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 .
Response to Amendment
The examiner acknowledges applicant’s arguments in the Response dated November 25, 2025 directed to the Non-Final Office Action dated May 30, 2025. Claims 1-2 and 5-17 are pending in the application and subject to examination as part of this office action.
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 1-2 and 5-17 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter. The claimed invention is directed to non-statutory subject matter because the claims as a whole, considering all claim elements both individually and in combination, do not amount to significantly more than an abstract idea. Each of claims 1-2 and 5-17 has been analyzed to determine whether it is directed to any judicial exceptions.
The determination of subject matter eligibility under 35 USC 101, relies on the Mayo/Alice two-step analysis.
In step 1 of the analysis, the claims are evaluated to determine whether they fall within one of the four statutory categories (i.e., process, machine, manufacture, or composition of matter). In the present case, claims 1-2 and 5-17 are directed to a system (i.e., a machine). The claims are, therefore directed to one of the four statutory categories.
Under prong 1 of step 2A, the examiner is directed to determine whether the claim recites a judicial exception. The claims are compared to groupings of subject matter that have been found by courts as abstract ideas. These groupings include
(a) Mathematical concepts—mathematical relationships, mathematical formulas or equations, mathematical calculations;
(b) Certain methods of organizing human activity—fundamental economic principles or practices (including hedging, insurance, mitigating risk); commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations); managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions); and
(c) Mental processes—concepts performed in the human mind (including an observation, evaluation, judgment, opinion).
Claim 1 recites the instructions for (the abstract idea is underlined) a system for generating casino patron activity monetary value transaction reports, comprising:
a centralized casino patron activity server comprising a processor, a memory, a communication interface and machine-readable code stored in said memory and executable by said processor;
a database which is accessible by said processor of said centralized casino patron activity server;
wherein said centralized casino patron activity server is in communication with a casino system of a casino which receives transaction information regarding one or more monetary value transactions of a patron at said casino;
said machine-readable code of the centralized casino patron activity server configured to cause said processor to:
associate patron identification information regarding said patron with a monetary value transaction report;
associate information regarding said one or more monetary value transactions of said patron with said monetary value transaction report, said information regarding said one or more monetary value transactions comprising at least one of a monetary amount and a transaction type;
store a first version of said monetary value transaction report with said associated patron identification information and monetary value transaction information; and
update said monetary value transaction report based upon a change to transaction information regarding said one or more monetary value transactions.
Claim 7 recites a system for generating casino patron activity monetary value transaction reports, comprising:
a centralized casino patron activity server comprising a processor, a memory, a communication interface and machine-readable code stored in said memory and executable by said processor;
a database which is accessible by said processor of said centralized casino patron activity server;
wherein said centralized casino patron activity server is in communication with a casino system of a casino which receives transaction information regarding one or more monetary value transactions of a patron at said casino;
said machine-readable code of the centralized casino patron activity server configured to cause said processor to:
associate patron identification information regarding said patron with a monetary value transaction report;
associate information regarding said one or more monetary value transactions of said patron with said monetary value transaction report, said information regarding said one or more monetary value transactions comprising at least one of a monetary amount and a transaction type;
store a first version of said monetary value transaction report with said associated patron identification information and monetary value transaction information;
determine if any errors exist in said first version of said monetary value transaction report; and
generate an output which causes a user display to display information regarding one or more identified errors relation to a portion of said monetary value transaction report where said error exists, said output comprising the display of at least the portion of said monetary value transaction report containing said error in a machine-readable format and a corresponding portion of said monetary value transaction report transformed into and displayed in human-readable format adjacent thereto;
update said monetary value transaction report in response to input of a correction to said report by a user; and
store a second version of said monetary value transaction report as updated.
Claim 13 recites a system for generating casino patron activity monetary value transaction reports, comprising:
a centralized casino patron activity server comprising a processor, a memory, a communication interface and machine-readable code stored in said memory and executable by said processor;
a database which is accessible by said processor of said centralized casino patron activity server;
wherein said centralized casino patron activity server is in communication with a casino system of a casino which receives transaction information regarding one or more monetary value transactions of a patron at said casino; said machine-readable code of the centralized casino patron activity server configured to cause said processor to:
associate patron identification information regarding said patron with a monetary value transaction report;
associate information regarding said one or more monetary value transactions of said patron with said monetary value transaction report, said information regarding said one or more monetary value transactions comprising at least one of a monetary amount and a transaction type;
store a first version of said monetary value transaction report with said associated patron identification information and monetary value transaction information; and
generate a second version of said monetary value transaction report without permitting editing of said first version by receiving, from a user, at least one of a change to transaction information regarding said one or more monetary value transactions and a change to said patron identification information, wherein said monetary value transaction report comprises a template with a plurality of fields, wherein said patron identification information and said monetary value transaction information are associated with said fields of said monetary value transaction report.
The present claims are directed to systems and methods for consolidating data from various casino systems to a central system, automatically performing due diligence on patron profiles using internal and external data, automatically identifying unusual patron profiles and transactions, and generating, submitting, and tracking AML reports. These steps fall into the category of certain methods of organizing human activity. The steps involve the tracking of monetary value transactions and fall within the sub-categories of fundamental economic practices and managing personal behavior or relationships or interactions between people. Finally, they also fall into the category of mental processes because some of the limitations "can be performed in the human mind, or by a human using a pen and paper". Accordingly, the claims recite an abstract idea.
Under prong 2 of Step 2A, the examiner considers whether additional elements integrate the abstract idea into a practical application. To do so, the examiner looks to the following exemplary considerations, looking at the elements individually and in combination:
• an additional element reflects an improvement in the functioning of a computer, or an improvement to other technology or technical field;
• an additional element that applies or uses a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition (not considered relevant to the present claims);
• an additional element implements a judicial exception with, or uses a judicial exception in conjunction with, a particular machine or manufacture that is integral to the claim;
• an additional element effects a transformation or reduction of a particular article to a different state or thing; and
• an additional element applies or uses the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception.
The additional elements in the present claims are a centralized casino patron activity server comprising a processor, a memory, a communication interface and machine-readable code, a database, a casino system, and a user display. The additional elements do no integrate the judicial exception into a practical application. In particular, the additional elements do not reflect an improvement in the functioning of a computer, or an improvement to other technology or technical field. The additional elements do not implement a judicial exception with, or uses a judicial exception in conjunction with, a particular machine or manufacture that is integral to the claim. The additional elements do not effect a transformation or reduction of a particular article to a different state or thing. The additional elements do not apply or use the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment. Accordingly, the additional elements do not integrate the abstract idea into a practical application because they does not impose any meaningful limits on practicing the abstract idea.
Under step 2B, the examiner evaluates whether the additional elements amount to significantly more than the judicial exception itself. The examiner considers if the additional elements:
• add a specific limitation or combination of limitations that are not well-understood, routine, conventional activity in the field, which is indicative that an inventive concept may be present; or
• simply appends well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception, which is indicative that an inventive concept may not be present.
The present claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception.
The additional elements are well-understood, routine, or conventional as follows:
a centralized casino patron activity server comprising a processor, a memory, a communication interface and machine-readable code, a database, a casino system, (Goldstein, US 2010/0169802 A1, a conventional server including processors and storage means, for example databases and memory [0027]); (Walker et al., US 2004/0162130 A1, server 200 includes a processor 202, a storage device 204 and a communication port 220, as well as conventional server components well known in the art [0048]); (Updike, US 2005/0003878 A1, the process 500 is embodied in a software program which is stored in the game server memory 308 and executed by the game server CPU 304 in a well known manner [0049]); and
a user display (Tedesco et al., US 2008/0248865 A1, for gaming devices, common output devices include a cathode ray tube (CRT) monitor on a video poker machine, a bell on a gaming device (e.g., rings when a player wins), an LED display of a player's credit balance on a gaming device, an LCD display of a personal digital assistant (PDA) for displaying keno numbers [0120]).
Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept.
As a result, the claims are not directed to patent eligible subject matter.
Prior Art
There are currently no prior art rejections against claims 1-2 and 5-17.
Response to Arguments
With respect to the rejections under 35 USC 101, applicant's arguments filed November 25, 2025 have been fully considered but they are not persuasive.
Applicant states:
The Applicant submits that characterizing the claims as certain methods of organizing human activity and mental processes over-simplifies and improperly characterizes the claims. The Applicant notes that the claims cannot be properly characterized by looking at individual elements in the claim, and the mere fact that an invention relates to the interaction with a party or between two parties does not mean that the invention is abstract. For example, the Federal Circuit has previously found that patent claims directed to a method of authenticating the identity of a party relative to a transaction at a device, are patent-eligible (Cosmokey Solutions GMBH v. DUO Security LLC, 15 Fed. 4th 1091(2021)). (Response [pp. 10-11])
MPEP 2106.04 states: “Prong One asks does the claim recite an abstract idea, law of nature, or natural phenomenon? In Prong One examiners evaluate whether the claim recites a judicial exception, i.e. whether a law of nature, natural phenomenon, or abstract idea is set forth or described in the claim”. The abstract idea
Under prong 1 of step 2A, the examiner is directed to determine whether the claim recites a judicial exception. A judicial exception can be a law of nature, a natural phenomenon, or an abstract idea. In the present instance, the claims recite an abstract idea -- not a law of nature or a natural phenomenon.
MPEP 2106.04(a) states:
To facilitate examination, the Office has set forth an approach to identifying abstract ideas that distills the relevant case law into enumerated groupings of abstract ideas. The enumerated groupings are firmly rooted in Supreme Court precedent as well as Federal Circuit decisions interpreting that precedent, as is explained in MPEP § 2106.04(a)(2). This approach represents a shift from the former case-comparison approach that required examiners to rely on individual judicial cases when determining whether a claim recites an abstract idea. By grouping the abstract ideas, the examiners’ focus has been shifted from relying on individual cases to generally applying the wide body of case law spanning all technologies and claim types.
The enumerated groupings of abstract ideas are defined as:
1) Mathematical concepts – mathematical relationships, mathematical formulas or equations, mathematical calculations (see MPEP § 2106.04(a)(2), subsection I);
2) Certain methods of organizing human activity – fundamental economic principles or practices (including hedging, insurance, mitigating risk); commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations); managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions) (see MPEP § 2106.04(a)(2), subsection II); and
3) Mental processes – concepts performed in the human mind (including an observation, evaluation, judgment, opinion) (see MPEP § 2106.04(a)(2), subsection III).
The claims recite a system for generating casino patron activity monetary value transaction reports. The claim limitations refer to monetary value transactions and clearly fall into certain methods of organizing human activity (the sub-category of fundamental economic practice). The claims also fall into the sub-category of managing personal behavior or relationships or interactions between people because the claims are similar to Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 115 USPQ2d 1636 (Fed. Cir. 2015). The Federal Circuit determined that the claims were directed to the abstract idea of "tracking financial transactions to determine whether they exceed a pre-set spending limit (i.e., budgeting)", which "is not meaningfully different from the ideas found to be abstract in other cases before the Supreme Court and our court involving methods of organizing human activity." 792 F.3d. at 1367-68, 115 USPQ2d at 1640.
Finally, they also fall into the category of mental processes because some of the limitations "can be performed in the human mind, or by a human using a pen and paper".
Accordingly, the claims recite an abstract idea. A finding that the claims recite an abstract idea under prong 1 of step 2A is not the end of the analysis and proceeds to prong 2 of step 2A.
Next, applicant states:
More importantly, the Applicant asserts that the claims are "integrated into a practical application" of any exception, thus satisfying prong two of Step 2A. Much like inventions which relate to improvements in computers and computing systems, gaming devices and gaming systems are now largely fully electronic systems. Thus, when addressing issues relating to gaming devices and gaming systems, the solutions necessarily focus on an electronic solution - e.g. an electronic improvement to such a system. (Response [p. 11])
Applicant goes on to state “the claims recite a practical application of technology to generate a unified or central interface between multiple existing electronic casino management systems which each collect information regarding casino patron activities in electronic form, as well as associated electronic validation systems” (Response [p. 11]).
Prong 2 of step 2A asks whether the additional elements integrate abstract idea into a practical application. Under prong 2, a claim that recites a judicial exception is not directed to that judicial exception, if the claim as a whole integrates the recited judicial exception into a practical application of that exception.
The combination of these additional elements is no more than using generic computing components to apply the judicial exception to the judicial exception and generally linking the judicial exception to a particular technological environment or field of use. Accordingly, even in combination, these additional elements do not integrate the abstract idea into a practical application. The claim is directed to an abstract idea.
Under step 2B, the applicant asserts that the claims recite significantly more than any abstract idea under Step 2B because the claim limitations recite more than “generic computer functions” (Response [p. 12]).
Under step 2B, the examiner evaluates whether the additional elements:
• add a specific limitation or combination of limitations that are not well-understood, routine, conventional activity in the field, which is indicative that an inventive concept may be present (MPEP 2106.05(d)); or
• simply appends well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception, which is indicative that an inventive concept may not be present (MPEP 2106.05(d) and Berkheimer Memo, April 20, 2018). Thus, the additional elements evaluated under Step 2A are re-evaluated in Step 2B to determine if they are more than what is well-understood, routine, conventional activity in the field.
The claims do not recite additional elements, individually or in combination, that amount to significantly more than the abstract idea. As discussed above with respect to the lack of a practical application, the additional elements in the claim (i.e. one or more processors coupled to a non-transitory memory, a language model, and a client device etc.) amount to no more than mere instructions to apply the exception using generic computer components used as tools. The courts have recognized such computer functions as well understood, routine, and conventional functions when claimed in a merely generic manner (e.g., at a high level of generality) or as insignificant extra-solution activity. See, Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015); and OIP Techs., 788 F.3d at 1363, 115 USPQ2d at 1092-93.
Applicant cites BASCOM Global Internet Services, Inc. v. AT&T and Data Engine Technologies LLC v. Google LLC. BASCOM relates to filtering content retrieved from an Internet computer network while Data Engine relates to a specific interface and implementation for navigating complex three-dimensional spreadsheets using techniques unique to computers. The cited decisions are not considered similar enough to the present claims to be considered helpful in the subject matter eligibility analysis.
Applicant also points to Example 42 as being analogous to the present claims. The examiner disagrees.
Example 42 recites a network-based patient management method that collects, converts and consolidates patient information from various medical providers into a standardized format, stores it in network-based storage devices, and generates messages notifying health care providers or patients whenever that information is updated the present claims also refer to fundamental economic transactions and mental processes.
The present claims are directed to consolidating monetary transactions from various casino systems to a central system, automatically performing due diligence on patron profiles using internal and external data, automatically identifying unusual patron profiles and transactions, and generating, submitting, and tracking AML reports. This is more similar to Intellectual Ventures I v. Capital One Fin. Corp., 850 F.3d 1332, 121 USPQ2d 1940 (Fed. Cir. 2017). In Intellectual Ventures, the steps in the claims described "the creation of a dynamic document based upon ‘management record types’ and ‘primary record types.’" 850 F.3d at 1339-40; 121 USPQ2d at 1945-46. The claims were found to be directed to the abstract idea of "collecting, displaying, and manipulating data." 850 F.3d at 1340; 121 USPQ2d at 1946. In addition to the abstract idea, the claims also recited the additional element of modifying the underlying XML document in response to modifications made in the dynamic document. 850 F.3d at 1342; 121 USPQ2d at 1947-48. Although the claims purported to modify the underlying XML document in response to modifications made in the dynamic document, nothing in the claims indicated what specific steps were undertaken other than merely using the abstract idea in the context of XML documents. The court thus held the claims ineligible, because the additional limitations provided only a result-oriented solution and lacked details as to how the computer performed the modifications, which was equivalent to the words "apply it". 850 F.3d at 1341-42; 121 USPQ2d at 1947-48 (citing Electric Power Group., 830 F.3d at 1356, 1356, USPQ2d at 1743-44 (cautioning against claims "so result focused, so functional, as to effectively cover any solution to an identified problem")).
The examiner maintains that the present claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed with respect to Step 2A Prong 2, the additional elements in the claim amount to no more than mere instructions to apply the exception using a generic computer component and generally linking the use of the judicial exception to a particular technological environment or field of use. The same analysis applies here in step 2B and does not provide an inventive concept.
For these reasons, there is no inventive concept. The claim is not patent eligible. Even when viewed as a whole, nothing in the claim adds significantly more to the abstract idea.
Conclusion
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 WERNER G GARNER whose telephone number is (571)270-7147. The examiner can normally be reached M-F 7:30-15:30 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, DAVID LEWIS can be reached at (571) 272-7673. 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.
/WERNER G GARNER/ Primary Examiner, Art Unit 3715