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 . This office action is in response to applicant's communication of December 24, 2025. The rejections are stated below. Claims 1, 4, 8, 11, 15, and 18 are pending and have been examined.
Response to Amendment/Arguments
Applicant’s arguments concerning claims 1, 4, 8, 11, 15, and 18 rejected under 35 U.S.C. 101 have been considered but are not persuasive. The amended claims recite a method of paying a credit-product invoice by converting reward points into a currency, crediting a demand-deposit account (DDA) with that currency, and then debiting the same DDA to settle the invoice. This is a fundamental economic practice, a method of organizing human activity that falls squarely within the “certain methods of organizing human activity” grouping identified as an abstract idea. MPEP § 2106.04(a)(2) explains that “fundamental economic principles or practices” are abstract ideas. Paying an invoice with accumulated rewards is a commercial practice. The claims merely automate that practice using computing components. The focus of the claims is on converting non-currency rewards into a form that can be used for payment, not on a specific technological improvement.
The additional limitations in the claims, individually and in combination, represent the use of standard computer systems and data processing techniques to execute the underlying abstract idea. They do not provide an inventive concept sufficient to transform the claim into a patent eligible application. The recitation of a "public application programming interface gateway" describes a common interface for receiving electronic requests. The specification states such a gateway may accept calls without authentication, which is a typical function of such interfaces (0043). The "points bank" is a data store that maintains customer reward balances and associated account numbers. Querying a database to retrieve a balance and an account identifier, and updating that balance, constitutes data processing. The "automated ledger update" to credit and then debit a specific demand deposit account describes accounting transactions performed by financial software. The use of a "machine learning model" to analyze payment requests for fraud is a known application of analytical tools in the financial services field. Sending a message to halt a transaction based on such analysis is a standard risk mitigation response. The combination of these elements amounts to an instruction to apply the abstract idea of invoice payment with rewards using the additional elements as a tool and or linking the exception to a particular technological environment.
Applicant asserts the claim elements integrate the abstract idea into a practical application by tying it to specific computing operations. However, merely describing the use of standard computing mechanisms to perform the steps of an economic practice does not create a patent eligible practical application. The technological components are employed in their expected manner: an API receives a request, a database is queried and updated, an account ledger is modified, and a software model assesses risk. The claim does not alter the normal operation of these components or solve a technical problem in their function. It instead employs them as tools to execute the financial process.
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, 4, 8, 11, 15, and 18 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea of invoice payments using earned points without significantly more.
The Examiner has identified independent method Claim 1 as the claim that represents the claimed invention for analysis.
Claim 1 is directed to a method which is one of the four statutory categories of invention (Step 1: YES).
Claim 1 recites “a method comprising: receiving, at a … , a request, wherein the request initiates an invoice payment, wherein the request comprises an … that are accepted without authenticating a source of the request and without validating the source of the request, and wherein one or more parameters of the … includes a customer identifier, an invoice identifier, and a payment amount;
sending, by the … and to an …, the one or more parameters;
determining, by a …, a number of reward points that is equal to the payment amount;
executing, by the …, a query, wherein the query includes the customer identifier as a lookup parameter, and wherein the query returns a number of reward points associated with the customer identifier and a demand deposit account number;
determining, by the …, that the number of reward points returned by the query is equal to or greater than the number of reward points that is equal to the payment amount;
sending, by the …, a communication to the …, wherein the communication includes the demand deposit account number;
maintaining, by …, a points bank that stores a reward-linked demand deposit account number associated with the customer identifier and, upon determining that the number of reward points is sufficient, the … performs an update on the points bank to deduct the corresponding number of reward points and returns the reward-linked demand deposit account number and a dollar amount corresponding to the payment amount to the …;
determining, by the …, a demand deposit account with a currency in an amount equal to the payment amount, wherein the demand deposit account is associated with the demand deposit account number;
initiate, by the …, upon receipt of the reward-linked demand deposit account number and the dollar amount an … ledger update to credit the reward-linked demand deposit account with the dollar amount and initiating an … payment of the invoice by debiting the credited reward-linked demand deposit account;
processing, by a … comprising a machine learning model, based on the request details received from the …;
determining, by the machine learning model, the … having been … to recognize fraudulent patterns in payment requests, a prediction that the payment request is fraudulent based on fraud rules and the request details;
receiving, by a … and from the …, the prediction that the payment request is fraudulent; and
exiting, by the …, a payment process comprising a transfer of the payment amount according to the invoice payment; and
passing, by the … to the …, a message comprising a halt-payment message that causes the payment engine to stop any pending transfer of the payment amount when the fraud prediction indicates likely fraud”.
These limitations describe an abstract idea of invoice payments using earned points and corresponds to Certain Methods of Organizing Human Activity (fundamental economic principles such as processing an invoice payment). (Step 2A: Prong 1: YES).
The judicial exception is not integrated into a practical application. The additional elements of “payment platform comprising a payment engine, an application programming interface method call communicated through a public application programming interface gateway, rewards platform of the issuing organization backend comprising a reward management engine, automated, electronic, processing, by a fraud platform of the issuing organization backend, the fraud platform comprising a machine learning model, trained, pay-with-point logic executed by a reward management engine of the rewards platform …” which do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as they do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field. Claim 1 is directed to an abstract idea without a practical application (Step 2A - Prong 2: NO).
Further, as the additional elements of claim 1 do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field. Thus, claim 1 is not patent eligible (Step 2B: NO).
Claim 8 also recites the abstract idea of invoice payments using earned points and Organizing human activity fundamental economic principles such as processing an invoice payment. Claim 8 includes the additional elements of “a system comprising at least one computer including a processor wherein the at least one computer is configured to execute a payment platform comprising a reward management engine, and wherein the at least one computer is configured, an application programming interface method call communicated through a public application programming interface gateway, rewards platform of the issuing organization backend comprising a reward management engine, automated, electronic, processing, by a fraud platform of the issuing organization backend, the fraud platform comprising a machine learning model, trained, pay-with-point logic executed by a reward management engine of the rewards platform …” . The additional elements of claims 8 do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment. There is no improvement to the functioning of a computer, or to any other technology or technical field (MPEP 2106.05(a).
Claim 15 also recites the abstract idea of invoice payments using earned points and Organizing human activity fundamental economic principles such as processing an invoice payment. Claim 15 includes the additional elements of “a non-transitory computer readable storage medium, including instructions stored thereon, which instructions, when read and executed by one or more computer processors, payment platform comprising a reward management engine, an application programming interface method call communicated through a public application programming interface gateway, rewards platform of the issuing organization backend comprising a reward management engine, automated, electronic, processing, by a fraud platform of the issuing organization backend, the fraud platform comprising a machine learning model, trained, pay-with-point logic executed by a reward management engine of the rewards platform …”. The additional elements of claims 15 do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment. There is no improvement to the functioning of a computer, or to any other technology or technical field (MPEP 2106.05(a).
Claims 4, 11, and 18 recites “wherein the request is generated by a computer application executing on the electronic device” as an additional elements. The additional elements do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment. There is no improvement to the functioning of a computer, or to any other technology or technical field (MPEP 2106.05(a).
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 KEVIN T POE whose telephone number is (571)272-9789. The examiner can normally be reached on Monday-Friday 9:30am through 6pm EST.
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/K.T.P/Examiner, Art Unit 3692 /KEVIN T POE/
/RYAN D DONLON/Supervisory Patent Examiner, Art Unit 3692 February 27, 2026