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
This action is in reply to the communication(s) filed on 29 December 2025.
Claims 1, 10 and 18 are amended.
Claim(s) 1-20 is/are currently pending and have been examined.
Response to Arguments
Applicant's arguments filed 29 December 2025 have been fully considered but they are not persuasive.
Rejection Under 35 U.S.C. §112
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). New 112 rejections are entered based on the entered amendments.
Rejection Under 35 U.S.C. §101
Step 2A Prong One
Applicant asserts that the Office rejected the claims under 35 U.S.C. §101 as being directed to the abstract idea of a Mental Process. This is incorrect. The claims were and are rejected under 35 U.S.C. §101 as being directed to the abstract idea of Certain Methods of Organizing Human Activity. As such any and all arguments relating to being directed to a Mental Process are moot.
Applicant further asserts that the claims do not recite “observation, evaluation, judgement and opinion” or “following rules or instructions”. Examiner notes that it was never asserted that the claims recited such abstract ideas. As such, any and all arguments with respect to these abstract ideas are moot.
Applicant argues that none of the claim elements are directed to “certain methods of organizing human activity” and do not recite what is required for a method of organizing human activity. 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.
Step 2A Prong Two
Applicant argues that the claims integrate the alleged abstract idea into a practical application by requiring a platform that accounts for lack of shared information and allows for customized solutions that are suitable for coordination across multiple entities. Examiner respectfully disagrees. 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 that their claims are eligible for reasons similar to those in Enfish. Examiner respectfully disagrees. In Enfish, the claims at issue focused not on asserted advances in uses to which existing computer capabilities could be put, but on a specific improvement-a particular database technique-in how computers could carry out one of their basic functions of storage and retrieval of data. In Enfish v. Microsoft, the United States Court of Appeals for the Federal Circuit decision… that “the self-referential table recited in the claims on appeal is a specific type of data structure designed to improve the way a computer stores and retrieves data in memory” which is “directed to a specific implementation of a solution to a problem in the software arts.” See also details in re TLI Communication LLC. In contrast, the instant claims provide a generically computer-implemented solution to a business-related or economic problem and are thus incomparable to the claims at issue in Enfish. The present case is different: the focus of the claims is not on such an improvement in computers as tools, but on certain independently abstract ideas that use computers as tools. The claims here are not directed to a specific improvement to computer functionality nor an inventive solution to any computer specific problem. The case of Enfish does not apply.
Applicant argues the newly amended limitations improves computer functionality by providing less stress on the system. Examiner respectfully disagrees. Examiner notes that applicant’s purported improvement (as explained above) 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.
Step 2B
Applicant argues that amended claim 1 recites significantly more than the alleged abstract idea under Step 2B because the element is not well known in the art and existing solutions do not have the ability to process data from multiple sources and validate that information properly. Examiner respectfully disagrees with this conclusion. 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 will interpret “eligible recipients” in Claim 5 to be recipients who are eligible for payment distribution (as is supported by the specification at paragraph [0062]).
Examiner will interpret “configuration-based” in Claim 7 to be equivalent to “preconfigured”, “predefined”, or “customizable to specify under which conditions a particular setting is applied” (as is supported by the specification at paragraph [0063]).
Examiner notes that “a payment recipient” recited in Claim 13 is a different recipient from “a recipient” in Claim 10 as noted by the applicant in the remarks dated 05 March 2025.
Claim Rejections - 35 USC § 112
The following is a quotation of 35 U.S.C. 112(b):
(b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention.
The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph:
The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention.
Claims 1-20 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention.
The independent claims recite “…based on the calculated payment eligibility amount…”. It is unclear what is meant by the phrase “payment eligibility amount” as there is a prior recited “at least one of payment eligibility and payment amount” but no single “payment eligibility amount”. Examiner will interpret it to recite “authorize, based on the at least one of payment eligibility and payment amount, an automatic payment to the recipient” for purposes of examination.
Any remaining claims not expounded upon are rejected based on their dependency to a rejected claim.
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 a system, non-transitory computer-readable medium, and method for multi-party payment disbursement. These are a machine, article of manufacture, and process 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, 10 and 18:
Claim(s) 1, 10 and 18:
“receive,…, a request to authenticate a recipient file template, wherein the recipient file template contains data fields for a recipient;”
“process, the data fields for validation to ensure data in the data fields is processed once for the recipient and there is no overlapping data from at least one of multiple entities within the system or multiple file templates;”
“validate, based on user-specified rules, that the data fields match user requirements, the data fields including personal identifiable information of the recipient wherein the rules are customized by the user based on information needed to validate and authorize the payment distribution to the recipient;”
“determine whether to authenticate the recipient file template based on the validation;”
“calculate, upon authentication of the recipient file template and based on the data fields, at least one of payment eligibility and payment amount;”
Claim(s) 1:
“authorize, based on the calculated payment eligibility amount, an automatic payment to a recipient;”
“send the payment to a payment disbursement system…”
Claim(s) 10 and 18:
“authorize, based on the calculated payment eligibility amount, a payment to a recipient;”
“notify the recipient of a status of the payment, using a payment disbursement system,…”
These limitations, as drafted, are a process that, under its broadest reasonable interpretation, describes Fundamental Economic Principles or Practices or Commercial or Legal Interactions but for the recitation of generic computer components. That is, other than reciting “a database, a memory storing instructions”, “at least one processor configured to execute the instructions to:”, “computer-implemented”, or “A computer-implemented method for automatic payment distribution, comprising:” nothing in the claims’ elements precludes the steps from practically describing Fundamental Economic Principles or Practices or Commercial or Legal Interactions. For example, but for the recited computer language, the limitations in the context of this claim describes Mitigating Risk or could reasonably describe business relations. Mitigating Risk is described when determining appropriate payees for disbursement. Business Relations is described when disbursing payment to recipients. If a claim limitations, under their broadest reasonable interpretation, describes Fundamental Economic Principles or Practices or Commercial or Legal Interactions 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) 4, 6, 8, 11, 13, 15-16 and 19-20 are directed to the following:
Claim(s) 4:
“generating a notification if the payment is attempted more than once.”
Claim(s) 6:
“denying authorization of another payment to the recipient;”
Claim(s) 8:
“…sending a notification of at least one of an email, text message, phone call, or system alert, based on the user-specified rules when a payment is sent to a payment disbursement system.”
Claim(S) 11:
“…wherein the operations further comprise determining a user’s authorization or status, wherein the user includes at least one of a read-only user, an upload-only user, a call center agent, or an administrator.”
Claim(s) 13:
“…wherein the operations further comprise a call center agent performing at least one of:… reporting a payment recipient;… reviewing payment history;”
Claim(s) 15:
“validating the payment recipient’s address;”
“confirming financial information with a financial institution.”
Claim(s) 16:
“…wherein the operations further comprise the payment recipient receiving multiple payments.”
Claim(s) 19:
“…wherein the user-specified rules are customized by an employing entity.”
Claim(s) 20:
“…wherein the operations further comprise an administrator changing the user requirements.”
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.
Dependent claim(s) 3-5, 7, 9, 12, 14 and 17 include the following limitations which are not directed to any additional abstract ideas and are also not directed to any additional non-abstract claim elements:
Claim(s) 3:
“…wherein the payment to the recipient further comprises a payment method of at least one of a check, ACH payment, or debit to a bank account.”
Claim(s) 4:
“…wherein the payment method is one of a plurality of payment methods…”
Claim(s) 5:
“…wherein the recipient is selected from a database of eligible recipients.”
Claim(s) 7:
“…wherein the user-specified rules are configuration-based.”
Claim(s) 9:
“…wherein each payment is an encrypted transaction.”
Claim(s) 12:
“…wherein an administrator has full permissions within the user-specified rules including changing the payment recipient’s address, re-issuing check payments, or flagging payments for review.”
Claim(s) 14:
“…wherein the data fields include personal identifiable information.”
Claim(s) 17:
“…wherein the payment amount has a limit based on user-specified rules.”
Rather, these claims offer further descriptive limitations of elements found in the independent claims and addressed above – such as by describing the nature and content of the data that is received/sent. While these descriptive elements may provide further helpful context for the claimed invention these elements do not serve to confer subject matter eligibility to the invention since they merely represent a narrowing of the recited judicial exception. Step 2A prong 2 and Step 2B for these limitations therefore are the same as for the independent claims.
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 1:
“a database;”
“a memory storing instructions;”
“at least one processor configured to execute the instructions to perform operations comprising:”
Claim(s) 1, 10 and 18:
“…from a user device of a user…”
“…wherein the payment disbursement system is configured with a search screen on a graphical user interface, the search screen including a button to customize fields to search for the recipient.
Claim 10:
“A non-transitory computer-readable medium including instructions that, when executed by at least one processor, cause the at least one processor to perform operations for automatic payment distribution, comprising:”
The computer components or other machinery (database, memory, non-transitory computer-readable medium and user device) are recited at a high level of generality (i.e. as a generic database, generic memory, and user device) 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 use of a search screen with customizable search via button 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, 4, 6 and 13 contain the following additional elements:
Claim(s) 2:
“…wherein the operations further comprise logging each authorized payment to a recipient as a transaction.”
Claim(s) 4:
“logging each payment method in a positive pay file;”
Claim(s) 6:
“logging the denied authorization of the another payment to the recipient.”
Claim(s) 13:
“…wherein the operations further comprise a call center agent performing at least one of: searching for a payment recipient;… searching a database;… viewing payment status.”
The computer components or other machinery (database) are recited at a high level of generality (i.e. as a generic database) 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 logging, searching, and viewing step(s) are recited at a high level of generality (i.e., as simply logging, simply searching, and simply viewing) 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 user device mentioned above is/are not described in further detail within the applicant’s specification. Therefore examiner must interpret these elements as generic computer components.
The database and non-transitory computer-readable medium mentioned above is/are disclosed in applicant’s specification (See paragraph [0042] of the specification). The components are described as:
“The various components of system 100 may be stored in database 102. Database 102 may be included on a volatile or non-volatile, magnetic, semiconductor, tape, optical, removable, non-removable, or other type of storage device or tangible or non-transitory computer-readable medium. Database 102 may include one or more memory devices that store data and instructions used to perform one or more features of the disclosed embodiments. Database 102 may include any suitable databases, ranging from small databases hosted on a work station to large databases distributed among data centers. Database 102 may also include any combination of one or more databases controlled by memory controller devices or software. For example, database 102 may include document management systems, Microsoft SQL™ databases, SharePoint™ databases, Oracle™ databases, Sybase™ databases, other relational databases, or non-relational databases, such as Mongo and others.”
The processor mentioned above is/are disclosed in applicant’s specification (See paragraph [0058] of the specification). The component is described as:
“Processor 220 may take the form of, but is not limited to, a microprocessor, embedded processor, or the like, or may be integrated in a system on a chip (SoC). Furthermore, according to some embodiments, processor 220 may be from the family of processors manufactured by Intel®, AMD®, Qualcomm®, Apple®, NVIDIA®, or the like. The processor 220 may also be based on the ARM architecture, a mobile processor, or a graphics processing unit, etc. The disclosed embodiments are not limited to any type of processor configured in server 210.”
The memory mentioned above is/are disclosed in applicant’s specification (See paragraph [0059] of the specification). The component is described as:
“Memory 230 may include one or more storage devices configured to store instructions used by the processor 220 to perform functions related to server 210. The disclosed embodiments are not limited to particular software programs or devices configured to perform dedicated tasks. For example, the memory230 may store a single program, such as a user-level application, that performs the functions associated with the disclosed embodiments, or may comprise multiple software programs. Additionally, the processor 220 may, in some embodiments, execute one or more programs (or portions thereof) remotely located from server 210. Furthermore, memory230 may include one or more storage devices configured to store data for use by the programs. Memory 230 may include, but is not limited to a hard drive, a solid state drive, a CD-ROM drive, a peripheral storage device (e.g., an external hard drive, a USB drive, etc.), a network drive, a cloud storage device, or any other storage device.”
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. Accordingly, the Examiner:
• Carries over their identification of the additional element(s) in the claim from Step 2A Prong Two;
• Carries over their conclusions from Step 2A Prong Two on the considerations discussed in MPEP §§ 2106.05(a) - (c), (e) (f) and (h):
• Re-evaluates 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.
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 logging/searching for/viewing various data) Storing and retrieving information in memory, (See MPEP § 2106.05(d)(II)).
(for viewing 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.
Cronin et al. (US 2019/0272597 A1) discloses employee based payroll validation including PII such as employee name.
Connor et al. (US 2023/0058933 A1) discloses filtering rules for validation where they may apply a rule to prepare a retrieved payment for potential duplicate payment matching based on payment amount when the payment destination account is a consumer card or business card (i.e. rules customized based on recipient account information).
Noland et al. (US 2017/0132200 A1) discloses searching data files with a search screen with search fields wherein the search fields are customizable via a button.
John et al. (US 8,078,515 B2) discloses recording user activity and historical records including history of charge-backs and historical record of rejection (i.e. logging the denied authorization).
Franceschi et al. (US 2020/0211012 A1) discloses that an administrator may flag transactions for review and restricting transaction amounts based on a user class.
Joyce et al. (WO 00/16568 A1) discloses a payment system may contain call center agents that can select accounts from a menu (i.e. search for payment recipient and searching a database) and display details of the selected account including payments and payment details (i.e. reviewing payment history and viewing payment status).
Kearns et al. (US 2015/0032604 A1) discloses call center agents making reports of DNR transactions.
Orttung et al. (US 2013/0226798 A1) discloses implementing user defined rules for electronic payment.
Rajendran et al. (US 2021/0295285 A1) discloses removing duplicate entries stored in a database.
Ainslie et al. (WO 2014/052970 A1) discloses how the presence of PII may affect usage policies.
Edlabadkar et al. (“IBM Financial Transaction Manager for Automated Clearing House Services”) discloses operations for an ACH including operations for business rules.
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 ADAM J HILMANTEL whose telephone number is (571)272-8984. The examiner can normally be reached M-F 8:30AM-5:00PM.
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, Abhishek Vyas can be reached at (571) 270-1836. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/A.H./Examiner, Art Unit 3691
/ABHISHEK VYAS/Supervisory Patent Examiner, Art Unit 3691
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