DETAILED ACTION
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Notice of Pre-AIA or AIA Status
This action is in response to the election filed 1/20/2026. Applicant has elected Invention I (claims 1-15) without traverse, amended claims 1 and 14, cancelled claims 16-20 and added new claims 21-25. Accordingly, claims 1-15 and 21-25 are pending for examination.
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1-15 and 21-25 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
Claims 1 and 21 recite the abstract idea of “generating prepaid account and funding prepaid account in response to determining funding rule has become satisfied”, which is grouped under “Certain Methods of Organizing Human Activity” such as “fundamental economic principles or practices” (mitigating risk), “commercial or legal interactions” (agreements; sales activities or behaviors). (MPEP 2016.04(a)). Specifically, claims 1 and 21 recite “receive … from a user…, at least one message comprising information identifying: user profile information to be associated with a prepaid account, funding source identification identifying a financial source to be used for temporarily funding the prepaid account, and a schedule identifying when the prepaid account is to be used to pay for a purchase”, “send an account key …of the payment processing system”, “generate the prepaid account with a logical association to the account key, the user profile information, the funding source identification, and the schedule”, “determine when a funding rule has become satisfied based on at least the schedule” and “respond to determining the funding rule has become satisfied, by funding the prepaid account from the financial source identified by the funding source identification”. Claims 2-15 and 22-25 are dependent on claims 1 and 21 and include all the limitations of claims 1 and 21. Therefore, claims 2-15 and 22-25 recite the same abstract idea of “generating prepaid account and funding prepaid account in response to determining funding rule has become satisfied”. The limitations recited in the depending claims (For example, the processing, communicating, determining, delaying, returning, deducting steps) are further details of the abstract idea and not significantly more. The concept described in claims 1-15 and 21-25 are not meaningfully different than those concepts found by the courts to be abstract ideas. As such, the description in claims 1-15 and 21-25 is an abstract idea. Accordingly, the claims recite an abstract idea.
This judicial exception is not integrated into a practical application because, when analyzed under prong two of step 2A (MPEP 2106.04II), the additional elements of independent claims 1 and 21 such as “a network interface”, “a processor”, “a memory storing instructions executable by the processor”, “through the network interface” and “user device” and additional elements of depending claims 2-15 and 22-25 (for example: “server (claim 2)”, “vehicle/vehicle-based (claims 2-3, 22-23)”, “aircraft flight (claims 4-7, 12-15 and 24”, “message…indicating loss of communication connectivity (claims 7, 15)”, “radio transceiver” (claims 7, 15) represent the use of a computer as a tool to perform an abstract idea and/or does no more than generally link the abstract idea to a particular technological environment or field of use. Further, as the additional elements do not provide a practical application, they do not improve computer functionality and do not improve another technology or technical field.
When analyzed under step 2B (MPEP 2106.04II), because the additional elements do no more than represent the use of a computer as a tool to perform an abstract idea and/or does no more than generally link the abstract idea to a particular field of use, they do not provide an improvement to computer functionality, or an improvement to another technology or technical field and, therefore, do not amount to significantly more than the judicial exception itself (MPEP 2106.05(I)(A)(f)&(h)).
Hence, claims 1-15 and 21-25 are not patent eligible.
Claim Rejections - 35 USC § 103
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
Claims 1-3 and 21-23 are rejected under 35 U.S.C. 103 as being unpatentable over Kwok et al. (US 2022/0141215 A1) in view of Salkini et al. (US 2008/0182553 A1).
As per Claims 1, 21
Kwok (‘215) discloses
a network interface, see at least paragraph 0062 (computing device is online e.g. connected to Internet), paragraph 0051 (communicate …over a network e.g. the Internet or other networking protocol), paragraph 0049 (Bluetooth, WiFi, a local network, NFC or other electronic communication)
a processor, see at least paragraphs 0004-0006 (processor), paragraph 0022 (processing devices; microprocessor)
a memory storing instructions executable by the processor, see at least paragraph 0006 (processor is configured to implement software instructions), paragraph 0109 (computer-executable program instructions stored in memory)
receive through the network interface from a user device, at least one message comprising information, see at least paragraph 0061 (the API may communicate the API request with the baseline information attributes over a network e.g. the internet…to the data enrichment service), paragraph 0004 (receive, by at least one processor, an activity record including activity details associated with an account activity request in a user account; flight booking, the flight data including a flight departure time)
send an account key (token) through the network interface of the payment processing system, see at least paragraph 0134 (download …the temporary offline token at a computer device to form an offline pre-approved payment device), paragraph 0049 (communicating the offline limited-use token can include an electronic communication via, e.g. Bluetooth, WiFi, a local network, NFC or by other electronic communication technics)
Kwok (‘215) discloses the message comprising information identifying: user profile information to be associated with account and a schedule identifying when the account is to be used to pay for a purchase, paragraph 0004 (receive, by at least one processor, an activity record including activity details associated with an account activity request in a user account; flight booking, the flight data including a flight departure time; temporary offline token includes account access restrictions;…the temporary offline token being active during a flight based on the flight departure time and a temporary offline token entity binding associated with the temporary online token being bound to the airline for performing n-flight account activity requests with the airline), paragraph 0134 (offline pre-approved payment device using the generate an entity binding including the airline for the flight specified in the itinerary record such that the offline limited-use token is bound to the airline for in-flight purchases), paragraph 0019 (maintaining activity histories for each user account), but fails to explicitly disclose the account is a prepaid account and the message comprising funding source identification identifying a financial source to be used for temporarily funding the prepaid account. Salkini (‘553) teaches a prepaid account and message comprising funding source identification identifying a financial source to be user for temporarily funding the prepaid account, see at least Abstract of Salkini (over the air OTA prepaid system), paragraph 0055 (accessing the OTA prepaid feature will be checked to verify a valid voucher; credit and deb it card access can be established so that the automated charging occurs when the established prepaid account triggers a recharge event; the trigger may be based on time, balance or other defined event), claim 4 of Salkini (establishing a balance to fund a prepaid account), paragraph 0027 (temporary prepaid), claim 13 of Salkini (establishing the prepaid account balance), paragraph 0024 (messaging, to transfer funds from the voucher to the user’s account). Both Kwok and Salkini are directed to over-the-air payment system. Therefore, it would be obvious to one of ordinary skill in the art before the effective filing date for the claimed invention to modify Kwok’s invention to include the account is a prepaid account and the message comprising funding source identification identifying a financial source to be used for temporarily funding the prepaid account. One would have been motivated to do so for the benefit of allowing the account be funded.
Kwok (‘215) discloses account with a logical association to the account key (offline token associated with the account), the user profile information (activity histories for user account) and the schedule and determine when a funding rule has become satisfied based on at least the schedule, see at least Abstract of Kwok (generates an offline token associated with the user account, including account access restricts; binds the offline token to the duration of the flight), paragraph 0004 (temporary offline token includes account access restrictions;…the temporary offline token being active during a flight based on the flight departure time and a temporary offline token entity binding associated with the temporary online token being bound to the airline for performing n-flight account activity requests with the airline), paragraph 0019 (maintaining activity histories for each user account), but fails to explicitly disclose the account is a prepaid account, generate the account with logical association to the funding source identification and respond to determining the funding rule has become satisfied, by funding the prepaid account from the financial source identified by the funding source identification. Salkini (‘553) teaches the account is a prepaid account, generate the account with logical association to the funding source identification and respond to determining the funding rule has become satisfied, by funding the prepaid account from the financial source identified by the funding source identification, see at least Abstract of Salkini (over the air OTA prepaid system), paragraph 0055 (accessing the OTA prepaid feature will be checked to verify a valid voucher; credit and deb it card access can be established so that the automated charging occurs when the established prepaid account triggers a recharge event; the trigger may be based on time, balance or other defined event), claim 4 of Salkini (establishing a balance to fund a prepaid account), paragraph 0027 (temporary prepaid), claim 13 of Salkini (establishing the prepaid account balance), paragraph 0024 (messaging, to transfer funds from the voucher to the user’s account), paragraph 0025 (establish an account; voucher…adding money to the user’s account). Both Kwok and Salkini are directed to over-the-air payment system. Therefore, it would be obvious to one of ordinary skill in the art before the effective filing date for the claimed invention to modify Kwok’s invention to include the account is a prepaid account, generate the account with logical association to the funding source identification and respond to determining the funding rule has become satisfied, by funding the prepaid account from the financial source identified by the funding source identification. One would have been motivated to do so for the benefit of reducing risk.
As per Claim 2
Kwok (‘215) discloses wherein the network interface, the processor, and the memory are part of a networked server operative to process purchase transactions received through the network interface from a vehicle-based account access system for users onboard the vehicle against accounts, see at least paragraph 0006 (processor is configured to implement software instructions), paragraph 0109 (computer-executable program instructions stored in memory), paragraph 0062 (computing device is online e.g. connected to Internet), paragraph 0051 (communicate …over a network e.g. the Internet or other networking protocol), paragraph 0049 (Bluetooth, WiFi, a local network, NFC or other electronic communication), paragraph 0052 (in-flight transactions while traveling), paragraph 0040 (user accounts), paragraph 0068 (flight purchases), but fails to explicitly disclose the account is a prepaid account. Salkini (‘553) teaches the account is a prepaid account, see at least Abstract of Salkini (over the air OTA prepaid system), paragraph 0055 (OTA prepaid feature), claim 4 of Salkini (establishing a balance to fund a prepaid account), paragraph 0027 (temporary prepaid), claim 13 of Salkini (establishing the prepaid account balance). Both Kwok and Salkini are directed to over-the-air payment system. Therefore, it would be obvious to one of ordinary skill in the art before the effective filing date for the claimed invention to modify Kwok’s invention to include the account is a prepaid account. One would have been motivated to do so for the benefit of allowing over-the-air payment to be made more easily.
As per Claims 3, 23
Kwok (‘215) discloses wherein the payment processing system comprises a vehicle-based prepaid account access system operative to process purchase requests for users onboard the vehicle and determining when the funding rule has become satisfied, see at least Abstract of Kwok (generates an offline token associated with the user account, including account access restricts; binds the offline token to the duration of the flight), paragraph 0004 (temporary offline token includes account access restrictions;…the temporary offline token being active during a flight based on the flight departure time and a temporary offline token entity binding associated with the temporary online token being bound to the airline for performing n-flight account activity requests with the airline), paragraph 0052 (in-flight transactions while traveling), paragraph 0040 (user accounts), paragraph 0068 (flight purchases)
Kwok (‘215) discloses wherein the vehicle-based account access system is operative to communicate through the network interface with a ground-based static server, see at least paragraph 00091 (remove the offline limited-user token from the computing device when the status switches from offline to online e.g. when the user’s flight lands and the user reconnects to the Internet) and paragraph 0102 (access to internet) and Abstract od Kwok (binds the offline token to the duration of the flight; i-flight account activity), paragraph 0052 (in-flight transactions while traveling), but fails to explicitly disclose to perform the operations of generating the prepaid account and funding the prepaid account. Salkini (‘553) teaches generating the prepaid account and funding the prepaid account., see at least Abstract of Salkini (over the air OTA prepaid system), paragraph 0055 (accessing the OTA prepaid feature will be checked to verify a valid voucher; credit and deb it card access can be established so that the automated charging occurs when the established prepaid account triggers a recharge event; the trigger may be based on time, balance or other defined event), claim 4 of Salkini (establishing a balance to fund a prepaid account), paragraph 0027 (temporary prepaid), claim 13 of Salkini (establishing the prepaid account balance), paragraph 0024 (messaging, to transfer funds from the voucher to the user’s account), paragraph 0025 (establish an account; voucher…adding money to the user’s account). Both Kwok and Salkini are directed to over-the-air payment system. In addition, applicant is reminded that intended use language is generally not given patentable weight. Therefore, it would be obvious to one of ordinary skill in the art before the effective filing date for the claimed invention to modify Kwok’s invention to include to perform the operations of generating the prepaid account and funding the prepaid account. One would have been motivated to do so for the benefit of allowing payments to be made more easily over-the-air.
As per Claim 22
Kwok (‘215) discloses wherein the payment processing system is part of a networked server operative to process purchase transactions received through the network interface from a vehicle-based account access system for users onboard the vehicle against accounts, see at least paragraph 0062 (computing device is online e.g. connected to Internet), paragraph 0051 (communicate …over a network e.g. the Internet or other networking protocol), paragraph 0049 (Bluetooth, WiFi, a local network, NFC or other electronic communication), Abstract of Kwok (generates an offline token associated with the user account, including account access restricts; binds the offline token to the duration of the flight), paragraph 0004 (temporary offline token includes account access restrictions;…the temporary offline token being active during a flight based on the flight departure time and a temporary offline token entity binding associated with the temporary online token being bound to the airline for performing n-flight account activity requests with the airline), paragraph 0052 (in-flight transactions while traveling), paragraph 0040 (user accounts), paragraph 0068 (flight purchases), but fails to explicitly disclose the accounts are prepaid accounts. Salkini (‘553) teaches the accounts are prepaid accounts, see at least Abstract of Salkini (over the air OTA prepaid system), paragraph 0055 (OTA prepaid feature), claim 4 of Salkini (establishing a balance to fund a prepaid account), paragraph 0027 (temporary prepaid), claim 13 of Salkini (establishing the prepaid account balance), paragraph 0050 (accounts). Both Kwok and Salkini are directed to over-the-air payment system. Therefore, it would be obvious to one of ordinary skill in the art before the effective filing date for the claimed invention to modify Kwok’s invention to include the accounts are prepaid accounts. One would have been motivated to do so for the benefit of allowing over-the-air payment to be made more easily.
Claims 4, 6 and 24 are rejected under 35 U.S.C. 103 as being unpatentable over Kwok et al. (US 2022/0141215 A1) in view of Salkini et al. (US 2008/0182553 A1), as applied to claims 1 and 21 above, and further in view of Metzger (US 2006/0085308 A1).
As per Claims 4, 24
Kwok (‘215) discloses wherein the payment processing system comprises an InFlight payment processing system, determine when the funding rule has become satisfied based on a current time of day and date being within a threshold time of scheduled departure of an aircraft flight indicated by the schedule, the prepaid account becoming available to authorize on- board purchases by the user during the flight, see at least Abstract of Kwok (generates an offline token associated with the user account, including account access restricts; binds the offline token to the duration of the flight), paragraph 0004 (temporary offline token includes account access restrictions;…the temporary offline token being active during a flight based on the flight departure time and a temporary offline token entity binding associated with the temporary online token being bound to the airline for performing n-flight account activity requests with the airline), paragraph 0052 (in-flight transactions while traveling), paragraph 0040 (user accounts), paragraph 0068 (flight purchases), paragraph 0005 (offline token being active during a flight based on the flight departure time and the flight arrival time), paragraph 0039 (departure date or time or both), paragraph 0048 (within a predetermined range of the dates of the itinerary record), paragraph 0053 (the offline limited-use token may then remain active for a duration until after a time period following the departure time of the flight of the travel itinerary), but fails to explicitly disclose Entertainment (IFE) system. Metzger (‘308) teaches payment processing system comprising InFlight entertainment system, see at least paragraph 0087 (in-flight sales transactions paid for by… prepaid card and other forms of payment for the purchase of in-flight entertainment (IFE) services). Both Kwok and Metzger are directed toward inflight payment processing system. Therefore, it would be obvious to one of ordinary skill in the art before the effective filing date for the claimed invention to modify Kwok’s invention to include payment processing system comprising InFlight entertainment system. One would have been motivated to do so for the benefit of making flights more enjoyable.
Kwok (‘215) discloses wherein the payment processing system comprises an InFlight payment processing system, determine when the funding rule has become satisfied based on a current time of day and date being within a threshold time of scheduled departure of an aircraft flight indicated by the schedule, the prepaid account becoming available to authorize on- board purchases by the user during the flight, see at least Abstract of Kwok (generates an offline token associated with the user account, including account access restricts; binds the offline token to the duration of the flight), paragraph 0004 (temporary offline token includes account access restrictions;…the temporary offline token being active during a flight based on the flight departure time and a temporary offline token entity binding associated with the temporary online token being bound to the airline for performing n-flight account activity requests with the airline), paragraph 0052 (in-flight transactions while traveling), paragraph 0040 (user accounts), paragraph 0068 (flight purchases), paragraph 0005 (offline token being active during a flight based on the flight departure time and the flight arrival time), paragraph 0039 (departure date or time or both), paragraph 0048 (within a predetermined range of the dates of the itinerary record), paragraph 0053 (the offline limited-use token may then remain active for a duration until after a time period following the departure time of the flight of the travel itinerary), but fails to explicitly disclose the account is a prepaid account. Salkini (‘553) teaches the account is a prepaid account, see at least Abstract of Salkini (over the air OTA prepaid system), paragraph 0055 (OTA prepaid feature), claim 4 of Salkini (establishing a balance to fund a prepaid account), paragraph 0027 (temporary prepaid), claim 13 of Salkini (establishing the prepaid account balance). Both Kwok and Salkini are directed to over-the-air payment system. Therefore, it would be obvious to one of ordinary skill in the art before the effective filing date for the claimed invention to modify Kwok’s invention to include the account is a prepaid account. One would have been motivated to do so for the benefit of allowing over-the-air payment to be made more easily.
As per Claim 6
Kwok (‘215) discloses wherein the payment processing system comprises an InFlight payment processing system, see at least Abstract of Kwok (binds the offline token to the duration of the flight), paragraph 0052 (in-flight transactions while traveling), paragraph 0068 (flight purchases), but fails to explicitly disclose the InFlight system is an Entertainment (IFE) system. Metzger (‘308) teaches payment processing system comprising InFlight entertainment system, see at least paragraph 0087 (in-flight sales transactions paid for by… prepaid card and other forms of payment for the purchase of in-flight entertainment (IFE) services). Both Kwok and Metzger are directed toward inflight payment processing system. Therefore, it would be obvious to one of ordinary skill in the art before the effective filing date for the claimed invention to modify Kwok’s invention to include payment processing system comprising InFlight entertainment system. One would have been motivated to do so for the benefit of making flights more enjoyable.
Kwok (‘215) discloses determine when the funding rule has become satisfied based on receiving a message through the network interface indicating an aircraft flight identified based on the schedule has departed an airport and further based on a current time of day and date being after a scheduled departure of the aircraft flight during which the account is available to make on-board purchases, see at least paragraph 0061 (the API may communicate the API request with the baseline information attributes over a network e.g. the internet…to the data enrichment service), paragraph 0004 (receive, by at least one processor, an activity record including activity details associated with an account activity request in a user account; flight booking, the flight data including a flight departure time), Abstract of Kwok (generates an offline token associated with the user account, including account access restricts; binds the offline token to the duration of the flight), paragraph 0004 (temporary offline token includes account access restrictions;…the temporary offline token being active during a flight based on the flight departure time and a temporary offline token entity binding associated with the temporary online token being bound to the airline for performing n-flight account activity requests with the airline), paragraph 0052 (in-flight transactions while traveling), paragraph 0040 (user accounts), paragraph 0068 (flight purchases), paragraph 0005 (offline token being active during a flight based on the flight departure time and the flight arrival time), paragraph 0039 (departure date or time or both), paragraph 0048 (within a predetermined range of the dates of the itinerary record), paragraph 0053 (the offline limited-use token may then remain active for a duration until after a time period following the departure time of the flight of the travel itinerary), but fails to explicitly disclose the account is a prepaid account. Salkini (‘553) teaches the account is a prepaid account, see at least Abstract of Salkini (over the air OTA prepaid system), paragraph 0055 (OTA prepaid feature), claim 4 of Salkini (establishing a balance to fund a prepaid account), paragraph 0027 (temporary prepaid), claim 13 of Salkini (establishing the prepaid account balance). Both Kwok and Salkini are directed to over-the-air payment system. Therefore, it would be obvious to one of ordinary skill in the art before the effective filing date for the claimed invention to modify Kwok’s invention to include the account is a prepaid account. One would have been motivated to do so for the benefit of allowing over-the-air payment to be made more easily.
Claims 5, 7-15 and 25 have been searched and reviewed. No prior art has been found that discloses, either expressly or inherently, all of the limitations of the claimed invention. Even though Kwok et al. (US 2022/0141215 A1) discloses receive through the network interface from a user device, at least one message comprising information, the message comprising information identifying: user profile information to be associated with account and a schedule identifying when the account is to be used to pay for a purchase and send an account key through the network interface of the payment processing system, see at least paragraphs 0004, 0061, 0134, 0049, the rest of limitations recited in depending claims 5, 7-48 and 25 (claims 9 and 10 depend on claim 7; claims 12-15 depend on claim 11), considered as a whole including all limitations in the independent claims, is not taught by the prior arts found in examiner’s search. Therefore, no rejection under 102/103 is made.
Conclusion
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/CHIA-YI LIU/Primary Examiner, Art Unit 3692