Prosecution Insights
Last updated: October 02, 2026
Application No. 18/065,500

INVOICE PAYMENT AUTHORIZATION PLATFORM

Final Rejection §101
Filed
Dec 13, 2022
Examiner
SALMAN, AVIA ABDULSATTAR
Art Unit
3627
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Target Brands Inc.
OA Round
4 (Final)
49%
Grant Probability
Moderate
5-6
OA Rounds
0m
Est. Remaining
91%
With Interview

Examiner Intelligence

Grants 49% of resolved cases
49%
Career Allowance Rate
99 granted / 203 resolved
-3.2% vs TC avg
Strong +42% interview lift
Without
With
+42.1%
Interview Lift
resolved cases with interview
Typical timeline
3y 4m
Avg Prosecution
29 currently pending
Career history
232
Total Applications
across all art units

Statute-Specific Performance

§101
37.3%
-2.7% vs TC avg
§103
44.4%
+4.4% vs TC avg
§102
3.7%
-36.3% vs TC avg
§112
11.1%
-28.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 203 resolved cases

Office Action

§101
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 is in reply to communication filed on 06/17/2026. Claims 1-12 and 20 have been cancelled. Claims 13, 18 and 21 have been amended. Claims 13-19 and 21 are currently pending and have been examined. Response to Arguments In response to Applicant Arguments /Remarks made in an amendment filled on 06/17/2026: Regarding 35 USC § 101 rejection: Applicant argument submitted under the title “Claim Rejections Under 35 U.S.C. § 101” in pages 7-13, that: Applicant's arguments have been fully considered but they are not persuasive. The applicant argues that the amended claims do not recite a mental process because the claims require parallel rate and event checks, multiple temporally dependent inputs, decoupled models and rules, and computerized updating of outputs. Applicant further argues that the claims do not recite a certain method of organizing human activity because they do not regulate or organize human conduct. In response, the examiner respectfully disagrees. The claims recite underlying evaluations and determinations including evaluating invoice and transaction data according to rules, determining whether results satisfy acceptability criteria, determining whether an invoice should be approved or rejected, evaluating candidate locations, and updating evaluation criteria, these limitations constitute evaluations, judgments, and decision-making falling within the mental-process grouping, notwithstanding that the claims implement the evaluations using computerized components. The claims also recite a certain method of organizing human activity, specifically commercial interactions involving invoice auditing, payment approval, rejection, payment processing, and exception handling between commercial entities. The fact that the process is computer-implemented does not remove the underlying commercial activity form the abstract-idea grouping. Furthermore, applicant argues that the claims solve a technical problem involving disjointed data sources and asynchronous information by using rate and load APIs, parallel checks, decoupled rules and models, and updates as data becomes available. In response, the examiner respectfully disagrees. These limitations improve the manner in which invoice information is collected and evaluated, but the claims do not recite a specific improvement to computer functionality, database technology, API operation, communication protocols, or parallel-processing technology. The rate API, Load API, audit database, and parallel checks are used as tools to more efficiently perform the underlying commercial determination of whether an invoice should be approved or rejected. Accordingly, the abstract idea is not integrated into a practical application. Additionally, applicant further argues that the ordered combination of parallel checks, decoupled models and rules, and continuous updating provides an inventive concept and that the Office has not established that the combination is well-understood, routine, or conventional. In response, the examiner respectfully disagrees, as the maintenance of the rejection does not rely on a finding that the claimed limitations are well-understood, routine, or conventional. When considered individually and as an ordered combination, the additional computer elements merely organize and automate the abstract invoice-auditing process. They do not impose a meaningful limitation on the judicial exception or provide a technological operation distinct form the underlying commercial and analytical process. For the reasons above along with the reasons set forth in the updated §101 rejection set forth below, Applicant's amendments and arguments concerning the §101 rejection are not sufficient to overcome the rejection. Claim Rejections - 35 USC § 101 35 U.S.C. 101 reads as follows: Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title. Claims 13-19 and 21 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception without significantly more. Step 1: Claims 13-19 recite a method, which is directed to a process. Claim 21 recites a platform, which is directed to a machine. Therefore, each claim falls within one of the four statutory categories. Step 2A, Prong 1 (Is a judicial exception recited?): The independent claims 13 and 21 recite the abstract idea of tracking loads of items within a supply chain and managing corresponding invoices, see specification [0001]. A) These claims recite a certain method of organizing human activity. The claims recite to a certain method of organizing human activity as the above abstract idea limitations are directed to a commercial interaction and managing personal behavior or relationships or interactions between people. The examiner finds the claims to simply recite steps of following rules or instructions of receiving information, generating information, displaying results, and commercial interaction involving invoice auditing, payment processing, and manual exception handling. The claims recite receiving EDI and non-EDI invoices, evaluating invoice and transaction data according to business models and rules, determining whether invoice data satisfies bounded acceptability levels, approving or rejecting invoices, presenting rejected invoices for manual review, receiving user selecting to resolve rejected invoices, and updating processing. These limitations constitute commercial activities directed to managing financial transactions between shippers and retail enterprise. B) The claims recite a mental process. The claims also recite an abstract idea in form of mental processes because they include observations, evaluations, judgments, and decision-making capable of being performed in the human mind or with the aid of pen and paper. For example, the claims recite evaluating invoice and transaction data against stored models and rules, determining whether system outputs satisfy bounded acceptability levels, determining whether an invoice should be approved or rejected, selecting an invoice for manual review, identifying candidate locations corresponding to invoice data, receiving a user selection among candidate locations, and updating models and rules based on proper invoice assessments. These limitations merely automate analytical judgments that could otherwise be performed mentally. Therefore, claims 13 and 21 recite an abstract idea. Step 2A, Prong 2 (Is the exception integrated into a practical application?): This judicial exception is not integrated into a practical application because the claims satisfy the following criteria, which indicate that the claims do not integrate the abstract idea into practical application: The claimed additional limitations are: Claim 13: computer, an invoice management software platform, audit database can be accessed via an audit UI, an automated invoice processing API, the audit UI further comprises a first user interface and a second user interface, rate API, Load API Claim 21: at least one computing system of a retail enterprise, the at least one computing system including a processor and a memory storing instructions which, when executed, cause the at least one computing system, an invoice management software platform, computer, audit database can be accessed via an audit UI, an automated invoice processing API, the audit UI further comprises a first user interface and a second user interface, , rate API, Load API The additional limitations are directed to using a generic computer to process information and perform the abstract idea. Therefore, the limitations merely amount to adding the words “apply it” (or an equivalent) to the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea, as discussed in MPEP 2106.05(f). Although the claims recite performing a system event check in parallel with a system rate check, generating outputs, transmitting updates between software components, displaying aggregated invoice information, and updating models and rules, these operating merely facilitate execution of the underlying invoice auditing and payment workflow. The claims do not recite any improvement to computer functionality, database technology, user-interface technology, networking technology, API architecture, or any other technological field. Rather, the computer components are used as tool to execute the abstract commercial process more efficiently. Likewise, the recited audit database stores models and rules used to evaluate invoices, while the audit user interfaces merely present information and receive user input during manual review. These elements implement the abstract idea without imposing any meaningful technological limitation on how the computer itself operates. Accordingly, claims 13 and 21 are directed to abstract idea as the judicial exception is not integrated into a practical application. Step 2B (Does the claim recite additional elements that amount to significantly more that the judicial exception?): The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Viewed as an ordered combination, the claims merely automate the longstanding business practice of auditing invoices, determining whether invoices satisfy predetermined criteria, approving qualifying invoices, routing exceptions for manual review, receiving user decisions, and updating evaluation criteria based upon prior invoice processing. The additional computer components perform their ordinary functions of receiving information, storing data, executing programmed instructions, transmitting information between software components, displaying information to users, and receiving user input. The ordered combination therefore merely links the abstract ideas to a generic computer environment without imposing a meaningful limitation on the judicial exception or effecting an improvement in computer technology itself. Accordingly, claims 13 and 21 are directed to abstract idea, without significantly more than the abstract idea. In addition, the dependent claims recite: Claims 14-17 and 19 further limit the abstract idea by specifying particular types of invoice data, particular data formats, Boolean or probabilistic outputs, or additional invoice relationships. These limitations merely refine the information being collected, analyzed, displayed, or used in the commercial decision-making process and therefore remain directed to the same abstract ideas. They do not integrate the judicial exception into a practical application not provide additional elements amounting to significantly more than the abstract idea. In addition, claim 18 further the system rate check output and system event check output are probabilities and that the automated invoice processing API comprises a machine learning module configured to determine a probability indicative of a level of risk based on training data. These additional limitations merely employ a machine learning model to perform the same abstract evaluation of invoice risk used in determining whether invoices should be approved or rejected. The claim does not recite an improvement to machine learning technology, model training, computer functionality, or any other technological field. Rather, the machine learning module serves as another analytical tool for carrying out the abstract ideas (i.e., the commercial process). Accordingly, claim 18 also does not integrate the judicial exception into a practical application or recite significantly more than the abstract idea. Therefore, the limitations on the invention of claims 13-19 and 21, when viewed individually and in ordered combination are directed to in-eligible subject matter. Distinguished Over Prior Art Examiner is in agreement with applicant’s amendments and arguments filed on 02/26/2026. The claims 13-19 and 21, in present form, have overcome the prior art rejections and the examiner has been unable to find the claimed limitations in the prior art. The prior art on record, alone or in combination, neither anticipates, reasonably teaches, nor renders obvious the applicant's claimed invention. The examiner has been unable to find the claimed limitations in any prior art. Accordingly, the applicant needs to address the outstanding rejections above in order to issue an allowability notice. The reason to withdraw the 35 USC 103 rejection of claims 13-19 and 21 in the instant application is because the prior art of record fails to teach the overall combination as claimed. Therefore, it would not have been obvious to one of ordinary skill in the art to modify the prior art to meet the combination above without unequivocal hindsight and one of ordinary skill would have no reason to do so. Upon further searching the examiner could not identify any prior art to teach these limitations. The prior art on record, alone or in combination, neither anticipates, reasonably teaches, not renders obvious the Applicant’s claimed invention. Accordingly, the examiner recommends addressing the outstanding rejections above. Conclusion 1. THIS ACTION IS MADE FINAL. 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. 2. Any inquiry concerning this communication or earlier communications from the examiner should be directed to AVIA SALMAN whose telephone number is (313)446-4901. The examiner can normally be reached Monday thru Friday; 9:00 AM to 5:00 PM EST. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, FAHD OBEID can be reached at (571) 270-3324. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /AVIA SALMAN/Primary Patent Examiner, Art Unit 3627
Read full office action

Prosecution Timeline

Show 8 earlier events
Feb 26, 2026
Request for Continued Examination
Mar 13, 2026
Response after Non-Final Action
Mar 31, 2026
Non-Final Rejection mailed — §101
May 13, 2026
Interview Requested
May 19, 2026
Applicant Interview (Telephonic)
May 21, 2026
Examiner Interview Summary
Jun 17, 2026
Response Filed
Aug 13, 2026
Final Rejection mailed — §101 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

5-6
Expected OA Rounds
49%
Grant Probability
91%
With Interview (+42.1%)
3y 4m (~0m remaining)
Median Time to Grant
High
PTA Risk
Based on 203 resolved cases by this examiner. Grant probability derived from career allowance rate.

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