Prosecution Insights
Last updated: May 29, 2026
Application No. 18/152,025

PROVISIONING PLATFORM FOR MACHINE-TO-MACHINE DEVICES

Final Rejection §103
Filed
Jan 09, 2023
Priority
Dec 12, 2014 — provisional 62/091,097 +1 more
Examiner
RAZA, ZEHRA
Art Unit
3697
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
VISA INTERNATIONAL SERVICE ASSOCIATION
OA Round
4 (Final)
44%
Grant Probability
Moderate
5-6
OA Rounds
1y 3m
Est. Remaining
94%
With Interview

Examiner Intelligence

Grants 44% of resolved cases
44%
Career Allowance Rate
81 granted / 182 resolved
-7.5% vs TC avg
Strong +49% interview lift
Without
With
+49.4%
Interview Lift
resolved cases with interview
Typical timeline
4y 8m
Avg Prosecution
22 currently pending
Career history
215
Total Applications
across all art units

Statute-Specific Performance

§101
3.2%
-36.8% vs TC avg
§103
86.8%
+46.8% vs TC avg
§102
5.9%
-34.1% vs TC avg
§112
3.9%
-36.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 182 resolved cases

Office Action

§103
DETAILED ACTION The following FINAL Office action is in response to Amendment filed on January 5, 2026 for application 18/152,025. Acknowledgements Claims 1-7 and 19-25 are pending. Claims 1-7 and 19-25 have been examined. Notice of Pre-AIA or AIA Status The present application, filed on or after December 13, 2013, is being examined under the first inventor to file provisions of the AIA . Response to Arguments In response to the Applicant’s arguments under 35 USC 103, Applicant argues that the combination of Holcombe, Bowen, and Ranganathan fail to teach or suggest an electronic device comprising a utility meter or a household appliance that is configured to (1) establish, over a network connection, a communication session with a second electronic device that manages the resource; and (2) provide the payment token and transaction details to the second electronic device during the communication session over the network connection, as recited in Applicant's amended claim 1. Specifically, Applicant argues that Ranganathan fails to teach or suggest a meter or a household appliance that can conduct a transaction with a resource provider by transmitting a payment token and transaction details to the resource provider. In response to the arguments under 35 USC 103 and after careful review of the references, Examiner respectfully disagrees as primarily (1) Holcombe was used to disclose “an electronic device comprising a utility meter or a household appliance that is configured to (1) establish, over a network connection, a communication session with a second electronic device that manages the resource” in paragraphs 0060 and 0066 in which meters are disclosed for continuously monitoring and reporting the usage rate or electric power meter. Paragraph 0075 of Holcombe discloses a measurement device to monitor the actual "inflow" of energy (consumption from the utility) and paragraph 0147 discloses monitoring of a customer receiving utility services utilizing an internet protocol network and a utility monitoring device, such as a meter or a measuring device. Paragraph 0269 of Holcombe discloses how the usage data is received from a usage monitoring device that measures or estimates utility use, such as a meter and the usage monitoring device may also form part of the device (i.e., smart appliance) using the utility. Lastly, paragraphs 0273 and 0279 of Holcombe discloses how a payment can be made by electronically transmitting to the provider of the utility utilizing the wide area network. Holcombe did not disclose “provide the payment token and transaction details to the second electronic device during the communication session over the network connection”. Examiner believes that Ranganathan is sufficient to disclose “provide the payment token and transaction details to the second electronic device during the communication session over the network connection” specifically in paragraph 0007 in which a wireless appliance provides the token to a point-of-sale (POS) terminal using a communication device. One of ordinary skilled in the art discloses that a wireless appliance can be replaced by the appliance used in Holcombe. Any type of wireless or smart appliance can be used to transmit a token to a server computer that is operated by a merchant such as a grocery store. Paragraph 0018 of Ranganathan discloses how key account and personal information may be transferred from the wireless appliance to a point-of-sale (POS) terminal. Lastly, paragraph 0021 of Ranganathan clearly discloses that Wireless appliance 110 and POS terminal 130 are able to communicate with remote server 150 through internet connections. The wireless appliance 110 in Ranganathan comprises a communication device 122, a memory chip 120, a processor chip 121 and a wireless transceiver 123 which is similar to a smart appliance disclosed in Holcombe. Examiner concludes that the combination of references are sufficient to disclose the amended claims. 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 pre-AIA 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: (a) A patent may not be obtained though the invention is not identically disclosed or described as set forth in section 102 of this title, if the differences between the subject matter sought to be patented and the prior art are such that the subject matter as a whole would have been obvious at the time the invention was made to a person having ordinary skill in the art to which said subject matter pertains. Patentability shall not be negative by the manner in which the invention was made. Claims 1-3 and 19-21 are rejected under 35 U.S.C. 103 as being unpatentable over Holcombe (US 2004/0024483 A1) in view of Bowen (US 9,332,002 B1) in view of Ranganathan et al. (US 2013/0173474 A1) Regarding Claims 1 and 19, Holcombe discloses an electronic device comprising: a utility meter or a household appliance comprising: an input sensor configured to detect consumption of a resource; a processor; and a memory including instructions that, when executed with the processor, cause the processor to at least (¶0060, ¶0066, ¶0075, ¶0147, ¶0151, ¶0243, ¶0244, ¶0245, ¶0269, ¶0279): establish a first connection with a user device connected to a service provider computer via a second connection, wherein a primary function of the electronic device is unrelated to communicating with other electronic devices; (¶0241, ¶0244, ¶0245) [receive, from the service provider computer via the user device, a payment token and a policy] indicating a list of transactions that are allowed for the electronic device based at least in part on a meter or appliance type of the electronic device, certain resource types that are allowed for the electronic device, and certain resource managers with which transactions are allowed to be conducted by the electronic device (Fig. 25 (2510, 2512); ¶¶0270-¶0272, ¶0275, ¶0309) initiate a transaction in accordance with the policy by: establishing, over a network connection, a communication session with a second electronic device that manages the resource; and (¶0273, ¶0279) providing the [payment token] and transaction details to the second electronic device (¶0293) wherein the transaction details include an amount of the resource based on the detected consumption of the resource (¶0150, ¶0294, ¶0295, ¶0334) Holcombe does not disclose: [receive, from the service provider computer via the user device, a payment token and a policy] and [wherein the payment token is generated based on a device identifier associated with the electronic device and a user account information encrypted with an encryption key based on the meter or appliance type of the electronic device]. Bowen however discloses: [receive, from the service provider computer via the user device, a payment token and a policy] and (Col. 1 lines 59-66, Col. 2 lines 45-50, Col. 3 lines 41-50, Col. 6 lines 31-43) [wherein the payment token is generated based on a device identifier associated with the electronic device and a user account information encrypted with an encryption key based on the meter or appliance type of the electronic device] (Col. 6 lines 44-56, Col. 6 lines 3-14, Col. 9 line 29-36) Therefore, it would have been obvious to one of ordinary skill in the art at the time of the invention to modify the method of Holcombe to include “[receive, from the service provider computer via the user device, a payment token and a policy] and [wherein the payment token is generated based on a device identifier associated with the electronic device and a user account information encrypted with an encryption key based on the meter or appliance type of the electronic device]”, as disclosed in Bowen, in order to provide digital certificates binding a credential with information identifying a user to authenticate users in computing systems and to authorize access to computing resources (see Bowen Col. 1 lines 6-19). The combination of Holcombe and Bowen does not disclose: providing the payment [token] and transaction details to the second electronic device during the communication session over the network connection. Ranganathan however discloses: providing the payment [token] and transaction details to the second electronic device during the communication session over the network connection (¶0007, ¶0018, ¶0021, ¶0030, ¶0032). Therefore, it would have been obvious to one of ordinary skill in the art at the time of the invention to modify the method of Holcombe to include providing the payment [token] and transaction details to the second electronic device during the communication session over the network connection”, as disclosed in Ranganathan, in order to provide a method for performing vending transactions upon request by a wireless appliance using a remote account in a secure manner (see Ranganathan abstract). Regarding Claims 2 and 20, the combination of Holcombe, Bowen and Ranganathan disclose the invention as above. Ranganathan further discloses wherein the payment token is stored in a secure memory of the electronic device (¶0031). Therefore, it would have been obvious to one of ordinary skill in the art at the time of the invention to modify the method of Holcombe to include wherein the payment token is stored in a secure memory of the electronic device”, as disclosed in Ranganathan, in order to provide a method for performing vending transactions upon request by a wireless appliance using a remote account in a secure manner (see Ranganathan abstract). Regarding Claims 3 and 21, Holcombe further discloses wherein a primary function of the electronic device is to monitor consumption of the resource (¶0060, ¶0066, ¶0075, ¶0147). Claims 4-7 and 22-25 are rejected under 35 U.S.C. 103 as being unpatentable over Holcombe, Bowen and Ranganathan and in further view of Schibuk (US 2009/0132813 A1) Regarding Claims 4 and 22, the combination of Holcombe, Bowen and Ranganathan does not disclose wherein the policy restricts the transaction to a purchase of the resource. Schibuk discloses wherein the policy restricts the transaction to a purchase of the resource (¶0158, ¶0194) Therefore, it would have been obvious to one of ordinary skill in the art at the time of the invention to modify the method of Holcombe to include wherein the policy restricts the transaction to a purchase of the resource, as disclosed in Schibuk, in order to provide a system to perform transactions in a secure environment between an individual and another party (see Schibuk abstract). Regarding Claims 5 and 23, Schibuk discloses wherein the policy indicates at least one condition upon which a transaction is to be initiated (¶0212) Regarding Claims 6 and 24, Schibuk discloses wherein the one condition includes limiting the transaction to transactions associated with the meter or appliance type of the electronic device (¶0128, ¶0212, ¶0260) Regarding Claims 7 and 25, Schibuk discloses wherein the one condition includes a data or time condition associated with the transaction (¶0260) Conclusion THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to ZEHRA RAZA whose telephone number is (571)272-8128. The examiner can normally be reached 10AM-6:30PM. 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, John W Hayes can be reached at (571) 272-6708. 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. /ZEHRA RAZA/Examiner, Art Unit 3697 /JOHN W HAYES/Supervisory Patent Examiner, Art Unit 3697
Read full office action

Prosecution Timeline

Show 11 earlier events
Aug 25, 2025
Request for Continued Examination
Sep 02, 2025
Response after Non-Final Action
Oct 02, 2025
Non-Final Rejection mailed — §103
Dec 04, 2025
Interview Requested
Dec 29, 2025
Applicant Interview (Telephonic)
Dec 29, 2025
Examiner Interview Summary
Jan 05, 2026
Response Filed
May 06, 2026
Final Rejection mailed — §103 (current)

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

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Prosecution Projections

5-6
Expected OA Rounds
44%
Grant Probability
94%
With Interview (+49.4%)
4y 8m (~1y 3m remaining)
Median Time to Grant
High
PTA Risk
Based on 182 resolved cases by this examiner. Grant probability derived from career allowance rate.

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