 1-8 are directed to a gaming establishment fund management system (i.e., a machine) claims 9-12 are directed to a gaming establishment front money handling system (i.e., a machine) and claims 13-20 are directed to a method (i.e., a process). The claims are, therefore directed to one of the four statutory categories.
Under prong 1 of step 2A, the examiner is directed to determine whether the claim recites a judicial exception. The claims are compared to groupings of subject matter that have been found by courts as abstract ideas. These groupings include
(a) Mathematical concepts—mathematical relationships, mathematical formulas or equations, mathematical calculations;
(b) Certain methods of organizing human activity—fundamental economic principles or practices (including hedging, insurance, mitigating risk); commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations); managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions); and
(c) Mental processes—concepts performed in the human mind (including an observation, evaluation, judgment, opinion).
Claim 1 recites (the abstract idea is underlined) a gaming establishment fund management system comprising:
a processor; and
a memory device that stores a plurality of instructions that, when executed by the processor following an occurrence of a request to complete, in association with a first amount of funds, a gaming establishment cashless transaction independent of any banking network, independent of any physical currency being manually handled and without accessing any external funding source, cause the processor to:
responsive to a gaming establishment fund management system account being associated with a second amount of funds that is less than the first amount of funds:
operate with a distinct gaming establishment front money handling system to determine if the gaming establishment fund management system account is associated with a gaming establishment front money account maintained by the gaming establishment front money handling system,
responsive to the gaming establishment fund management system account being associated with the gaming establishment front money account, communicate data associated with an authorization to complete the gaming establishment cashless transaction, wherein a difference between the first amount of funds and the second amount of funds is accessed from an amount of front money of the associated gaming establishment front money account, and
responsive to the gaming establishment fund management system account not being associated with the gaming establishment front money account and the gaming establishment fund management system account being associated with the second amount of funds that is less than the first amount of funds, communicate data associated with a denial to complete the gaming establishment cashless transaction.
Claim 9 recites (the abstract idea is underlined) a gaming establishment front money handling system comprising:
a processor; and
a memory device that stores a plurality of instructions that, when executed by the processor, cause the processor to:
maintain a gaming establishment front money account, and
responsive to a deposit of an amount of front money in the gaming establishment front money account:
determine if the gaming establishment front money account is associated with any gaming establishment fund management system accounts maintained by a gaming establishment fund management system operating independent of the processor, and
responsive to the determination being that the gaming establishment front money account is associated with a gaming establishment fund management system account, cause a transfer of the amount of front money to the gaming establishment fund management system account.
Claim 13 recites (the abstract idea is underlined) a method of operating a gaming establishment fund management system, the method comprising:
following an occurrence of a request to complete, in association with a first amount of funds, a gaming establishment cashless transaction independent of any banking network, independent of any physical currency being manually handled and without accessing any external funding source:
causing a processor to exchange data with a computing components of a distinct gaming establishment front money handling system to determine if a gaming establishment fund management system account is associated with a gaming establishment front money account maintained by the gaming establishment front money handling system,
responsive to the gaming establishment fund management system account being associated with the gaming establishment front money account and the gaming establishment fund management system account being associated with a second amount of funds that is less than the first amount of funds, causing the processor to cause a communication of data associated with an authorization to complete the gaming establishment cashless transaction, wherein a difference between the first amount of funds and the second amount of funds is accessed from an amount of front money of the associated gaming establishment front money account, and
responsive to the gaming establishment fund management system account not being associated with the gaming establishment front money account and the gaming establishment fund management system account being associated with the second amount of funds that is less than the first amount of funds, causing the processor to cause a communication of data associated with a denial to complete the gaming establishment cashless transaction.
The underlined portions of claim 1 recite the transfer of funds from accounts to complete a transaction if there are sufficient funds and denying a transaction if there are insufficient funds. These steps fall under the category of certain methods of organizing human activity, specifically, fundamental economic practices. In addition, the claim limitations recite a method or organizing human activity by conducting financial transactions between parties.
Under prong 2 of Step 2A, the examiner considers whether additional elements integrate the abstract idea into a practical application. To do so, the examiner looks to the following exemplary considerations, looking at the elements individually and in combination:
• an additional element reflects an improvement in the functioning of a computer, or an improvement to other technology or technical field;
• an additional element that applies or uses a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition (not considered relevant to the present claims);
• an additional element implements a judicial exception with, or uses a judicial exception in conjunction with, a particular machine or manufacture that is integral to the claim;
• an additional element effects a transformation or reduction of a particular article to a different state or thing; and
• an additional element applies or uses 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.
The additional elements in the present claims are: a processor, a memory device, a distinct gaming establishment front money handling system, a gaming device, an electronic gaming machine, a gaming table component, a gaming table, a gaming establishment fund management system, an input device, and a point-of-sale retail terminal. The additional elements do no integrate the judicial exception into a practical application. In particular, the additional elements do not reflect an improvement in the functioning of a computer, or an improvement to other technology or technical field. The additional elements do not implement a judicial exception with, or uses a judicial exception in conjunction with, a particular machine or manufacture that is integral to the claim. The additional elements do not effect a transformation or reduction of a particular article to a different state or thing. The additional elements do not apply or use the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment. The additional elements merely use general purpose computer components as tools to perform an abstract idea. Accordingly, the additional elements do not integrate the abstract idea into a practical application because they does not impose any meaningful limits on practicing the abstract idea.
Under step 2B, the examiner evaluates whether the additional elements amount to significantly more than the judicial exception itself. The examiner considers if the additional elements:
• add a specific limitation or combination of limitations that are not well-understood, routine, conventional activity in the field, which is indicative that an inventive concept may be present; or
• simply appends well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception, which is indicative that an inventive concept may not be present.
The present claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. The additional elements are well-understood, routine, and conventional:
a processor, a memory device (Vagner, US 2015/0302482 A1, a general computer can include a memory, a processor, input/out components, and other components that are common for general computers, all of which are well known in the art [0099]);
a distinct gaming establishment front money handling system, a gaming establishment fund management system (Douglas et al., US 2003/0069648 A1, Computer-based financial management systems are well known prior to the present invention and are available from many sources [0014])
a gaming device, an electronic gaming machine, a gaming table component, a gaming table (Borissov et al., US 2015/0243136 A1, gaming machines 22, mobile gaming devices 124 such as hand-held or tablet devices, or other devices such as electronic gaming tables and the like, as are well known [0012])
an input device (Walker et al., US 2004/0082384 A1, components well known in the art, specifically a processor, Ram and ROM, a data storage device, a random number generator, a communication port, a hopper controller, a hopper, a video controller, a touch screen, a coin acceptor controller, a coin acceptor, a bill acceptor controller, a bill acceptor, a reel controller, reels, an input device, an output device and a sensor [0058]), and
a point-of-sale retail terminal (Lee et al., US 2016/0063526 A1, each merchant that accepts a payment card has on their premises at least one card swiping machine or point of sale device 380, of a type well known in the art, for initiating customer transactions [0058]).
Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept.
As a result, the claims are not directed to patent eligible subject matter.
Prior Art
There are currently no prior art rejections against claims 1-20.
Response to Arguments
Applicant's arguments regarding the rejections under 35 USC 101 filed November 3, 2025 have been fully considered but they are not persuasive.
Applicant states:
Applicant respectfully submits that claimed additional elements of a gaming establishment fund management system and a distinct gaming establishment front money handling system are not generic, conventional, or well-known in accordance with MPEP 2106.05(d); MPEP 2106.07(a); Berkheimer v. HP, Inc., 881 F.3d 1360, 1368, 125 USPQ2d 1649, 1654 (Fed. Cir. 2018)). While the Office cites to U.S. 2003/0069648 to Douglas et al. ("Douglas") for support that such additional elements are well-understood, routine, and conventional, Applicant submits that Douglas does not disclose (let alone establish as well-understood, routine or conventional) any of a gaming establishment fund management system, a gaming establishment front money handling system or a gaming establishment fund management system account. That is, while Douglas mentions that "[c]omputer-based financial management systems are well known prior to the present invention and are available from many sources" (see paragraph [0014]), without including any disclosure of any gaming establishment fund management systems, any gaming establishment fund management system accounts, any front money or any gaming establishment front money accounts, Douglas cannot establish that a gaming establishment fund management system or a distinct gaming establishment front money handling system are generic, conventional, or well-known. (Response [p. 8])
Under prong 2 of Step 2A, the examiner considers whether additional elements integrate the abstract idea into a practical application. The additional elements of the present application are a processor, a memory device, a distinct gaming establishment front money handling system, a gaming device, an electronic gaming machine, a gaming table component, a gaming table, a gaming establishment fund management system, an input device, and a point-of-sale retail terminal. The distinct gaming establishment front money handling system, along with the other additional elements, are used to carry out the abstract idea. Applicant appears to mix the additional elements with the abstract idea and expect a reference that shows all the elements together.
In addition, under Step 2B, the examiner provided support that such additional elements are well-understood, routine, and conventional.
Applicant further states:
Applicant further submits that the Office's reliance on the sentence from paragraph [0013] of the specification that "the system provides that one or more front money accounts are connectable to the different accounts of the eco-system of disparate components across one or more different sites and/or one or more different gaming and non-gaming vertical boundaries to enable improved access to funds deposited into a front money account (which certain users may be familiar with) to facilitate use of such funds at the one or more different sites and/or with the one or more different gaming and non-gaming vertical boundaries (which those certain users may not be familiar with but could benefit from)" to conclude that the claims "address business problems that are applied to a computer network" (see page 11 of Office Action) fails to appreciate the technical improvements achieved by the claims. That is, in view of the friction encountered by certain users in having certain gaming establishment cashless transactions (which themselves overcome the documented problems with the use of cash and ticket vouchers within a gaming establishment) at a gaming establishment device declined due to inadequate funds in a gaming establishment fund management system account to complete a requested transaction, the claimed gaming establishment fund management systems and methods access an amount of funds from a gaming establishment front money account to facilitate such transactions. In other words, rather than operating how certain prior systems operated by denying a requested transaction if a single funding source lacks the requested amount of funds to complete the requested transaction, the claimed gaming establishment fund management systems and methods coordinate obtaining the requested amount of funds from multiple funding sources (i.e., front money from a front money account and funds from a gaming establishment fund management system account) to complete the requested transaction and thus avoid the reliance on cash and ticket vouchers. Such a configuration results in operational efficiencies via the completion of more gaming establishment cashless transactions and thus less processing resources dedicated to failed cashless transactions or operationally inefficient cash and ticket voucher transactions. (Response [pp. 8-9])
The abstract ideas do not reflect an improvement in the functioning of a computer, or an improvement to other technology or technical field. The decision to organize a network to carry out the abstract idea is not understood to be a technical problem. Instead, it appears to be a business decision to address business problems that are applied to a computer network. As such, the present claims do not improve the functioning of a computer or improve another technology or technical field.
The examiner maintains that the present claims are not directed to patent eligible subject matter.
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to WERNER G GARNER whose telephone number is (571)270-7147. The examiner can normally be reached M-F 7:30-15:30 EST.
Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, DAVID LEWIS can be reached at (571) 272-7673. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/WERNER G GARNER/Primary Examiner, Art Unit 3715