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 .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 12/12/2025 has been entered.
Response to Amendment
Applicant’s “Amendment” filed on 11/25/2025 has been considered.
Claims 1, 7, 21, 27, and 28 are amended. Claims 1-7 and 21-33 remain pending in this application and an action on the merits follow.
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 1-7 and 21-33 are rejected under 35 USC 101. The claimed invention is directed to non-statutory subject matter because claims 1, 21, and 28 are directed to an abstract idea without significantly more. Claims 2-7, 22-27, and 29-33 fail to remedy these deficiencies.
The claims 1, 21, and 28 recite receiving a request to submit a first invoice, querying a camara to scan the first invoice, receiving image data of the first invoice, extracting a plurality of data elements, comparing the data elements with the stored expense information, determining the at least one data element meets an alert criteria, storing the plurality of data elements with an indication to prevent an initiation of funds, transmitting a notification that the first invoice is duplicative, generating a user profile, providing the user interface, receiving a selection of the graphical representation, generating a report of a plurality of invoices with an alert icon, providing the report, receiving a selection of the alert icon, and transmitting a second notification including a remedial action.
The Claims 1, 21, and 28 recite receiving, querying, extracting, comparing determining, storing, transmitting, generating, and providing steps as drafted, are processes that under broadest reasonable interpretation, cover performance of the limitation in the mind and managing personal behavior, but for the recitation of generic computer components. That is, other than reciting “a network interface, a database, a processing circuit comprising one or more processors and a memory, a camera, a first user device, and a second user device”, nothing in the claim element precludes the steps from practically being performed by organizing human activity and in the mind. For example, but for the “a network interface, a database, a processing circuit comprising one or more processors and a memory, a camera, a first user device, and a second user device” in the context of these claims encompasses a person manually receives a request to submit the first invoice, scans the first invoice, receives image data of the first invoice, extracts a plurality of data elements, compares the data elements with the stored expense information, determines the at least one data element meets an alert criteria, stores the plurality of data elements with an indication to prevent an initiation of funds, transmits a notification that the first invoice is duplicative, generates a user profile, provides the user interface, receives a selection of the graphical representation, generates a report of a plurality of invoices with an alert icon, provides the report, receives a selection of the alert icon, and transmits a second notification including a remedial action. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind and managing personal behavior but for the recitation of generic computer components, then it falls within the “Mental Processes” and the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claims recite an abstract idea.
This judicial exception is not integrated into a practical application because the claims as a whole merely describe how to generally “apply” the concept of receiving, querying, extracting, comparing determining, storing, transmitting, generating, and providing in a computer environment. The claimed computer components such as the network interface, the database, the processing circuit comprising the one or more processors and the memory, the camera, the first user device, and the second user device are recited at a high level of generality and are merely invoked as tools to perform receiving, querying, extracting, comparing determining, storing, transmitting, generating, and providing steps. Simply implementing the abstract idea on a generic computer is not a practical application of the abstract idea. Accordingly, this additional element does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. The claims 1, 21, and 28 are directed to an abstract idea.
The claims 1, 21, and 28 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 of using the network interface, the database, the processing circuit comprising the one or more processors and the memory, the camera, the first user device, and the second user device to perform receiving, querying, extracting, comparing determining, storing, transmitting, generating, and providing steps amount to no more than mere instructions to apply the exception using generic computer components. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Therefore, the claim does not amount to significantly more than the recited abstract idea (Step 2B: NO). The claims 1, 21 and 28 are not patent eligible.
Claims 2-7, 22-27, and 29-33, disclose insignificant helpful content to further describe content, such as different data elements, different alert criteria’s, utilizing and training a machine learning model, and the geolocation data is used for comparison which are merely descriptive content to further limit the abstract idea but not make it less abstract. Thus, the claims 2-7, 22-27, and 29-33 are directed to an abstract idea.
This judicial exception is not integrated into a practical application because descriptive content in claims 2-7, 22-27, and 29-33 further limit the abstract idea but not make it less abstract. Thus, the claims 2-7, 22-27, and 29-33 are directed to an abstract idea.
There are no additional claim element limitations recited in the claims 2-7, 22-27, and 29-33. Therefore, the claim does not amount to significantly more than the recited abstract idea (Step 2B: NO). The claims 2-7, 22-27, and 29-33 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 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 1-5, 21-25, and 28-32 are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Patent Application Publication No. 2020/0211012 to Franceschi et al., in view of U.S. Patent Application Publication No. 2014/0095379 to Williams et al.
With regard to claims 1, 21, and 28, Franceschi discloses a computing system of a provider, comprising:
a network interface (Fig. 6, paragraph 89);
a database configured to store expense information of the provider (paragraph 49, Additionally, expense management system 140 includes database 144. As previously discussed, the entity corresponding to company server 110 may establish one or more accounts with expense management system 140. Payment accounts in database 144 may include entity information, such as name, address, payment/funding information, additional user financial information, and/or other desired user data. The entity may establish expense controls and policies for their company that may be stored in database 144. Database 144 may also be used to store information on issued payment instruments to the company, as well as associations between payment instruments, users, user classes, expense policies, and payment networks); and
a processing circuit comprising one or more processors and a memory, the memory structured to store instructions that are executable to cause the one or more processors to (Fig. 6, paragraph 89):
receive, via the network interface and via a manual input to a first user device communicably coupled to the computing system, a request to submit a first invoice for an expense reimbursement (paragraphs 29 and 85-86, At the time of receiving a payment request. In environment 500, expense management system 140 detects a card swipe 5000. This may include data such as a card number 5002 for the card that was swiped, which may be used to identify a user 5004.); and
query, via the network interface and responsive to receiving the request, a camera device of the first user device to scan the first invoice (paragraphs 29 and 86, The message may request that the user image or capture the receipt for the recent transaction. The user may then image, such as through a camera device or functionality on the user device );
receive, via the network interface and via the first user device, image data of the first invoice based on the scan (paragraph 29, the receipt and transmit back the image);
extract, via a content recognition algorithm, a plurality of data elements of the image data of the first invoice (paragraph 29, Utilizing optical character recognition (OCR) and/or other data parsing and image processing);
compare the plurality of data elements with the stored expense information of the provider (Fig. 3A, paragraphs 25 and 68, the system may then determine if the conditions from the expense policy are met, satisfied, or the rule set is otherwise not violated (e.g., the transaction data for the payment request complies with the rule set). Expense policies may have a notion of priority so that one expense policy may override or preempt any other policies, where the most permissive rule applies and is accessed for the transaction data. For instance, if the user belongs to a sales class and executive user class, if sales only receives $20 a day in food expenses but executives are provided $100, the executive expense policy may apply and be accessed.);
determine, based on the comparison, that at least one data element of the plurality of data elements meets an alert criteria (paragraph 25, alert an administrator of particular transactions.);
store the plurality of data elements of the invoice in the database with an indication to prevent an initiation of funds corresponding to the expense reimbursement responsive to determining the at least one data element meets the alert criteria (paragraphs 25 and 81-82, the system may flag such purchases for review by the user class and/or an administrator. the administrator may view pending and completed transaction for a team that have been approved under the expense policy rules for that team. Team statement 4100 allows the administrator to view transaction 4108 in an interface or dashboard for review. Transactions 4108 include pending transactions 4110 and completed transactions 4112. In certain embodiments, pending transactions 4110 may allow the administrator to review and approve transactions that may require approval, or deny transactions that violate an expense rule.); and
transmit, via the network interface, to a second user device communicably coupled to the computing system, a notification including an indication to review the invoice (paragraph 25, However, between $1,000-$5,000, the user class is allowed purchases, but the system may flag such purchases for review by the user class and/or an administrator.);
generate a user interface displaying a user profile associated with the first user device, the user interface including a graphical representation of expenses of the user profile (paragraphs 60 and 78, Expense management system may require at least one user class for user classes 1002 and may further use external validation through company email to create a user profile and ensure the user is within the user class (e.g., based on title, position, office location, job requirements, etc.). Personal statement 4000 in interface 400a display an individual balance 4002 of charges by the user for expenses, which may also include an amount of a total expense policy used (e.g., $922.95 of $5,000 maximum over an amount of time).);
provide, via the network interface, the user interface to the first user device (fig. 4a and 4b, paragraph 77, Interface 400a of FIG. 4A is displayed by a user device accessing a system, such as expense management system 140 of FIG. 1A);
receive, via the network interface and via a user input to the user interface, a selection of the graphical representation (paragraph 81-82, Team statement 4100 may also allow an administrator to apply filters 4106, such as team members, transaction type, expense type or rule, etc., for team statement 4100 during viewing.);
generate, responsive to receiving the user input, a report of a plurality of invoices associated with the user profile, the report including the first invoice and an alert icon indicating a status of the first invoice (paragraph 81-82, When the administrator views team statement 4100, the administrator may view pending and completed transaction for a team that have been approved under the expense policy rules for that team. Team statement 4100 allows the administrator to view transaction 4108 in an interface or dashboard for review. Transactions 4108 include pending transactions 4110 and completed transactions 4112. In certain embodiments, pending transactions 4110 may allow the administrator to review and approve transactions that may require approval, or deny transactions that violate an expense rule. Examiner notes that pending and completed are considered as “indicating a status of invoices”);
provide, via the network interface and via the user interface, the report to the first user device (Fig. 4B, paragraph 81-82, Team statement 4100 allows the administrator to view transaction 4108 in an interface or dashboard for review. Transactions 4108 include pending transactions 4110 and completed transactions 4112).
However, Franceschi does not disclose wherein the alert criteria comprises a first data element of the plurality of data elements matching a second data element in the stored expense information; and wherein the notification includes an indication that the invoice is duplicative; receive, via the network interface and via a second user input to the user interface, a selection of the alert icon; and transmit, via the network interface and responsive to receiving the selection of the alert icon, a second notification to the first user device, the second notification including a remedial action to address the duplicative first invoice.
However, Williams teaches wherein the alert criteria comprises a first data element of the plurality of data elements matching a second data element in the stored expense information and wherein the notification includes an indication that the invoice is duplicative (Duplicate detection rules 156 represent any suitable information operable to facilitate the determination of whether the a payment should be reviewed to identify a potential duplicate payment. Duplicate detection rules 156 may also utilize a master index repository of past transactions that can be compared to subsequent payments. If the payment does appear to be a potential duplicate according to duplicate detection rules 156, a duplicate detection exception is identified. paragraphs 39 and 72); receive, via the network interface and via a second user input to the user interface, a selection of the alert icon (the user of workstation 30 may be unable to resolve the exception identified by perfection module 100 and may interact with a button, such as the "unresolved" button shown in FIG. 3. paragraph 53); and transmit, via the network interface and responsive to receiving the selection of the alert icon, a second notification to the first user device, the second notification including a remedial action to address the duplicative first invoice (In some embodiments, this indication may trigger the execution of additional exception handling procedures that interact with a general ledger (not shown) that provides the ability to remove an item exception from a posting work steam without rendering a transaction out of balance. Indication that an exception is unresolved may also trigger the execution of exception bypass procedures (not shown) that replace the exceptions identified by perfection module 100 with work in process suspense entries. In some embodiments, indication that an exception is unresolved may also trigger interaction with an adjustment platform that serves as a repository for exceptions that will be addressed outside of the workflow of perfection module 100. FIG. 4 illustrates another example GUI 200b that facilitates review and input by a user related to the detection of duplicate payments. For example, if perfection module 100 evaluates duplicate detection rules 156 and identifies an exception, it executes duplicate detection procedures 176, which may utilize visual inspection logic 190 to facilitate the presentation of GUI 200b on a workstation 30. paragraphs 53 and 54).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Franceschi to include, wherein the alert criteria comprises a first data element of the plurality of data elements matching a second data element in the stored expense information; and wherein the notification includes an indication that the invoice is duplicative; receive, via the network interface and via a second user input to the user interface, a selection of the alert icon; and transmit, via the network interface and responsive to receiving the selection of the alert icon, a second notification to the first user device, the second notification including a remedial action to address the duplicative first invoice, as taught in Williams, in order to provide a more streamlined and efficient payment perfection system, which may reduce costs associated with payment perfection and facilitate the posting of payments within a shorter time period (Williams, paragraph 5).
With regard to claims 2, 22, and 29, Franceschi discloses the at least one data element comprises a name of an individual (paragraph 60, User classes 1002 may be established based on user class input 1010, which may correspond to manual input from an administrator of the company that establishes user class attributes (e.g., title, name, role, location, reporting line, etc.), members, managers or administrators, and other information.); and the alert criteria further comprises the name of the individual not matching any names of authorized users stored in the expense information (Fig. 3A, paragraph 68, the system may then determine if the conditions from the expense policy are met, satisfied, or the rule set is otherwise not violated (e.g., the transaction data for the payment request complies with the rule set). ).
With regard to claims 3, 23, and 30, Franceschi discloses the at least one data element comprises a location (paragraph 60, user class attributes (e.g., title, name, role, location, reporting line, etc.)); and the alert criteria further comprises the location not matching any authorized locations stored in the expense information (Fig. 3A, paragraphs 19 and 68-69, Thus, the classes may be designated by title, team, role, location, or other attribute. the conditions may not be met to approve the payment request, and flowchart 300a may proceed to step 310).
With regard to claims 4, 24, and 31, Franceschi discloses the at least one data element comprises a first date and a first location (paragraphs 19 and 60, Thus, the classes may be designated by title, team, role, location, or other attribute. The organization may further generate expense policies, which may include expense attributes such as global limits, approval limits, restricted/prohibited merchant or purchase types, time period specific limits, approved transaction types, and other limitations, permissions, or rules.); and the alert criteria further comprises the first date and the first location matching a second date and a second location stored in the expense information (Fig. 3A, paragraphs 19, 26, and 68-69, a policy may allow for group spending that increases a total allowable spend (e.g., on a single item or over a time period)).
With regard to claims 5, 25, and 32, Franceschi discloses the at least one data element comprises a payment amount (paragraphs 19 and 25, expense attributes such as global limits, approval limits, restricted/prohibited merchant or purchase types, time period specific limits, approved transaction types, and other limitations, permissions, or rules.); and the alert criteria further comprises the payment amount exceeding a threshold stored in the expense information (paragraph 25, the expense management system may be set up to allow for different authorizations and/or limit expense policies based on additional data provided with the payment request and/or previous transactions.).
Claims 6-7, 26-27, and 33 are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Patent Application Publication No. 2020/0211012 to Franceschi et al., in view of U.S. Patent Application Publication No. 2014/0095379 to Williams et al., and further in view of U.S. Patent Application Publication No. 2019/0303939 to Kurian et al.
With regard to claim 6, 26, and 33, the combination of references substantially discloses the claimed invention, however, the combination of references does not disclose the instructions further cause the one or more processors to: compare the plurality of data elements with the stored expense information of the provider using a machine learning model; and determine, based on the comparison, that the at least one data element of the plurality of data elements meets the alert criteria; wherein the machine learning model is trained to detect at least one pattern in the plurality of data elements.
However, Kurian teaches compare the plurality of data elements with the stored expense information of the provider using a machine learning model; and determine, based on the comparison, that the at least one data element of the plurality of data elements meets the alert criteria; wherein the machine learning model is trained to detect at least one pattern in the plurality of data elements (FIG. 6B shows an example of a notification 620 that a charge from a second participant exceeds amounts historically charged by the participant. As in a previous example, a charge from a particular utility may significantly exceed amounts previously charged by the same utility. The abstracted intelligence layer 430 may generate a user alert 620, which may prompt the user to investigate whether the charge was potentially erroneous. As the abstracted intelligence layer 430 gathers additional data, including responses to user inquiries and additional transaction data, the criteria may be further refined through machine learning. In this example, the abstracted intelligence layer 430 may learn seasonal patterns for utility charges so that subsequent transactions that correspond to normal seasonal fluctuations may not be flagged as unusual charges., paragraph 89).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the combination of references to include, compare the plurality of data elements with the stored expense information of the provider using a machine learning model; and determine, based on the comparison, that the at least one data element of the plurality of data elements meets the alert criteria; wherein the machine learning model is trained to detect at least one pattern in the plurality of data elements, as taught in Kurian, in order to learn seasonal patterns for utility charges (Kurian, paragraph 89).
With regard to claims 7 and 27, the combination of references substantially discloses the claimed invention, however, the combination of references does not disclose request, via the network interface, geolocation data of the first user device receive, via the network interface, the geolocation data of the first user device; compare the plurality of data elements with the stored expense information of the provider and with the geolocation data; determine, based on the comparison, that the plurality of data elements and the geolocation data does not match; and determine, based on the comparison, that the at least one data element of the plurality of data elements meets the alert criteria.
However, Kurian teaches request, via the network interface, geolocation data of the first user device receive, via the network interface, the geolocation data of the first user device; compare the plurality of data elements with the stored expense information of the provider and with the geolocation data; determine, based on the comparison, that the plurality of data elements and the geolocation data does not match; and determine, based on the comparison, that the at least one data element of the plurality of data elements meets the alert criteria ( the computing platform may compare geolocation information of a transaction request to that of the predetermined criteria. The transaction information transmitted to the user computing device may include an indication of any discrepancy between the geolocation information of the transaction request and that of the predetermined criteria. A discrepancy in geolocation information may be, for example, a warning of a potentially fraudulent transaction since the transaction request was made remote from the user's location. The abstracted intelligence layer 430 may determine that the user is physically located in a different state or country than the state or country from which a transaction request is received. Upon identifying such discrepancies in locations, abstracted intelligence layer 430 may generate appropriate user alerts to resolve whether the requested transaction was authorized, paragraphs 4 and 86).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the combination of references to include, request, via the network interface, geolocation data of the first user device receive, via the network interface, the geolocation data of the first user device; compare the plurality of data elements with the stored expense information of the provider and with the geolocation data; determine, based on the comparison, that the plurality of data elements and the geolocation data does not match; and determine, based on the comparison, that the at least one data element of the plurality of data elements meets the alert criteria, as taught in Kurian, in order to detect potentially fraudulent transactions (Kurian, paragraph 86).
Response to Arguments
Applicants' arguments filed on 11/25/2025 have been fully considered but they are not fully persuasive especially in light of the new art used in the rejections.
Applicants remark that “the combination of references does not disclose generate a user interface displaying a user profile associated with the first user device, the user interface including a graphical representation of expenses of the user profile; provide, via the network interface, the user interface to the first user device; receive, via the network interface and via a user input to the user interface, a selection of the graphical representation; generate, responsive to receiving the user input, a report of a plurality of invoices associated with the user profile, the report including the first invoice and an alert icon indicating a status of the first invoice; provide, via the network interface and via the user interface, the report to the first user device; receive, via the network interface and via a second user input to the user interface, a selection of the alert icon; and transmit, via the network interface and responsive to receiving the selection of the alert icon, a second notification to the first user device, the second notification including a remedial action to address the duplicative first invoice”.
Examiner directs Applicants' attention to the office action above.
Conclusion
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/ARIEL J YU/Primary Examiner, Art Unit 3627