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 amendment filed 06/04/2026.
Claims 1, 3, 5, 8-10, 14-17, and 19-20 have been amended. Claims 1-6 and 8-20 are pending and have been examined on the merits (claims 1, 10, and 17 being independent), and claim 7 has been canceled.
The amendment filed 06/04/2026 to the claims has been entered.
Response to Arguments
Applicant’s arguments and amendments filed 06/04/2026 have been fully considered.
Applicants assert that the pending claims fully comply with the requirement of 35 U.S.C. 101. Examiner respectfully disagrees. Applicant’s argument and amendments have been considered and are not persuasive. The rejections under 35 U.S.C. 101 have been maintained and clarified in view of the USPTO MPEP 2106.
Applicant’s arguments (see Applicant’s remarks, pages 10-15)
Step 2A-Prong 1: The Claims Are Not Directed to the Identified Abstract Idea
(1) Applicant’s arguments that “Applicant submits that this characterization is overbroad and fails to account for the specific technical limitations of the claims. See Enfish, LLC v. Microsoft Corp., 822 F.3d 1327, 1337 (Fed. Cir. 2016) (cautioning against describing claims "at such a high level of abstraction and untethered from the language of the claims").” (see remarks, page 11), are not found persuasive.
In response (1): Under Step 2 A, Prong 1 of the 2019 Revised § 101 Guidance, it is determined whether the claims are directed to a judicial exception such as a law of nature, a natural phenomenon, or an abstract idea (See Alice, 134 S. Ct. at 2355) by identify the specific limitation(s) in the claim that recites abstract idea(s); and then determine whether the identified limitation(s) falls within at least one of the groupings of abstract ideas enumerated in the MPEP 2106.04.
The cited limitations as drafted are systems and methods that, under their broadest reasonable interpretation, covers performance of a method of organizing human activity, but for the recitation of the generic computer components. Further, none of the limitations recite technological implementations details for any of the steps but, instead, only recite broad functional language being performed by the generic use of at least one processor. Managing a risk in transaction data associated with an entity and optimizing an allocation of transaction alerts that concern suspicious financial activities is a fundamental economic practice long prevalent in commerce systems. If a claim limitation, under its broadest reasonable interpretation, covers a fundamental economic principle or practice but for the general linking to a technological environment, then it falls within the organizing human activity grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
In Enfish, the courts applied the distinction to reject the §101 challenge at stage one because the claims in Enfish 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. Enfish, 822 F.3d at 1335-36; see Bascom, 827 F.3d at 1348-49, 2016 WL 3514158, at *5; cf. Alice, 134 S.Ct. at 2360 (noting basic storage function of generic computer). The instant 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. So Enfish has no applicability.
(2) Applicant’s arguments that “Second, amended claim 1 now recites "classifying a first entity into a risk category group" rather than "assigning." Classifying data entities into categories is a data processing operation. It is not a "fundamental economic practice" or "commercial or legal interaction" as defined by the 2019 Revised Patent Subject Matter Eligibility Guidance (2019 PEG).” (see remarks, page 11), are not found persuasive.
In response (2): Again, under Step 2 A, Prong 1 of the 2019 Revised § 101 Guidance, specifically, claim 1 comprises inter alia the functions or steps of “classifying a first entity into a risk category group based at least in part on a risk level of the first entity, wherein the risk level is based at least in part on transaction data of a transaction alert associated with the first entity, wherein the transaction alert is concerning potentially suspicious financial activities” and this limitation as drafted are methods that, under their broadest reasonable interpretation, covers performance of a method of organizing human activity as managing a risk in transaction data associated with an entity and optimizing an allocation of transaction alerts that concern suspicious financial activities which is a fundamental economic practice long prevalent in commerce systems.
B. Step 2A-Prong 2: The Claims Are Integrated into a Practical Application
(3) Applicant’s arguments that “Even if the claims were found to recite a judicial exception at Prong 1, amended claim 1 integrates any such exception into a practical application.” (see remarks, page 12), are not found persuasive.
In response (3): Step 2A Prong 2, next, it is determined whether the claim is directed to the abstract concept itself or whether it is instead directed to some technological implementation or application of, or improvement to, this concept, i.e., integrated into a practical application. See, e.g., Alice, 573 U.S. at 223, discussing Diamond v. Diehr, 450 U.S. 175 (1981 ). The mere introduction of a computer or generic computer technology into the claims need not alter the analysis. See Alice, 573 U.S. at 223-24. "[T]he relevant question is whether the claims here do more than simply instruct the practitioner to implement the abstract idea on a generic computer." Alice, 573 U.S. at 225.
In the present case, the judicial exception is not integrated into a practical application. The claim limitations are not indicative of integration into a practical application by claiming an improvement to the functioning of the computer or to any other technology or technical field. Further, the claim limitations are not indicative of integration into a practical application by applying or using the judicial exception in some other meaningful way. In particular the claim limits of (1) “an optimization operation” and “an objective function” amount to simply applying the abstract idea to a computer component. (e.g. “apply it”) (2) “ program instructions executable by a processor” and “the processor to perform operations” describe transmitting generic instructions to a computer component, and therefore also amounts to simply applying the abstract idea to a generic computer/component (e.g. “apply it” or the equivalent) do not apply, rely on, or use the judicial exception in a manner that that imposes a meaningful limitation on the judicial exception (i.e. generally linking the use of the judicial exception to a particular technological environment or field of use - see MPEP 2106.05(h) or apply it with 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 - see MPEP 2106.05(f)). The claim limits also recite the use of a processor, computer readable storage media, program instructions, an optimization operation, an objective function, nodes, a network graph, over a network as additional elements. However, the use of these additionally elements, described at a high level of generality, perform generic computer functions such that it amounts to no more than mere instruction to apply the exception to a particular technological environment. Accordingly, these additional elements do not integrate the abstract idea into a practical application because it does not impose any meaning limits on practicing the abstract idea. Thus, the claim is directed toward an abstract idea
(4) Applicant’s arguments that “In In re Desjardins (Appeal 2024-000567), the PTAB vacated a § 101 rejection where claims reflected improvements described in the specification. Here, the specification describes the technical problem at paragraph [0017] and the multi-module architecture that solves it at paragraph [0060], and amended claim 1 recites that specific computational architecture.” (see remarks, page 14), are not found persuasive.
In response (4): As argued above, claims reflected improvements described in the specification, and the specification describes the technical problem and the multi-module architecture that solves it. However, Examiner considers that it is a business solution to a business problem because it uses multiple modules to make an transaction alert based on the transaction data of the entity with potentially suspicious financial activities and provide the alert to the alert analyst for reviewing transaction in order to reduce a risk. Furthermore, the instant recited claims including additional elements (i.e., a processor, computer readable storage media, program instructions, an optimization operation, an objective function, nodes, an entity network graph, over a network) do not improve the functioning of the computer or improve another technology or technical field nor do they recite meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment. The limitations merely use a generic computing technology (Specification paragraph [0029]: computer, wide area network, end user device, remote server, public cloud, private cloud, processor, alert triage module, network module, remote database, etc.) as generally linking the use of the judicial exception to a particular technological environment or field of use - see MPEP 2106.05(h) or apply it with 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 - see MPEP 2106.05(f)). Therefore, when considered as a whole, it is not integrated into a practical application.
C. Step 2B: The Claims Recite Significantly More
(5) Applicant’s arguments that “Under Berkheimer v. HP Inc., 881 F.3d 1360 (Fed. Cir. 2018), whether claim elements are WRC is a question of fact. The USPTO's April 19, 2018 Memorandum ("Berkheimer Memo") requires the Examiner to support a WRC finding with one of four forms of evidence: (1) a citation to a specification or prosecution history admission; (2) a citation to a court decision in MPEP § 2106.05(d)(II); (3) a citation to a publication; or (4) a statement of official notice. (Berkheimer Memo, p. 3). The Office Action provides none of these.” (see remarks, page 14), are not found persuasive.
In response (5): In Berkheimer, Applicant argues the Examiner must provide any of the above noted four bases in support of an assertion of a noted element being conventional. The Examiner notes that the steps of the claims, taken individually or as an ordered combination, have been identified as corresponding to an abstract idea. The additional elements in the claim are a processor, computer readable storage media, program instructions, an optimization operation, an objective function, nodes, an entity network graph, over a network” (Independent claim 1). Furthermore, it is clear, through a plain reading of Applicant’s specification, that the computing processors are suitably programmed to perform the abstract idea, see at least paragraphs [0032] and [0087]. The claims at issue do not require any nonconventional computer, network, or other components, or even a non-conventional and non-generic arrangement of known, conventional pieces but merely call for performance of the claimed functions on a set of generic computer components. The elements of the instant process, when taken alone, each execute in a manner conventionally expected of these elements. The elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone.
According to the USPTO guidelines of April 19, 2018 incorporating the Berkheimer memo (Berkheimer memo, hereinafter), in a step 2B analysis, an additional element (or combination of elements) is not well-understood, routine or conventional unless the examiner finds, and expressly supports a rejection in writing with, one or more of the following:
1. A citation to an express statement in the specification or to a statement made by an applicant during prosecution that demonstrates the well-understood, routine, conventional nature of the additional element(s).
2. A citation to one or more of the court decisions discussed in MPEP § 2106.05(d)(II) as noting the well-understood, routine, conventional nature of the additional element(s).
3. A citation to a publication that demonstrates the well-understood, routine, conventional nature of the additional element(s).
4. A statement that the examiner is taking official notice of the well-understood, routine, conventional nature of the additional elements). This option should be used only when the examiner is certain, based upon his or her personal knowledge, that the additional elements) represents well-understood, routine, conventional activity engaged in by those in the relevant art, in that the additional elements are widely prevalent or in common use in the relevant field, comparable to the types of activity or elements that are so well-known that they do not need to be described in detail in a patent application to satisfy 35 U.S.C. § 112(a).
The fact that a generic computing system such as described above can be suitably programmed, may be used to perform the claimed method and the fact that the claims at issue do not require any nonconventional computer, network, or other components, or even a “non- conventional and non-generic arrangement of known, conventional pieces” but instead merely call for performance of the claimed functions on a set of generic computer components, satisfies the Berkheimer memo requirement that the additional elements are conventional elements (as outlined in criterion 1 of the Berkheimer memo). The elements of the instant process, when taken alone, each execute in a manner conventionally expected of these elements. The elements of the instant process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. Hence these additional elements do not add anything significantly more than an abstract idea.
With regard to the rejections of claims 1-6 and 8-20 under 35 U.S.C. 103, Applicant’s arguments and amendments have been considered but are moot as a new ground of rejection has been added as cited above and Examiner respectfully disagrees. Examiner notes that Applicant is arguing newly amended claim language. As noted in the citation above the prior art and it is addressed by the rejections under 35 USC 103.
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 1-6 and 8-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter without significantly more.
When considering subject matter eligibility under 35 U.S.C. 101, (1) it must be determined whether the claim is directed to one of the four statutory categories of invention, i.e., process, machine, manufacture, or composition of matter. If the claim does fall within one of the statutory categories, (2a) it must then be determined whether the claim is directed to a judicial exception (i.e., law of nature, natural phenomenon, and abstract idea), and if so (2b), it must additionally be determined whether the claim is a patent-eligible application of the exception. If an abstract idea is present in the claim, any element or combination of elements in the claim must be sufficient to ensure that the claim amounts to significantly more than the abstract idea itself. Examples of abstract ideas include fundamental economic practices; certain methods of organizing human activities; an idea itself; and mathematical relationships/formulas. Alice Corporation Pty. Ltd. v. CLS Bank International, et al., 573 U.S. (2014).
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. In the instant case, the claim(s) as a whole, considering all claim elements both individually and in combination, do not amount to significantly more than an abstract idea.
Step (1): In the instant case, the claims are directed towards to a method for providing for optimizing allocation of transaction alerts which contains the steps of classifying, identifying, determining, and generating. The claim recites a series of steps and, therefore, is a process. The claims do fall within at least one of the four categories of patent eligible subject matter because claim 1 is direct to a method, claim 10 is direct to a computer program product, and claim 17 is direct to a computer system, i.e. machines programmed to carrying out process steps, Step 1-yes.
Step (2A) Prong 1: A method providing for optimizing allocation of transaction alerts is akin to the abstract idea subject matter grouping of: Certain Methods of Organizing Human Activity as fundamental economic principles or practices including mitigating risk. As such, the claims include an abstract idea.
The specific limitations of the invention are (a) identified to encompass the abstract idea include: {….. classifying a first entity into a risk category group based at least in part on a risk level of the first entity, wherein the risk level is based at least in part on transaction data of a transaction alert associated with the first entity, wherein the transaction alert is concerning potentially suspicious financial activities; identifying a relationship between the first entity and a second entity based at least in part on the transaction data, wherein the identifying comprises generating …… comprising nodes representative of respective entities and edges representative of relationships between the first and second entities; determining a capability of an anti-money laundering ("AML") analyst, wherein the capability comprises a skill level of the AML analyst; generating task allocation data by performing ……, wherein …… comprises solving the objective function subject to a set of optimization constraints, wherein the set of optimization constraints comprises the risk category group, ……, and the capability of the AML analyst, wherein the task allocation data comprises an optimized assignment list for the AML analyst.}
As stated above, this abstract idea falls into the (b) subject matter grouping of: Certain Methods of Organizing Human Activity as fundamental economic principles or practices including mitigating risk as managing a risk in transaction data associated with an entity and optimizing an allocation of transaction alerts that concern potentially suspicious financial activities.
Step (2A) Prong 2: The instant claims do not integrate the exception into a practical application because additional elements: 1) an “optimization operation” and an “entity network graph” amount to simply applying the abstract idea to a computer component. (e.g. “apply it”) 2) “program instructions executable by a processor” and “the processor to perform operations” describe transmitting generic instructions to a computer component, and therefore also amounts to simply applying the abstract idea to a generic computer/component (e.g. “apply it” or the equivalent) do not apply, rely on, or use the judicial exception in a manner that that imposes a meaningful limitation on the judicial exception (i.e. generally linking the use of the judicial exception to a particular technological environment or field of use - see MPEP 2106.05(h) or apply it with 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 - see MPEP 2106.05(f)).
The instant recited claims including additional elements (i.e., a processor, computer readable storage media, program instructions, an optimization operation, nodes, an entity network graph, over a network) do not improve the functioning of the computer or improve another technology or technical field nor do they recite meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment. The limitations merely use a generic computing technology (Specification paragraph [0029]: computer, wide area network, end user device, remote server, public cloud, private cloud, processor, alert triage module, network module, remote database, etc.) as generally linking the use of the judicial exception to a particular technological environment or field of use - see MPEP 2106.05(h) or apply it with 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 - see MPEP 2106.05(f)). Therefore, the claims are directed to an abstract idea
Step (2B): 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 (Claims: e.g., a processor, computer readable storage media, program instructions, an optimization operation, nodes, an entity network graph, over a network) amount to no more than mere instructions to apply the exactly using generic computer component. The claim elements when considered separately and in an ordered combination, do not add significantly more than implementing the abstract idea over a generic computer network with a generic computer element.
The computer is merely a platform on which the abstract idea is implemented. Simply executing an abstract concept on a computer does not render a computer “specialized,” nor does it transform a patent-ineligible claim into a patent-eligible one. See Bancorp Servs., LLC v. Sun Life Assurance Co. of Can., 687 F.3d 1266, 1280 (Fed. Cir. 2012). There are no improvements to another technology or technical field, no improvements to the functioning of the computer itself, transformation or reduction of a particular article to a different state or thing or any other meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment as a result of performing the claimed method. Also, the addition of merely novel or non-routine components to the claimed idea does not necessarily turn an abstraction into something concrete (See Ultramercial, Inc. v. Hulu, LLC, _ F.3d_, 2014 WL 5904902, (Fed. Cir. Nov. 14, 2014). Hence, the claims do not recite significantly more than an abstract idea. In conclusion, merely “linking/applying” the exception using generic computer components does not constitute ‘significantly more’ than the abstract idea. (MPEP 2106.05 (f) (h)). Therefore, the claims are not patent eligible under 35 USC 101.
Dependent claims 2-6, 8-9, 11-16, and 18-20 when analyzed as a whole and in an ordered combination are held to be patent ineligible under 35 U.S.C. 101 because the additional recited limitation(s) fail(s) to establish that the claim(s) is/are not directed to an abstract idea, as detailed below. The additional recited limitations in the dependent claims only refine the abstract idea.
For instance, in claims 2, 13, and 18, the step of “… further comprising generating the objective function ….” (i.e., making a task), in claims 3, 14, and 19, the step of “… wherein the objective function is a cost-based objective function, …. comprises minimizing a total cost metric subject….” (i.e., minimizing a cost), in claims 4, 15, and 20, the step of “… wherein the transaction alert is one of a plurality of transaction alerts, ...” (i.e., providing an alert), in claims 5 and 16, the step of “… wherein the assigning of the first entity to the risk category group further comprises distributing the plurality of entities among a plurality of risk category groups ...” (i.e., assigning a risk level), in claim 6, the step of “… wherein the distributing of the plurality of entities among the plurality of risk category groups is based at least in part on risk metadata ….” (i.e., using risk metadata), in claim 8, the step of “… further comprising identifying a plurality of distinct relationship-based entity groups ….” (i.e., identifying an entity group), and in claim 9, the step of “… wherein the determining of the capability of the AML analyst ….” (i.e., determining an availability) are all processes that, under its broadest reasonable interpretation, covers performance of a fundamental economic practice but for the recitation of a generic computer component. Performing for optimizing allocation of transaction alerts is a most fundamental commercial process.
This is an abstract concept with nothing more and is also considered mere instructions to apply an exception akin to a commonplace business method or mathematical algorithm being applied on a general purpose computer, Alice Corp. Pty. Ltd.; Gottschalk and Versata Dev. Group, Inc.; see MPEP 2106.05(f)(2).
In dependent claims 2-6, 8-9, 11-16, and 18-20, the step claimed are rejected under the same analysis and rationale as the independent claims 1, 10, and 17 above. Merely claiming the same process using an optimization operation for optimizing allocation of transaction alerts based on potentially suspicious financial activities does not change the abstract idea without an inventive concept or significantly more. Clearly, the additional recited limitations in the dependent claims only refine the abstract idea further. Further refinement of an abstract idea does not convert an abstract idea into something concrete.
Therefore, claims 1-6 and 8-20 are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter.
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 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.
In the rejections below, where claims are currently amended, this is indicated by underlining.
Claims 1-6, 8-10, and 13-20 are rejected under 35 U.S.C. 103 as being unpatentable over Somasundaram et al. (hereinafter Somasundaram), US Patent Number 11113694 B1 in view of view of Guo, US Publication Number 2020/0394707 A1 in further view of Kloostra et al. (hereinafter Kloostra), US Publication Number 2009/0125369 A1.
Regarding claim 1:
Somasundaram discloses the following
A computer-implemented method comprising: (see Somasundaram: at least [column 2, lines 29-42] discloses “a method for operating an automated Anti-Money Laundering (AML) alerts investigation and disposition system is disclosed. The method includes generating, by an alert generation unit, alert data representative of AML alert transactions of one or more entities through a financial institution.)
classifying a first entity into a risk category group based at least in part on a risk level of the first entity, wherein the risk level is based at least in part on transaction data of a transaction alert associated with the first entity, wherein the transaction alert is concerning potentially suspicious financial activities; (see Somasundaram: at least [column 6, lines 25-40] discloses “The disposition categories may include an alert closure category and an alert escalation category. In one embodiment, category ratings of the plurality of alerts 45 are checked to determine depth of investigation. For example, an alert with a low risk rating is typically checked only for associated transactions leading to the corresponding alert, whereas an alert with a medium/high risk rating may lead to a more comprehensive investigation including seeking additional information about the associated entity or entities. The additional information can be used to decide whether to classify corresponding alerts into an alert closure category or an alert escalation category.”; [column 9, lines 40-64] discloses “The alert generation unit 12 is configured to generate the alert data 32 representative of AML alert transactions of one or more entities through a financial institution. The alert data 32 is stored in the storage server 16. The alert data 32 includes a plurality of alerts, transaction data, and associated entity data such as Know Your Customer (KYC) information (91)”)
identifying a relationship between the first entity and a second entity based at least in part on the transaction data, (see Somasundaram: at least [column 11, lines 31-64] discloses “the dashboard 120 includes the AML transaction details, risk evidence, transactional relationships between the parties of associated transactions”)
Somasundaram does not explicitly disclose the following, however Guo further teaches:
wherein the identifying comprises generating an entity network graph comprising nodes representative of respective entities and edges representative of relationships between the first and second entities; (see Guo, at least [0045] “Based on the established fund-transfer relationship, fund-transfer-relationship-establishing module 304 can construct a fund-transfer graph 306. The vertices or nodes in fund-transfer graph 306 can be the customer accounts, and the edges can be the fund-transfer relationships among the customer accounts”; and [0046] discloses “Money-laundering-detection system 300 can further construct a subgraph for each node cluster. The nodes in each subgraph can be the nodes sharing the same group ID, and the edges in each subgraph can represent the fund-transfer relationships among nodes in the subgraphs.”)
….. the entity network graph, …… (see Guo, at least [0045] “Based on the established fund-transfer relationship, fund-transfer-relationship-establishing module 304 can construct a fund-transfer graph 306. The vertices or nodes in fund-transfer graph 306 can be the customer accounts, and the edges can be the fund-transfer relationships among the customer accounts”; and [0046] discloses “Money-laundering-detection system 300 can further construct a subgraph for each node cluster. The nodes in each subgraph can be the nodes sharing the same group ID, and the edges in each subgraph can represent the fund-transfer relationships among nodes in the subgraphs.”)
It would have been obvious to one of ordinary skill in the art as of the effective filing date of the claimed invention to modify generating, by an alert generation unit, alert data representative of AML alert transactions of one or more entities through a financial institution of Somasundaram to include constructing a subgraph for each node cluster and the nodes in each subgraph can be the nodes sharing the same group ID, and the edges in each subgraph can represent the fund-transfer relationships among nodes in the subgraphs, as taught by Guo, in order to make easier the detection of groups of customer accounts for potentially suspicious customer activities. (Guo: See [0022-0024])
Somasundaram and Guo do not explicitly disclose the following, however Kloostra further teaches:
determining a capability of an anti-money laundering ("AML") analyst, wherein the capability comprises a skill level of the AML analyst; and (see Kloostra, at least [0036] discloses “Groups of analysts may be configured using the administration module 210 in order to define groupings of work for alerts. For example, groups can be configured to work specific types of alerts based on their source such as transaction monitoring system alerts, or fraud system alerts or branch referrals.”, and [0037] discloses “The background pre-processing routine 306 can be configured to assign alerts to an alert pre-queue 308 for either a group or a specific analyst based on the configured assignment rules. Each pre-queue may have the alerts prioritized based on the configured prioritization rules.”, and see also fig. 3, (“Assignment Rules (e.g. Skills, Resources, Experience)”))
generating task allocation data by performing an optimization operation on an objective function, wherein the optimization operation comprises solving the objective function subject to a set of optimization constraints, wherein the set of optimization constraints comprises the risk category group, [……………], and the capability of the AML analyst, wherein the task allocation data comprises an optimized assignment list for the AML analyst. (see Kloostra, at least [0035] discloses “The alert queue processing engine 202 may be configured to manage the import, prioritization and assignment of alerts needing review. A plurality of alert sources 302 may be configured to pass potentially suspicious customer activity notifications to the unprioritized/unassigned alert pool 304 in the alert queue processing engine 202. Rules to prioritize the order in which alerts are worked and who should be assigned to work the alerts can be configured using the administrative module 210”; [0036] discloses “Groups of analysts may be configured using the administration module 210 in order to define groupings of work for alerts. For example, groups can be configured to work specific types of alerts based on their source such as transaction monitoring system alerts, or fraud system alerts or branch referrals.”; and [0037] discloses “The background pre-processing routine 306 can be configured to assign alerts to an alert pre-queue 308 for either a group or a specific analyst based on the configured assignment rules. Each pre-queue may have the alerts prioritized based on the configured prioritization rules.”)
It would have been obvious to one of ordinary skill in the art as of the effective filing date of the claimed invention to modify generating, by an alert generation unit, alert data representative of AML alert transactions of one or more entities through a financial institution of Somasundaram to include groups of analysts who may be configured using the administration module in order to define groupings of work for alerts based on assignment rules (e.g., skills, resources, experience), as taught by Kloostra, in order to provide less cost and more efficient way for reviewing potential suspicious customer activities. (Kloostra: See [0003-0005])
Regarding claim 2:
Somasundaram and Guo do not explicitly disclose the following, however Kloostra further teaches:
The computer-implemented method according to claim 1, further comprising generating the objective function based at least in part on a user-specified objective. (see Kloostra, at least [0037] discloses “The background pre-processing routine 306 can be configured to assign alerts to an alert pre-queue 308 for either a group or a specific analyst based on the configured assignment rules. Each pre-queue may have the alerts prioritized based on the configured prioritization rules.”)
It would have been obvious to one of ordinary skill in the art as of the effective filing date of the claimed invention to modify generating, by an alert generation unit, alert data representative of AML alert transactions of one or more entities through a financial institution of Somasundaram to include groups of analysts who may be configured using the administration module in order to define groupings of work for alerts based on assignment rules (e.g., skills, resources, experience), as taught by Kloostra, in order to provide less cost and more efficient way for reviewing potential suspicious customer activities. (Kloostra: See [0003-0005])
Regarding claim 3:
Somasundaram and Guo do not explicitly disclose the following, however Kloostra further teaches:
The computer-implemented method according to claim 1, wherein the objective function is a cost-based objective function, and wherein the optimization operation comprises minimizing a total cost metric subject to the set of optimization constraints. (see Kloostra, at least [0029] discloses “The division of responsibilities between the AML analyst 104 and the AML investigator 106 results in a two-step process for reviewing and investigating alerts. Embodiments using this two-step approach, with an analyst and investigator, lower costs of the review, provide efficiencies”; and [0038] discloses “Using the administrative module 210, a user can setup optional configurable logic to group activity (e.g. alerts) by similar attributes so they can be consolidated and reviewed together. For example, alerts for the same TIN/Customer or the Account Number can be grouped together to optimize the review process by decreasing time and cost.”)
It would have been obvious to one of ordinary skill in the art as of the effective filing date of the claimed invention to modify generating, by an alert generation unit, alert data representative of AML alert transactions of one or more entities through a financial institution of Somasundaram to include groups of analysts who may be configured using the administration module in order to define groupings of work for alerts based on assignment rules (e.g., skills, resources, experience), as taught by Kloostra, in order to provide less cost and more efficient way for reviewing potential suspicious customer activities. (Kloostra: See [0003-0005])
Regarding claim 4:
Somasundaram discloses the following:
The computer-implemented method according to claim 1, wherein the transaction alert is one of a plurality of transaction alerts, and wherein the first and second entities are among a plurality of entities associated with the plurality of transaction alerts. (see Somasundaram: at least [column 6, lines 25-34] discloses “The disposition categories may include an alert closure category and an alert escalation category. In one embodiment, category ratings of the plurality of alerts 45 are checked to determine depth of investigation. For example, an alert with a low risk rating is typically checked only for associated transactions leading to the corresponding alert, whereas an alert with a medium/high risk rating may lead to a more comprehensive investigation including seeking additional information about the associated entity or entities.”; and [column 9, lines 40-64] discloses “The alert generation unit 12 is configured to generate the alert data 32 representative of AML alert transactions of one or more entities through a financial institution. The alert data 32 is stored in the storage server 16. The alert data 32 includes a plurality of alerts, transaction data, and associated entity data such as Know Your Customer (KYC) information (91)”)
Regarding claim 5:
Somasundaram discloses the following:
The computer-implemented method according to claim 4, wherein the classifying of the first entity into the risk category group further comprises distributing the plurality of entities among a plurality of risk category groups associated with respective risk levels. (see Somasundaram: at least [column 6, lines 25-40] discloses “The disposition categories may include an alert closure category and an alert escalation category. In one embodiment, category ratings of the plurality of alerts 45 are checked to determine depth of investigation. For example, an alert with a low risk rating is typically checked only for associated transactions leading to the corresponding alert, whereas an alert with a medium/high risk rating may lead to a more comprehensive investigation including seeking additional information about the associated entity or entities. The additional information can be used to decide whether to classify corresponding alerts into an alert closure category or an alert escalation category.”)
Regarding claim 6:
Somasundaram and Guo do not explicitly disclose the following, however Kloostra further teaches:
The computer-implemented method according to claim 5, wherein the distributing of the plurality of entities among the plurality of risk category groups is based at least in part on risk metadata of the transaction data. (see Kloostra, at least [0038] discloses “Using the administrative module 210, a user can setup optional configurable logic to group activity (e.g. alerts) by similar attributes so they can be consolidated and reviewed together. For example, alerts for the same TIN/Customer or the Account Number can be grouped together to optimize the review process by decreasing time and cost.”)
It would have been obvious to one of ordinary skill in the art as of the effective filing date of the claimed invention to modify generating, by an alert generation unit, alert data representative of AML alert transactions of one or more entities through a financial institution of Somasundaram to include groups of analysts who may be configured using the administration module in order to define groupings of work for alerts based on assignment rules (e.g., skills, resources, experience), as taught by Kloostra, in order to provide less cost and more efficient way for reviewing potential suspicious customer activities. (Kloostra: See [0003-0005])
Regarding claim 8:
Somasundaram does not explicitly disclose the following, however Guo further teaches:
The computer-implemented method according to claim 4, further comprising identifying a plurality of distinct relationship-based entity groups from the entity network graph. (see Guo, at least [0022] “the present invention provide a solution to the technical problems of detecting online money laundering. More specifically, the system constructs a fund transfer graph, with the nodes in the graph being the user account and the edges being the transaction relationship. The system can use a cluster-analysis technique to cluster the nodes in the fund-transfer graph into a number of groups and create a subgraph for each group of nodes.”; and [0046] discloses “Money-laundering-detection system 300 can further construct a subgraph for each node cluster. The nodes in each subgraph can be the nodes sharing the same group ID, and the edges in each subgraph can represent the fund-transfer relationships among nodes in the subgraphs.”)
It would have been obvious to one of ordinary skill in the art as of the effective filing date of the claimed invention to modify generating, by an alert generation unit, alert data representative of AML alert transactions of one or more entities through a financial institution of Somasundaram to include constructing a subgraph for each node cluster and the nodes in each subgraph can be the nodes sharing the same group ID, and the edges in each subgraph can represent the fund-transfer relationships among nodes in the subgraphs, as taught by Guo, in order to make easier the detection of groups of customer accounts for potentially suspicious customer activities. (Guo: See [0022-0024])
Regarding claim 9:
Somasundaram and Guo do not explicitly disclose the following, however Kloostra further teaches:
The computer-implemented method according to claim 1, wherein the determining of the capability of the AML analyst further comprises determining an availability of the AML analyst, the method further comprising routing the transaction data of the transaction alert to the AML analyst based at least in part on the optimized assignment list. (see Kloostra, at least [0036] discloses “Groups of analysts may be configured using the administration module 210 in order to define groupings of work for alerts. For example, groups can be configured to work specific types of alerts based on their source such as transaction monitoring system alerts, or fraud system alerts or branch referrals.”; and [0037] discloses “The background pre-processing routine 306 can be configured to assign alerts to an alert pre-queue 308 for either a group or a specific analyst based on the configured assignment rules. Each pre-queue may have the alerts prioritized based on the configured prioritization rules.”)
It would have been obvious to one of ordinary skill in the art as of the effective filing date of the claimed invention to modify generating, by an alert generation unit, alert data representative of AML alert transactions of one or more entities through a financial institution of Somasundaram to include groups of analysts who may be configured using the administration module in order to define groupings of work for alerts based on assignment rules (e.g., skills, resources, experience), as taught by Kloostra, in order to provide less cost and more efficient way for reviewing potential suspicious customer activities. (Kloostra: See [0003-0005])
Regarding claims 10 and 17: it is similar scope to claim 1, and thus it is rejected under similar rationale.
Regarding claims 13 and 18: it is similar scope to claim 2, and thus it is rejected under similar rationale.
Regarding claims 14 and 19: it is similar scope to claim 3, and thus it is rejected under similar rationale.
Regarding claims 15 and 20: it is similar scope to claim 4, and thus it is rejected under similar rationale.
Regarding claim 16: it is similar scope to claim 5, and thus it is rejected under similar rationale.
Claims 11-12 are rejected under 35 U.S.C. 103 as being unpatentable over Somasundaram in view of Guo in view of Kloostra in further view of Ferranti et al. (hereinafter Ferranti), US Publication Number 2019/0164172 A1.
Regarding claim 11:
Somasundaram, Guo, and Kloostra do not explicitly disclose the following, however Ferranti further teaches:
The computer program product of claim 10, wherein the stored program instructions are stored in a computer readable storage device in a data processing system, and wherein the stored program instructions are transferred over a network from a remote data processing system. (see Ferranti, at least [0008] discloses “computer program product comprises a computer readable storage medium having stored thereon program instructions executable by a processing device to cause said processing device to receive public information source data from one or more public data servers.”)
It would have been obvious to one of ordinary skill in the art as of the effective filing date of the claimed invention to modify generating, by an alert generation unit, alert data representative of AML alert transactions of one or more entities through a financial institution of Somasundaram to include program instructions executable by a processing device to cause said processing device to receive public information source data from one or more public data servers, as taught by Ferranti, in order to provide cost tracking as resources are utilized. (Ferranti: See [0019-0023])
Regarding claim 12:
Somasundaram, Guo, and Kloostra do not explicitly disclose the following, however Ferranti further teaches:
The computer program product of claim 10, wherein the stored program instructions are stored in a computer readable storage device in a server data processing system, and wherein the stored program instructions are downloaded in response to a request over a network to a remote data processing system for use in a computer readable storage device associated with the remote data processing system, further comprising: (see Ferranti, at least [0008] discloses “computer program product comprises a computer readable storage medium having stored thereon program instructions executable by a processing device to cause said processing device to receive public information source data from one or more public data servers.”, and see also [0019-0023])
program instructions to meter use of the program instructions associated with the request; and program instructions to generate an invoice based on the metered use. (see Ferranti, at least [0038] discloses “Metering and Pricing 82 provide cost tracking as resources are utilized within the cloud computing environment, and billing or invoicing for consumption of these resources.”, and see also [0008])
It would have been obvious to one of ordinary skill in the art as of the effective filing date of the claimed invention to modify generating, by an alert generation unit, alert data representative of AML alert transactions of one or more entities through a financial institution of Somasundaram to include program instructions executable by a processing device to cause said processing device to receive public information source data from one or more public data servers, as taught by Ferranti, in order to provide cost tracking as resources are utilized. (Ferranti: See [0019-0023])
Conclusion
The prior art made of record but not relied upon herein but pertinent to Applicant’s disclosure is listed in the enclosed PTO-892.
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 extension fee 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.
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/YONGSIK PARK/Examiner, Art Unit 3694
August 3, 2026
/BENNETT M SIGMOND/Supervisory Patent Examiner, Art Unit 3694
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