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 1 and 7 are amended while claims 2-4, 6, 8, 10-14, and 17-21 are cancelled. Claims 1, 5, 7, 9, 15-16, and 22 filed December 5, 2025 are pending and are hereby examined.
Claim Rejections - 35 USC § 101
3. 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.
4. Claims 1, 5, 7, 9, 15-16, and 22 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
6. Step 1 Statutory Category: Claims 1, 5, and 15-16 are directed to a method, and claims 7, 9, and 22 are directed to a system, all of which are statutory classes of invention.
5. Step 2A – Prong 1: Judicial Exception Recited: Nevertheless, independent claims 1 and 7 recite an abstract idea of automated routing of voucher verification.
The independent claims 1 and 7 recite the following limitations which fall under commercial or legal interactions:
receiving a first voucher as first image data that is obtained by capturing a first paper-based voucher and has no electrical character data;
extracting a first character string, a second character string and a third character string from the first image data by adding produced electric data of the first character string, the second character string and the third character string to the first image data using optical character recognition of an image of the first image data;
… receiving all of unaudited accounting data that each meet a condition including the first character string;
… searching the second character string in a first unaudited accounting data, and then determining that the first unaudited accounting data agrees with the first voucher with respect to the second character string if the second character string is found in the first unaudited accounting data and then:
If the second character string is not found in the first unaudited accounting data… further searching a string that has a similarity higher than or equal to a pre-determined threshold value in the first unaudited accounting data by calculating a similarity between each string in the first unaudited accounting data and a partial image corresponding to the second character string in the first image data, and then with respect to the second character string, determining that the first unaudited accounting data agrees with the first voucher if the string that has the similarity higher than or equal to the pre-determined threshold value is found in the first unaudited accounting data;
… searching the third character string in the first unaudited accounting data, and then: determining that the first unaudited accounting data agrees with the first voucher with respect to the third character string if the third character string is found in the first unaudited accounting data;
and if the second character string is not found in the first unaudited accounting data… further searching a string that has a similarity higher than or equal to the pre-determined threshold value in the first unaudited accounting data by calculating a similarity between each string in the first unaudited accounting data and a partial image corresponding to the third character string in the first image data, and then with respect to the third character string, determining that the first unaudited accounting data agrees with the first voucher if the string that has the similarity higher than or equal to the pre-determined threshold value is found in the first unaudited accounting data;
… determining that the first unaudited accounting data agrees with the first voucher if with respect to all of the first character string, the second character string and the third character string, the first unaudited accounting data agrees with the first voucher, and then changing the first unaudited accounting data to one of audited accounting data automatically;
wherein the partial image corresponding to the second character string in the first image data is identified by using coordinates attached to the second character string that is embedded in the first image data;
wherein the similarity between each string in the first unaudited accounting data and a partial image corresponding to the third character string in the case that that the third character string is not found in the first unaudited accounting data is calculated by…;
… is learned by supervised learning with a learning data set including images of paper-based vouchers of actually-audited accounting data as a part of teacher labels;
wherein the supervised learning is performed by calculating similarities between accounting data and corresponding partial images of the paper-based vouchers as the part of teacher labels;
… stores accounting data including unaudited accounting data to be checked.
6. According to the MPEP, "Commercial interactions" or "legal interactions" include agreements in the form of contracts, legal obligations, advertising, marketing or sales activities or behaviors, and business relations. Clearly, voucher verification falls under sales activities, therefore commercial or legal interactions. If the claim limitations, under the broadest reasonable interpretation, covers performance of the limitations as a commercial or legal interaction, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
7. Step 2A – Prong 2: Practical Application: This judicial exception is not integrated into a practical application because the claim as a whole merely recites voucher verification with generally recited computer elements such as a learned determination model, memory portion, receiving portion, processing portion, and database, which in these steps are recited at a high-level of generality such that it amounts to more than mere instructions to apply the exception using a generic computer component, and are merely invoked as tools for voucher verification. Accordingly, these elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Simply implementing the abstract idea on a generic computing environment is not a practical application of the abstract idea, and does not take the claim out of the Commercial or Legal Interactions subgrouping of Certain Methods of Organizing Human Activity grouping. The claims are directed to an abstract idea.
8. Step 2B – Inventive Concept: The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when considered individually and as an ordered combination, they do not add significantly more (also known as “inventive concept”) to the exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements of a learned determination model, memory portion, receiving portion, processing portion, and database, to perform these steps amounts to no more than mere instructions to apply the exception using a generic computer component. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Accordingly, these additional elements, do not change the outcome of the analysis, when considered individually and as an ordered combination as there is no inventive concept sufficient to transform the claimed subject matter into a patent-eligible application. The claims are not patent eligible.
9. Regarding dependent claim 5, although this claim recites a generally recited database, this claim merely narrows the abstract idea of voucher verification, and this claim neither integrates into a practical application nor contains additional elements which amount to significantly more than the abstract idea.
10. Regarding dependent claim 9, although this claim recites a generally recited display, this claim merely narrows the abstract idea of voucher verification, and this claim neither integrates into a practical application nor contains additional elements which amount to significantly more than the abstract idea.
11. Regarding dependent claims 15-16, these claims merely narrow the abstract idea of voucher verification, and these claims neither integrate into a practical application nor contain additional elements which amount to significantly more than the abstract idea.
12. Regarding dependent claim 22, although this claim recites a generally recited database, this claim merely narrows the abstract idea of voucher verification, and this claim neither integrates into a practical application nor contains additional elements which amount to significantly more than the abstract idea.
13. Therefore, the limitations of the claims, when viewed individually and in ordered combination, are directed to ineligible subject matter.
Claim Interpretation
14. The following is a quotation of 35 U.S.C. 112(f):
(f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.
The following is a quotation of pre-AIA 35 U.S.C. 112, sixth paragraph:
An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.
15. The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked.
16. As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph:
(A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function;
(B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and
(C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function.
17. Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function.
18. Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function.
19. Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action.
20. This application includes one or more claim limitations that do not use the word “means,” but are nonetheless being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, because the claim limitation(s) uses a generic placeholder that is coupled with functional language without reciting sufficient structure to perform the recited function and the generic placeholder is not preceded by a structural modifier.
21. Such claim limitation(s) is/are: processing portion, memory portion, and receiving portion in claims 1 and 7. A review of the Specification of the processing portion, memory portion, and receiving portion were found to be generally recited software.
22. For purposes of examination, the Examiner is assuming all of the aforementioned components to be software. For purposes of examination, under broadest reasonable interpretation (BRI), the Examiner is interpreting these components to be generally recited hardware. Dependent claims 3-6 and 8-14 are invoking 35 U.S.C. 12(f) or pre-AIA 35 U.S.C. 112, sixth paragraph based on their dependency to an invoked claim.
23. Because this/these claim limitation(s) is/are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it/they is/are being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof.
24. If applicant does not intend to have this/these limitation(s) interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, applicant may: (1) amend the claim limitation(s) to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph (e.g., by reciting sufficient structure to perform the claimed function); or (2) present a sufficient showing that the claim limitation(s) recite(s) sufficient structure to perform the claimed function so as to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph.
Examiner Notes
25. Claims 1, 5, 7, 9, 15-16, and 22 are novel and unobvious over the prior art, however, there remains a 35 U.S.C. 101 rejection. The Examiner suggests clarifying the processing/memory/receiving portions. Finally, the Examiner suggests incorporating more hardware from the Specification and any unique arrangements of hardware, unique hardware, or unique ways the hardware is communicating. The aforementioned claim suggestions, in combination together, is suggested to help advance prosecution forward, although further search, examination, and consideration is required.
26. After further search and consideration, the most pertinent U.S. prior art was found to be Simantov et al (US 2018/0012268), Morita (US 2020/0160149), and Anorga et al (US 2018/0336415). Morita (US 2020/0160149) is directed to a knowledge completion method and information processing. Anorga et al (US 2018/0336415) is directed to suggested actions for images. Simantov et al (US 2018/0012268) is directed to an expense management system based upon business document analysis. Meanwhile, Lahann, Johannes et al (Utilizing Machine Learning Techniques to Reveal VAT Compliance Violations in Accounting Data, NPL) was found to be the most pertinent NPL prior art, and is directed to using machine learning for accounting data.
27. However, both the most pertinent U.S. prior art and NPL fail to disclose all of the limitations particularly:
searching the second character string in a first unaudited accounting data, and then determining that the first unaudited accounting data agrees with the first voucher with respect to the second character string if the second character string is found in the first unaudited accounting data;
searching a string that has a similarity higher than or equal to a pre-determined threshold value in the first unaudited accounting data by calculating a similarity between each string in the first unaudited accounting data and a partial image corresponding to the second character string in the first image data, and then with respect to the second character string, determining that the first unaudited accounting data agrees with the first voucher if the string that has the similarity higher than or equal to the pre-determined threshold value is found in the first unaudited accounting data;
searching the third character string in the first unaudited accounting data, and then determining that the first unaudited accounting data agrees with the first voucher with respect to the third character string if the third character string is found in the first unaudited accounting data;
searching a string that has a similarity higher than or equal to the pre-determined threshold value in the first unaudited accounting data by calculating a similarity between each string in the first unaudited accounting data and a partial image corresponding to the third character string in the first image data, and then with respect to the third character string, determining that the first unaudited accounting data agrees with the first voucher if the string that has the similarity higher than or equal to the pre-determined threshold value is found in the first unaudited accounting data;
and determining that the first unaudited accounting data agrees with the first voucher if with respect to all of the first character string, the second character string and the third character string, the first unaudited accounting data agrees with the first voucher, and then changing the first unaudited accounting data to one of audited accounting data.
28. No prior art cited here or in any previous Office Action neither fully anticipates nor supports a conclusion of obviousness with respect to the subject matter present in the independent claims, either alone or in combination. The limitations lacking in the prior art, in combination with the other limitations clearly claimed in the application, are novel and unobvious.
Response to Arguments
29. Applicant's arguments filed 3/23/26 have been fully considered but they are not persuasive. However, the applicant’s amendments have overcome the previous claim objections and 35 U.S.C. 103 rejection, as noted above.
a) Response to 35 U.S.C. 101 arguments (not an abstract idea)
30. The Examiner respectfully disagrees in regards to the 35 U.S.C. 101 rejection, therefore it is maintained. The claims are directed to an abstract idea of voucher verification, which falls under commercial or legal interactions, or could also fall under fundamental economic practices. In MPEP 2106.04(a)(2), it describes concepts relating to managing relationships or transactions between people, or satisfying or avoiding a legal obligation, as being under certain methods of organizing human activity. Voucher verification would fall under sales activities or behaviors and business relations, therefore, the claims are directed to an abstract idea.
b) Argument #2: Applicant argues that the abstract idea is integrated into a practical application under Step 2A, Prong 2 (improvement in technology)
31. The Examiner respectfully disagrees. In regards to improving the functioning of the computer/technology/technical field, the claims recite a learned determination model, memory portion, receiving portion, processing portion, and database, and they are recited at a high level of generality, and therefore are merely using computer processing components for voucher verification. After further review of the Specification, there is no disclosure of technical enhancements to any of the computing components, as in multiple instances of the Specification it discloses generally recited elements. Interpreting the claims in view of the Specification, the claims recite the judicial exception are mere instructions to apply the exception of voucher verification (see MPEP 2106.05(f)). The elements recited above do not recite and are not directed to any elements or functions that improve underlying technology.
32. According to MPEP 2106.05(a), it states: “It is important to note that in order for a method claim to improve computer functionality, the broadest reasonable interpretation of the claim must be limited to computer implementation. That is, a claim whose entire scope can be performed mentally, cannot be said to improve computer technology. Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 120 USPQ2d 1473 (Fed. Cir. 2016) (a method of translating a logic circuit into a hardware component description of a logic circuit was found to be ineligible because the method did not employ a computer and a skilled artisan could perform all the steps mentally). Similarly, a claimed process covering embodiments that can be performed on a computer, as well as embodiments that can be practiced verbally or with a telephone, cannot improve computer technology. See RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1328, 122 USPQ2d 1377, 1381 (Fed. Cir. 2017) (process for encoding/decoding facial data using image codes assigned to particular facial features held ineligible because the process did not require a computer).”
33. Furthermore, in determining whether a claim integrates a judicial exception into a practical application, a determination is made of whether the claimed invention pertains to an improvement in the functioning of the computer itself or any other technology or technical field (i.e., a technological solution to a technological problem). Here, the claims recite generic computer components, i.e., a learned determination model, memory portion, receiving portion, processing portion, and database, that are recited at a high level of generality and are recited as performing generic computer functions customarily used in computer applications. The pending claims do not describe a technical solution to a technical problem. The pending claims are directed to voucher verification. The claims of the instant application describe an improvement to a business process i.e., voucher verification, not improvement in the functioning of the computer itself or an improvement to any other technology or technological field. Therefore, the claims do not integrate into a practical application either by improvement to a computer/technology/technical field.
34. The claims are not directed to any improvement in computer technology. Claims are directed to an abstract idea of voucher verification. Applicant must take into consideration that in order to view the claims as supplying an inventive concept the technological improvement must be present within the claims themselves (Accenture Global Servs., GmbH v. Guidewire Software, inc., 108 USPQ2d 1173 (Fed. Cir. 2013)), (Synopsys, inc. v. Mentor Graphics Corp... 120 USPQ2d 1473 (Fed. Cir. 2016). Additionally, the Specification does not provide any evidence that how the claims provide an improvement to functioning of computing systems or technology. Applicant failed to provide persuasive arguments supported by any necessary evidence to demonstrate that one of ordinary skill in the art would understand that the disclosed invention improves technology.
c) Argument #3: Applicant argues claim is directed to more than a mere drafting effort to monopolize a judicial exception
35. The applicant argues that there is a practical application of the judicial exception under Step 2A Prong 2 because it is not monopolizing all possible methods for voucher verification. The Examiner respectfully notes that the determination of whether claims include features that are a drafting effort designed to monopolize the abstract idea is not a separate analysis, but rather a conclusion that is reached after consideration of prong 2 and recognizing a lack of integration of the claims into a practical application. Applicant’s additional arguments fail to comply with 37 CFR 1.111(b) because they amount to a general allegation that the claims define a patentable invention without specifically pointing out how the language of the claims defines patent eligible subject matter.
36. According to the MPEP: “In contrast, the claims in Alice Corp. v. CLS Bank International did not meaningfully limit the abstract idea of mitigating settlement risk. 573 U.S. 208, 110 USPQ2d 1976 (2014). In particular, the Court concluded that the additional elements such as the data processing system and communications controllers recited in the system claims did not meaningfully limit the abstract idea because they merely linked the use of the abstract idea to a particular technological environment (i.e., "implementation via computers") or were well-understood, routine, conventional activity recited at a high level of generality. 573 U.S. at 225-26, 110 USPQ2d at 1984-85. Similarly, in this case, the abstract idea of information processing with cargo is linked to generally recited devices, therefore, the claims are not meaningfully limiting the abstract idea. Therefore, the claims do not integrate into a practical application either by improvement to a computer/technology/technical field, nor do they impose a meaningful limit on the judicial exception, such that the claim is more than a drafting effort designed to monopolize the exception.
37. Accordingly, there are no meaningful limitations in the claims that transform the judicial exception into a patent eligible application such that the claims amount to significantly more than the judicial exception itself. The dependent claims do not resolve the deficiency of the independent claims and accordingly stand rejected under 35 U.S.C. 101 based on the same rationale.
Conclusion
38. The prior art made of record and not relied upon is considered pertinent to applicant's disclosure: Lahann, Johannes et al (Utilizing Machine Learning Techniques to Reveal VAT Compliance Violations in Accounting Data, NPL) is found to be the most pertinent NPL prior art.
39. THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
40. 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.
41. Any inquiry concerning this communication or earlier communications from the examiner should be directed to FAWAAD HAIDER whose telephone number is (571)272-7178. The examiner can normally be reached Mon-Fri 8 AM to 5 PM.
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/FAWAAD HAIDER/
Primary Examiner, Art Unit 3627
Prosecution Insights