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 .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 17 March 2026 has been entered.
Status of Claims
This action is in reply to the communication(s) filed on 17 March 2026.
Claims 1, 12 and 20 are amended.
Claim(s) 1-20 is/are currently pending and have been examined.
Response to Arguments
Applicant's arguments filed 17 March 2026 have been fully considered but they are not persuasive.
Claim Interpretations
Examiner acknowledges that while the specification does disclose that data may be collected from different third-party providers that are not the client, this does not change the fact that the phrase “a third-party service provider holding the account for the user” recited in Claims 8 and 17 may be the same entity as the “a client that submitted the electronic request” recited in Claims 9 and 18. Data collected may be from a plurality of different third-party providers while also having at least one of those providers be the same as the client that submitted the electronic request. This interpretation is not inconsistent with applicant’s specification “[0034] In one embodiment, a third-party 108 (e.g., a financial institution, a service provider, a customer, a client, and/or another entity) may provide a verification module 104 with transaction data, account data, identity data, or other data held by the third-party 108 for the user, account, or other entity being verified” as in paragraph [0034] it is stated that the third-party provider may be a client that provides the verification module with data. While applicant may prefer that the recited client in Claims 9 and 18 and third-party provider recited in Claims 8 and 17 are different, the specification does not exclude the possibility that they are the same entity and even contemplates that the third-party service provider may be a client. This claim interpretation is consistent with applicant’s specification.
Regarding the term “dynamically”, the amendments have rendered the corresponding claim interpretation moot. Accordingly, Examiner withdraws the corresponding interpretation.
Regarding the phrase “based on the normalized attributes”, the amendments have rendered the corresponding claim interpretation moot. Accordingly, Examiner withdraws the corresponding interpretation.
Claim Rejections Under 35 U.S.C. §112
Regarding the phrase “a plurality of heterogenous core processing systems”, The claims have been amended to address the objection(s)/rejection(s) presented in the prior Office Action. Accordingly, Examiner withdraws the corresponding objection(s)/rejection(s).
Applicant’s arguments, see remarks at paragraphs [0022]-[0025], have been considered. While Examiner agrees that the specification does disclose a specific normalization process (i.e. data structure mapping as cited in paragraphs [0060]-[0063]), it does not disclose generalized normalization of data as was previously claimed when considering the cited paragraphs. Regardless, the claims have been amended to address the objection(s)/rejection(s) presented in the prior Office Action. Accordingly, Examiner withdraws the corresponding objection(s)/rejection(s).
Claim Rejections Under 35 U.S.C. §101
Applicant brings up the August 4, 2025 Memorandum which Examiner notes is related to the precedential case Ex Parte Desjardins and argues that the characterization is precisely the kind of oversimplification the August 2025 Memo warns against. Examiner respectfully disagrees. In Ex Parte Desjardins the Examiner in the case did not provide a 101 rejection, but rather a 101 rejection was a new ground of rejection submitted by the board. “This Appeals Review Panel ("ARP") was convened to review the Board's Decision on Appeal ("Dec.") and Decision on Request for Rehearing ("Reh'g Dec."), with particular focus on the Board's new ground of rejection of claims 1-6 and 8-20 under 35 U.S.C. § 101. We have jurisdiction under 35 U.S.C. § 6(b).” See Appeal 2024-000567 - Ex Parte Desjardins et al Rehearing Decision Sep 26 2025 at page 1. This new grounds of rejection was later overturned and a Memorandum issued by Deputy Commissioner Charles Kim regarding eligibility particularly when evaluating claims related to machine learning or artificial intelligence. As cited below, these updated are not intended to announce any new USPTO practice or procedure and are meant to be consistent with existing USPTO guidance.
“These updates are not intended to announce any new USPTO practice or procedure and are meant to be consistent with existing USPTO guidance. Indeed, the Ex Parte Desjardins
decision analyzed eligibility in terms of whether the claims were directed to an improvement in the functioning of a computer, or an improvement to other technology or technical field under longstanding Federal Circuit precedent in Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016) and McRO, Inc. v. Bandai Namco Games Am. Inc., 837 F.3d 1299 (Fed. Cir. 2016). See also MPEP §§ 2106.04(d)(l) and 2106.05(a).” Charles Kim Memorandum Page 1 (emphasis added).
“In Ex Parte Desjardins, Appeal No. 2024-000567 (PTAB September 26, 2025, Appeals Review Panel Decision) (precedential), the claimed invention was a method of training a machine learning model on a series of tasks. The Appeals Review Panel (ARP) overall credited benefits including reduced storage, reduced system complexity and streamlining, and preservation of performance attributes associated with earlier tasks during subsequent computational tasks as technological improvements that were disclosed in the patent application specification. Specifically, the ARP upheld the Step 2A Prong One finding that the claims recited an abstract idea (i.e., mathematical concept). In Step 2A Prong Two, the ARP then determined that the specification identified improvements as to how the machine learning model itself operates, including training a machine learning model to learn new tasks while protecting knowledge about previous tasks to overcome the problem of “catastrophic forgetting” encountered in continual learning systems. Importantly, the ARP evaluated the claims as a whole in discerning at least the limitation “adjust the first values of the plurality of parameters to optimize performance of the machine learning model on the second machine learning task while protecting performance of the machine learning model on the first machine learning task” reflected the improvement disclosed in the specification. Accordingly, the claims as a whole integrated what would otherwise be a judicial exception instead into a practical application at Step 2A Prong Two, and therefore the claims were deemed to be outside any specific, enumerated judicial exception (Step 2A: NO).” Charles Kim Memorandum Page 2; to be added to the end of MPRP §2106.04(d)(III) (emphasis added).
As such, the specification identified improvements as to how the machine learning model itself operates. In the instant application, the specification does not provide improvements to any technology as applicant asserts. The specification discloses the nature of the claims’ elements:
“[0004] Apparatuses, methods, computer program products, and systems are disclosed for transaction based fraud detection. In one embodiment, an apparatus includes a processor and a memory that stores code executable by the processor. Executable code, in some embodiments, is executable to receive, over an application programming interface, an electronic request to perform an action for a user. In a further embodiment, executable code is executable to electronically access one or more attributes of an account for the user. In certain embodiments, executable code is executable to selectively perform the action for the user based on the one or more attributes of the account.
[0005] In some embodiments, a method for transaction based fraud detection includes receiving, over an application programming interface, an electronic request to perform an action for a user. A method, in certain embodiments, includes electronically accessing one or more attributes of an account for the user. In a further embodiment, a method includes selectively performing the action for the user based on the one or more attributes of the account.
[0006] In one embodiment, an apparatus for transaction based fraud detection includes means for receiving, over an application programming interface, an electronic request to perform an action for a user. An apparatus, in some embodiments, includes means for electronically accessing one or more attributes of an account for the user. In certain embodiments, an apparatus includes means for selectively performing the action for the user based on the one or more attributes of the account.”
Thus, applicant’s specification does NOT support the idea that the cited additional elements either separately or in combination amount to an improvement in the functioning of a computer, or an improvement to other technology or a technical field as the specification did in Ex Parte Desjardins. The instant case is not analogous to Ex Parte Desjardins.
Applicant further argues that the claims merely involve, rather than recite, a fundamental economic concept. Examiner respectfully disagrees. Step 2A Prong 1 requires examiners to evaluate whether a claim recites a judicial exception as the applicant cited. The elements which examiner identified in Step 2A Prong 1 are those which describe the noted abstract idea which means that the claim recites an abstract idea. “The mere inclusion of a judicial exception such as a mathematical formula (which is one of the mathematical concepts identified as an abstract idea in MPEP § 2106.04(a)) in a claim means that the claim "recites" a judicial exception under Step 2A Prong One.” See MPEP 2106.04(II)(A)(2). “When performing the analysis at Step 2A Prong One, it is sufficient for the examiner to provide a reasoned rationale that identifies the judicial exception recited in the claim and explains why it is considered a judicial exception (e.g., that the claim limitation(s) falls within one of the abstract idea groupings). Therefore, there is no requirement for the examiner to rely on evidence, such as publications or an affidavit or declaration under 37 CFR 1.104(d)(2), to find that a claim recites a judicial exception. Cf. Affinity Labs of Tex., LLC v. Amazon.com Inc., 838 F.3d 1266, 1271-72, 120 USPQ2d 1210, 1214-15 (Fed. Cir. 2016) (affirming district court decision that identified an abstract idea in the claims without relying on evidence); OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1362-64, 115 USPQ2d 1090, 1092-94 (Fed. Cir. 2015) (same); Content Extraction & Transmission LLC v. Wells Fargo Bank, N.A., 776 F.3d 1343, 1347, 113 USPQ2d 1354, 1357-58 (Fed. Cir. 2014) (same).” See MPEP 2106.07(a)(III). The omitted element(s) (if any) are elements in addition to the abstract idea (i.e. they are not abstract) which require further analysis under Step 2A Prong 2 in order to determine if they cause the recited abstract idea to be integrated into a practical application. See MPEP 2106.07(a)(II). The omitted element(s) (if any) are later enumerated under Step 2A Prong 2 as additional elements. The claims recite and/or describe a judicial exception.
Applicant further argues that the amended claims are directed to the specific technical architecture of the datapath module. Examiner respectfully disagrees. Applicant’s specification has not asserted to have invented a new type of database. “[0025] These computer readable program instructions may be provided to a processor of a general purpose computer, special purpose computer, or other programmable data processing apparatus to produce a machine, such that the instructions, which execute via the processor of the computer or other programmable data processing apparatus, create means for implementing the functions/acts specified in the flowchart and/or block diagram block or blocks.” Examiner notes that applicant’s purported improvement comes from potential improvements in the judicial exception, and not from improvements to computers or technology as the recitation of computing components in the claimed invention amounts to no more than invoking computers merely as a tool. See at least MPEP 2106.05(a)(I). The recitation of generic computing components to perform an otherwise ineligible judicial exception does not confer patent eligibility.
Applicant argues that the specification describes a concrete technical problem and that this is not a financial problem, but is a data integration and systems interoperability problem. Examiner respectfully disagrees. Data content incompatibility between providers has existed long before the invention of the computer. The MPEP clarifies how additional elements can impose meaningful limits on a recited judicial exception:
“Consideration of improvements is relevant to the eligibility analysis regardless of the technology of the claimed invention. That is, the consideration applies equally whether it is a computer-implemented invention, an invention in the life sciences, or any other technology. See, e.g., Rapid Litigation Management v. CellzDirect, Inc., 827 F.3d 1042, 119 USPQ2d 1370 (Fed. Cir. 2016), in which the court noted that a claimed process for preserving hepatocytes could be eligible as an improvement to technology because the claim achieved a new and improved way for preserving hepatocyte cells for later use, even though the claim is based on the discovery of something natural. Notably, the court did not distinguish between the types of technology when determining the invention improved technology. However, it is important to keep in mind that an improvement in the abstract idea itself (e.g. a recited fundamental economic concept) is not an improvement in technology. For example, in Trading Technologies Int’l v. IBG, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019), the court determined that the claimed user interface simply provided a trader with more information to facilitate market trades, which improved the business process of market trading but did not improve computers or technology.” (MPEP 2106.05(a)(II))
Drawing attention to the emphasized section, an improvement in the judicial exception itself is not an improvement in technology. In the current case, regardless of whether or not applicant’s invention improves the recited judicial exception, improving a method, algorithm, or process of a judicial exception absent of any technological modification, would be an improvement to the judicial exception (e.g. via the improvement in the efficiency of the judicial exception), but does not improve computers or technology.
Applicant argues the claims are eligible for reasons similar to Example 42. Examiner respectfully disagrees. In Example 42, the claims described medical records that were stored in a non-standard format selected by whichever hardware or software platform is in use in the medical provider’s local office. These medical records were shared among medical providers which were often-times incomplete since records in separate locations are not timely or readily-shared or cannot be consolidated due to format inconsistencies. Claim 1 recited a combination of additional elements which converted non-standardized form information to a standardized format. 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. Applicant’s claims are not converting non-standardized form information to a standardized format but rather, under their BRI, are changing the content of the data. The instant claims are not analogous to Example 42.
Applicant argues that the instant claims are similar to Example 40 of the USPTO’s “Subject Matter Eligibility Examples: Abstract Ideas” for use in conjunction with the 2019 PEG. Examiner respectfully disagrees. Example 40 is eligible because the claim is integrated into a practical application through being directed towards an improvement of network monitoring technology. In Example 40 network traffic data is collected to determine whether or not to further collect NetFlow records which in the background is discussed to be very large such that continuous collection of NetFlow records would hinder network performance. “Specifically, the method limits collection of additional Netflow protocol data to when the initially collected data reflects an abnormal condition, which avoids excess traffic volume on the network and hindrance of network performance. The collected data can then be used to analyze the cause of the abnormal condition. This provides a specific improvement over prior systems, resulting in improved network monitoring. The claim as a whole integrates the mental process into a practical application” (Eligibility Example 40). The instant application is not so concerned with limiting collection of a NetFlow data or any collector that would hinder network performance if run continuously. Rather, the application is merely applying a commonplace business method (i.e. fraud detection and fraud detection modelling) on a general purpose computer which the courts have indicated may not be sufficient to show an improvement to technology (See MPEP 2106.05(a)(II)). Example 40 is not analogous to the instant claims.
Applicant argues that their claims are eligible for reasons similar to those given in Example 47. Examiner respectfully disagrees. Examiner notes that Example 47 references the case of SRI Int’l, Inc. v. Cisco Sys., Inc. (hereinafter SRI). Therefore for the sake of compact prosecution Examiner will address both together. In SRI, the problem being solved was identified as follows:
“While the interconnectivity of computer networks facilitates access for authorized users, it also increases a network's susceptibility to attacks from hackers, malware, and other security threats. Some of these security threats can only be detected with information from multiple sources. For instance, a hacker may try logging in to several computers or monitors in a network. The number of login attempts for each computer may be below the threshold to trigger an alert, making it difficult to detect such an attack by looking at only a single monitor location in the network.”
The focus of claims were further found to be the following:
“The "focus of the claims is on the specific asserted improvement in computer capabilities"—that is, providing a network defense system that monitors network traffic in real-time to automatically detect large-scale attacks”. The specification bolstered the court’s conclusion that the claims were directed to a technological solution to a technical problem. “The specification explains that, while computer networks "offer users ease and efficiency in exchanging information," '615 patent col. 1 ll.28-29, "the very interoperability and sophisticated integration of technology that make networks such valuable assets also make them vulnerable to attack, and make dependence on networks a potential liability." Id. at col. 1 ll. 36-39. The specification further teaches that, in conventional networks, seemingly localized triggering events can have globally disastrous effects on widely distributed systems—like the 1980 ARPAnet collapse and the1990 AT&T collapse. See id. at col. 1 ll. 43-47. The specification explains that the claimed invention is directed to solving these weaknesses in conventional networks and provides "a framework for the recognition of more global threats to interdomain connectivity, including coordinated attempts to infiltrate or destroy connectivity across an entire network enterprise."
Similarly, in Example 47 the problem being solved was identified in the following:
“The consideration of whether the claim as a whole includes an improvement to a computer or to a technological field requires an evaluation of the specification and the claim to ensure that a technical explanation of the asserted improvement is present in the specification, and that the claim reflects the asserted improvement. See MPEP 2106.04(d)(1). According to the background section, existing systems use various detection techniques for detecting potentially malicious network packets and can alert a network administrator to potential problems. The disclosed system detects network intrusions and takes real-time remedial actions, including dropping suspicious packets and blocking traffic from suspicious source addresses. The background section further explains that the disclosed system enhances security by acting in real time to proactively prevent network intrusions.
The claimed invention reflects this improvement in the technical field of network intrusion detection. Steps (d)-(f) provide for improved network security using the information from the detection to enhance security by taking proactive measures to remediate the danger by detecting the source address associated with the potentially malicious packets. Specifically, the claim reflects the improvement in step (d), dropping potentially malicious packets in step (e), and blocking future traffic from the source address in step (f). These steps reflect the improvement 13 described in the background. Thus, the claim as a whole integrates the judicial exception into a practical application such that the claim is not directed to the judicial exception.”
Unlike in SRI and Example 47, applicant’s specification is not focused on an improvement in computer capabilities, but rather is focused on implementation of a business practice (i.e. fraud detection, See at least paragraphs [0004]-[0006] of the specification) using generic computer components. The case of SRI and Example 47 are not analogous to the instant application.
Applicant argues that the amended claims solves a computer systems problem, the ability of a unified interface to query multiple core processing systems that use incompatible identifier and credential schemes by maintaining a specific data structure (the identity repository) that resolves those incompatibilities. Examiner respectfully disagrees. As stated above, data content incompatibility between providers has existed long before the invention of the computer. The MPEP clarifies how additional elements can impose meaningful limits on a recited judicial exception:
“Consideration of improvements is relevant to the eligibility analysis regardless of the technology of the claimed invention. That is, the consideration applies equally whether it is a computer-implemented invention, an invention in the life sciences, or any other technology. See, e.g., Rapid Litigation Management v. CellzDirect, Inc., 827 F.3d 1042, 119 USPQ2d 1370 (Fed. Cir. 2016), in which the court noted that a claimed process for preserving hepatocytes could be eligible as an improvement to technology because the claim achieved a new and improved way for preserving hepatocyte cells for later use, even though the claim is based on the discovery of something natural. Notably, the court did not distinguish between the types of technology when determining the invention improved technology. However, it is important to keep in mind that an improvement in the abstract idea itself (e.g. a recited fundamental economic concept) is not an improvement in technology. For example, in Trading Technologies Int’l v. IBG, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019), the court determined that the claimed user interface simply provided a trader with more information to facilitate market trades, which improved the business process of market trading but did not improve computers or technology.” (MPEP 2106.05(a)(II))
Drawing attention to the emphasized section, an improvement in the judicial exception itself is not an improvement in technology. Examiner is not saying this case is the exact same case as Trading Technologies, but rather in the current case, regardless of whether or not applicant’s invention improves the recited judicial exception, improving a method, algorithm, or process of a judicial exception absent of any technological modification, would be an improvement to the judicial exception (e.g. via the improvement in the efficiency of the judicial exception), but does not improve computers or technology.
Step 2B
Applicant argues that Examiner does not identify which specific court decision establishes that the combination of the newly amended limitations is WURC. Examiner notes this reasoning is flawed. “Although the conclusion of whether a claim is eligible at Step 2B requires that all relevant considerations be evaluated, most of these considerations were already evaluated in Step 2A Prong Two. Thus, in Step 2B, examiners should:
• Carry over their identification of the additional element(s) in the claim from Step 2A Prong Two;
• Carry over their conclusions from Step 2A Prong Two on the considerations discussed in MPEP §§ 2106.05(a) - (c), (e) (f) and (h):
• Re-evaluate any additional element or combination of elements that was considered to be insignificant extra-solution activity per MPEP § 2106.05(g), because if such re-evaluation finds that the element is unconventional or otherwise more than what is well-understood, routine, conventional activity in the field, this finding may indicate that the additional element is no longer considered to be insignificant; and
• Evaluate whether any additional element or combination of elements are other than what is well-understood, routine, conventional activity in the field, or simply append well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception, per MPEP § 2106.05(d)” (See MPEP 2106.05(II)).
In both the prior and instant Office Action, the conclusions from Step 2A Prong Two are equally applied in Step 2B which further re-evaluates additional elements which are considered to be insignificant extra-solution activity and evaluates these elements as per MPEP §2106.05(d) to be well-understood, routine, and conventional activity. Said elements which are considered to be insignificant extra-solution activity are evaluated as well-understood, routine, and conventional as per the evidentiary requirements detailed in MPEP §2106.07(a)(III) utilizing option (B) via citation to one or more of the court decisions discussed in MPEP §2106.05(d)(II). Thus, there are no further elements to evaluate under Step 2B. Most considerations relating to any additional elements were already evaluated in Step 2A Prong Two and thus do not require further re-evaluation in Step 2B. Furthermore, “The analysis under Step 2A Prong Two is the same for all claims reciting a judicial exception, whether the exception is an abstract idea, a law of nature, or a natural phenomenon (including products of nature). Examiners evaluate integration into a practical application by: (1) identifying whether there are any additional elements recited in the claim beyond the judicial exception(s); and (2) evaluating those additional elements individually and in combination to determine whether they integrate the exception into a practical application, using one or more of the considerations introduced in subsection I supra, and discussed in more detail in MPEP §§ 2106.04(d)(1), 2106.04(d)(2), 2106.05(a) through (c) and 2106.05(e) through (h).” See MPEP 2106.04(d)(II) (emphasis added). Examiner notes that the section(s) of the claim(s) which applicant cites were and/or are elements which cause the claim to recite an abstract idea. As cited, additional elements which could cause integration into a practical application must be those recited beyond the judicial exception (emphasis added). The elements which recite the judicial exception cannot also serve to integrate the judicial exception into a practical application.
Applicant argues that if the combination of elements was so well-understood and conventional as to be WURC, it should have been obvious over prior art – yet the Examiner conceded it was not. Examiner respectfully disagrees. “Although the courts often evaluate considerations such as the conventionality of an additional element in the eligibility analysis, the search for an inventive concept should not be confused with a novelty or non-obviousness determination.” See MPEP § 2106.05(I). Although the second step in the Alice/Mayo framework is termed a search for an “inventive concept,” the analysis is not an evaluation of novelty or non-obviousness, but rather, a search for an element or combination of elements that is sufficient to ensure that the patent in practice amounts to significantly more than a patent upon the ineligible concept itself. Furthermore, tests for whether an element is conventional under Step 2B only applies to the additional elements recited and not to the abstract idea present within the claims. Improvement of technology by virtue of novelty or non-obviousness is not a test of eligibility.
Claim Interpretation
Examiner notes that the phrase “a third-party service provider holding the account for the user” recited in Claims 8 and 17 and the phrase “a client that submitted the electronic request” recited in Claims 9 and 18 may be, under the claims’ BRI, the same entity (e.g. a bank may be both a third-party service provider holding the account for the user and may be a client that submitted the electronic request).
Examiner recognizes applicant’s explicit definition of computer readable storage medium present in paragraph [0021] of the specification: “A computer readable storage medium, as used herein, is not to be construed as being transitory signals per se, such as radio waves or other freely propagating electromagnetic waves, electromagnetic waves propagating through a waveguide or other transmission media (e.g., light pulses passing through a fiber-optic cable), or electrical signals transmitted through a wire.”
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.
Step 1 of the 101 Analysis:
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 claims recites an apparatus, a method, and a computer program product for transaction based fraud detection. These are a machine, a process and an article of manufacture which are within the four categories of statutory subject matter.
Step 2A Prong 1 of the 101 Analysis:
The following limitations and/or similar versions are found in claim(s) 1, 12 and 20:
Claim(s) 1, 12 and 20:
“receive,…, an electronic request to perform an action for a user;”
“maintain an identity repository mapping user and account identifiers across the plurality of core processing systems;”
“maintain separate electronic credentials for each of the plurality of core processing systems;”
“provide, using the identity repository and the separate electronic credentials, a single point of authentication through which each of the plurality of core processing systems is simultaneously accessible;”
“determine, based on the accessed attributes, a confidence score indicating a likelihood that the account is fraudulent, wherein the confidence score is updated in real time as additional account or transaction attributes are received;”
“determine a scope of allowed actions for the user from a set of available actions based on the confidence score, the scope being expanded or restricted as the confidence score changes;”
“selectively perform the action for the user based on the one or more attributes of the account.”
These limitations, as drafted, are a process that, under its broadest reasonable interpretation, describes Fundamental Economic Principles of Practices but for the recitation of generic computer components. That is, other than reciting “a processor”, “a memory that stores code executable by the processor to:”, or “over an application programming interface”, nothing in the claims’ elements precludes the steps from practically describing Fundamental Economic Principles of Practices. For example, but for the recited computer language, the limitations in the context of this claim describes Mitigating Risk. Mitigating Risk is described when selectively performing a requested action based on account attributes. If a claim limitations, under their broadest reasonable interpretation, describes Fundamental Economic Principles of Practices but for the recitation of generic computer components, then it falls within the “Certain Methods of Organizing Activity” grouping of abstract ideas.
Dependent claim(s) 3-7, 9-11, 14-16 and 18-19 are directed to the following:
Claim(s) 3:
“…wherein the one or more attributes comprise an age of the account.”
Claim(s) 4:
“…wherein the one or more attributes comprise a balance of the account.”
Claim(s) 5:
“…wherein the one or more attributes comprise one or more of a frequency of transactions for the account, a number of transactions for the account, a monetary amount of one or more transactions for the account, a total monetary amount of transactions for the account, an average monetary amount of transactions for the account, and a date of a most recent transaction for the account.”
Claim(s) 6 and 15:
“wherein the one or more attributes comprise a date of an oldest deposit for the account, a date of a most recent deposit for the account, and a monetary amount of a deposit for the account.”
Claim(s) 7 and 16:
“…wherein the one or more attributes comprise a type of the account and a role of the user for the account.”
Claims 9 and 18:
“…wherein the one or more attributes are received …from a client that submitted the electronic request.”
Claim(s) 10:
“…wherein the one or more attributes comprise identity data for the user.”
Claim(s) 11 and 19:
“…determine whether the account is a new account and the one or more attributes comprise identity data for the user in response to a determination that the account is new.”
Claim(s) 14:
“…wherein the one or more attributes comprise one or more of an age of the account, a balance of the account, a frequency of transactions for the account, a number of transactions for the account, a monetary amount of one or more transactions for the account, a total monetary amount of transactions for the account, an average monetary amount of transactions for the account, and a date of a most recent transaction for the account.”
These processes are similar to the abstract idea noted in the independent claims because they further the limitations of the independent claim which are directed to a judicial exception. Accordingly, these claim elements do not serve to confer subject matter eligibility to the claims since they are directed to abstract ideas.
Accordingly, the claims recite an abstract idea.
Step 2A Prong 2 of the 101 Analysis:
This judicial exception is not integrated into a practical application. In particular, the independent claim(s) recite the following additional elements:
Claim(s) 1, 12 and 20:
“…over an application programming interface…”
“electronically access one or more attributes of an account for the user from a plurality of core processing systems of different third-party service providers having different compatibilities, functions, and requirements via a datapath module, the datapath module configured to…;”
“provide, via the application programming interface, an interface that presents the confidence score and corresponding scope of allowed actions, wherein the interface is updated in real time as the confidence score changes.”
Claim(s) 1:
“a processor;”
“a memory that stores code executable by the processor to:”
The computer components or other machinery (processor, memory, interface and API) are recited at a high level of generality (i.e. as a generic processor, generic storage, generic interface and generic API) such that it amounts to no more than mere instructions to implement the judicial exception on a computer or by using a computer or other machinery merely as a tool to perform an existing process. These element(s) in combination do not add anything that is not already pre-sent when the steps are considered separately. Simply implementing an abstract idea on a computer or using machinery as a tool to perform an existing process is not indicative of integration into a practical application (See MPEP § 2106.05(f).)
The accessing step(s) are recited at a high-level of generality (i.e., as generally accessing) such that they amounts to no more than mere data gathering which is adding insignificant extra-solution activity. These element(s) in combination do not add anything that is not already present when the steps are considered separately. Simply adding insignificant extra-solution activity is not indicative of integration into a practical application (See MPEP § 2106.05(g).)
The use of heterogenous core processing systems is implemented at a high level of generality (i.e. as simply using the technology) such that it amounts to no more than generally linking the use of the judicial exception to a particular technological environment or field of use. These element(s) in combination do not add anything that is not already pre-sent when the steps are considered separately. Generally linking the use of the judicial exception to a particular technological environment or field of use is not indicative of integration into a practical application (See MPEP § 2106.05(h).)
Dependent claim(s) 2, 8-9, 13 and 17-28 contain the following additional elements:
Claim(s) 2 and 13:
“provide the confidence score over the application programming interface.”
Claim(s) 8 and 17:
“…wherein the one or more attributes are electronically accessed over a data network using an electronic interface of a third-party service provider holding the account for the user.”
Claim(s) 9 and 18:
“…over the application programming interface…”
The computer components or other machinery (API, data network and electronic interface) are recited at a high level of generality (i.e. as a generic API, generic network and generic interface) such that it amounts to no more than mere instructions to implement the judicial exception on a computer or by using a computer or other machinery merely as a tool to perform an existing process. These element(s) in combination do not add anything that is not already pre-sent when the steps are considered separately. Simply implementing an abstract idea on a computer or using machinery as a tool to perform an existing process is not indicative of integration into a practical application (See MPEP § 2106.05(f).)
The providing and accessing step(s) are recited at a high level of generality (i.e., as simply providing and simply accessing) such that they amount to no more than mere data gathering which is adding insignificant extra solution activity. These element(s) in combination do not add anything that is not already pre-sent when the steps are considered separately. Simply adding insignificant extra-solution activity is not indicative of integration into a practical application (See MPEP § 2106.05(g).)
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.
The claims are directed to an abstract idea.
Step 2B of the 101 Analysis:
The API and electronic interface mentioned above is/are disclosed in applicant’s specification (See at least paragraphs [0069] and [0075] of the specification). The component is described as:
“The one or more verification modules 104, in certain embodiments, may provide an interface (e.g., an application programming interface (API), a graphical user interface of an application 114, or the like) to provide downloaded and/or aggregated user data from servers 108, core processing systems 122a-n, or the like of one or more third- party service providers 108 to one or more other entities (e.g., an application 114 or other data recipient entity, a remote server 110 or other hardware computing device 102 unaffiliated with the third-party service provider 108, or the like). The interface, in one embodiment, comprises a private interface between applications 114 executing on users' hardware computing devices 102 and one or more verification modules 104. In another embodiment, the interface comprises a public and/or open interface, which may be secured, allowing a user to share the user's downloaded data from a verification module 104 to one or more other tools, services, and/or other entities to store, process, and/or otherwise use the data.” (paragraph [0069])
“The one or more third-party service providers 108, in one embodiment, may include one or more network accessible computing systems such as one or more core processing systems 122a-n, one or more web servers hosting one or more web sites, an enterprise intranet system, an application server, an application programming interface (API) server, an authentication server, or the like.” (paragraph [0075])
The data network mentioned above is/are disclosed in applicant’s specification (See at least paragraph [0030]). The component is described as:
“Figure lA and Figure 1B depict embodiments of systems 100, 120 for transaction based fraud detection. In one embodiment, the system 100 includes one or more hardware computing devices 102, one or more verification modules 104 (e.g., a backend verification module 104 disposed on a backend server 110, and/or a plurality of verification modules 104 disposed on servers 108 of one or more third-party service providers 108, or the like), one or more data networks 106 or other communication channels, one or more third-party service providers 108 (e.g., one or more servers 108 of one or more service providers 108; one or more cloud or network service providers 108, or the like), one or more backend servers 110 and/or one or more core processing systems 122a-n. In certain embodiments, even though a specific number of hardware computing devices 102,verification modules 104,data networks 106,third-party service providers 108,backend servers 110, and/or core processing systems 122a-n are depicted in Figure lA and Figure 1B, one of skill in the art will recognize, in light of this disclosure, that any number of hardware computing devices 102,verification modules 104,data networks 106,third-party service providers 108,backend servers 110, and/or core processing systems 122a-n may be included in the systems 100, 120.” (paragraph [0030], emphasis added)
The memory mentioned above is/are disclosed in applicant’s specification (See at least paragraph [0021]). The component is described as:
“The computer readable storage medium can be a tangible device that can retain and store instructions for use by an instruction execution device. The computer readable storage medium may be, for example, but is not limited to, an electronic storage device, a magnetic storage device, an optical storage device, an electromagnetic storage device, a semiconductor storage device, or any suitable combination of the foregoing. A non-exhaustive list of more specific examples of the computer readable storage medium includes the following: a portable computer diskette, a hard disk, a random access memory ("RAM"), a read-only memory ("ROM"), an erasable programmable read-only memory-5- ("EPROM" or Flash memory), a static random access memory ("SRAM"), a portable compact disc read-only memory ("CD-ROM"), a digital versatile disk ("DVD"), a memory stick, a floppy disk, a mechanically encoded device such as punch-cards or raised structures in a groove having instructions recorded thereon, and any suitable combination of the foregoing. A computer readable storage medium, as used herein, is not to be construed as being transitory signals per se, such as radio waves or other freely propagating electromagnetic waves, electromagnetic waves propagating through a waveguide or other transmission media (e.g., light pulses passing through a fiber-optic cable), or electrical signals transmitted through a wire.” (paragraph [0021])
The processor mentioned above is/are disclosed in applicant’s specification (See at least paragraph [0065]). The component is described as:
“In one embodiment, a system 100, 120 includes one or more hardware computing devices 102. The hardware computing devices 102 (e.g., hardware computing devices, information handling devices, or the like) may include one or more of a desktop computer, a laptop computer, a mobile device, a tablet computer, a smart phone, a set-top box, a gaming console, a smart TV, a smart watch, a fitness band, an optical head-mounted display (e.g., a virtual reality headset, smart glasses, or the like), an HDMI or other electronic display dongle, a personal digital assistant, and/or another computing device comprising a processor (e.g., a central processing unit (CPU), a processor core, a field programmable gate array (FPGA) or other programmable logic, an application specific integrated circuit (ASIC), a controller, a microcontroller, and/or another semiconductor integrated circuit device), a volatile memory, and/or a non-volatile storage medium.” (paragraph [0065])
Therefore applicant’s own specification supports these components as generic computer components.
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, the additional elements identified in Step 2A Prong 2 amount to no more than mere instructions to implement the judicial exception on a computer or no more than mere data gathering or data outputting which only adds insignificant extra solution activity to the judicial exception. These element(s) in combination do not add anything that is not already pre-sent when the steps are considered separately. Adding insignificant extra-solution activity cannot provide an inventive concept when the activities are well-understood routine and conventional. The courts have recognized the following computer functions as well-understood, routine, and conventional functions when they are claimed in a merely generic manner:
(for accessing various data) Storing and retrieving information in memory, (See MPEP § 2106.05(d)(II)).
(for providing/accessing various data) Receiving or transmitting data over a network, (See MPEP § 2106.05(d)(II)).
The claims are not patent eligible.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Prasad et al. (US 11,854,011 B1) discloses using account information to detect money laundering and using said information to restrict scope of allowed actions.
Zoldi et al. (US 2009/0222369 A1) discloses that collected attributes may include amount of a transaction (i.e. equivalent to deposit amount), date of the last deposit (i.e. date of most recent deposit) and account opening date.
Hiroyuki (JP 2005228159 A) discloses that an account opening process may be performed with an initial deposit and the amount and date of opening recorded as account information (i.e. equivalent to date of oldest deposit).
Herdrich et al. (US 2016/0284021 A1) discloses operation of a financial credit system using heterogenous cores.
Finot et al. (US 2014/0351129 A1) discloses normalization of attribute data.
Webster et al. (US 2020/0127843) discloses that general contractors, subcontractors and workers (i.e. roles of users) associated with a project may link their accounts with a property owner’s or escrow account (i.e. roles of users for an account) and enter into a smart contract to be paid from said account utilizing the terms of said smart contract which contains to-do lists associated with each task of a project and who is associated with each task.
Musser et al. (US 2014/0279522 A1) discloses attribute information may include date and time of the most recent deposit.
Chen (US 2022/0044244 A1) discloses normalization of attributes collected.
Ahmed et al. (“Security in Next Generation Mobile Payment Systems: A Comprehensive Survey”) discloses utilizing various factors for account authorization.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ADAM J HILMANTEL whose telephone number is (571)272-8984. The examiner can normally be reached M-F 8:30AM-5:00PM.
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/ADAM HILMANTEL/Examiner, Art Unit 3691