Prosecution Insights
Last updated: April 19, 2026
Application No. 18/170,183

CASHLESS PAYMENT TRANSACTION PROCESSING DEVICE AND METHOD

Final Rejection §101
Filed
Feb 16, 2023
Examiner
MUTSCHLER, JOSEPH M
Art Unit
3627
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Toshiba TEC Kabushiki Kaisha
OA Round
2 (Final)
60%
Grant Probability
Moderate
3-4
OA Rounds
2y 10m
To Grant
99%
With Interview

Examiner Intelligence

Grants 60% of resolved cases
60%
Career Allow Rate
137 granted / 227 resolved
+8.4% vs TC avg
Strong +48% interview lift
Without
With
+48.2%
Interview Lift
resolved cases with interview
Typical timeline
2y 10m
Avg Prosecution
28 currently pending
Career history
255
Total Applications
across all art units

Statute-Specific Performance

§101
31.5%
-8.5% vs TC avg
§103
49.7%
+9.7% vs TC avg
§102
8.7%
-31.3% vs TC avg
§112
8.9%
-31.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 227 resolved cases

Office Action

§101
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 the Claims This Office Action is in response to Applicant’s reply dated 7/22/2025, claims 1, 9-10, and 16 have been amended, and claims 1-20 are currently pending and being examined in this reply. Response to Arguments Regarding the 101 arguments: Applicant’s arguments regarding the 101 rejection have been considered but are not found to be persuasive. Applicant argues that the addition of claim elements of a scanner, in combination with all the other recited components points to the claims not being directed to certain methods of organizing human activity and instead an improvement to the tech. field of transaction processing devices. The Examiner disagrees and asserts that the claims are directed to the abstract idea of organizing human activity as outlined in the 101 rejection found below, and other than reciting “processor, scanner, display, printer, and communication interface”, nothing in the claim element precludes the step from practically being a method of organized human activity. For example, but for the “processor, scanner, display, printer, and communication interface”, the below underlined limitations in the context of this claim encompasses certain methods of organizing human activity. If the claim limitations, under its broadest reasonable interpretation, covers managing personal behavior or relationships or interactions between people and fundamental economic practices, but for the recitation of generic computer components, then it falls within the “certain methods of organizing human activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea. 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 1-20 are rejected under 35 U.S.C. § 101 because the claimed invention is directed to a judicial exception (i.e., an abstract idea) without “significantly more.” Claims 1-20 are directed to certain methods of organizing human activity which is considered an abstract idea. Further, the claim(s) as a whole, when examined on a limitation-by-limitation basis and in ordered combination do not include an inventive concept. Step 1 – Statutory Categories In regard to claims 1-20 as indicated in the preamble of the claims, the examiner finds the claims are directed to a process, machine, or article of manufacture. Step 2A – Prong One - Abstract Idea Analysis Representative claim 16 recites the following abstract concepts, in italics below, which are found to include an “abstract idea”: A non-transitory, computer-readable medium storing program instructions which when executed by a processor of a cashless transaction processing device causes the device to perform a method comprising: acquire a settlement brand for a cashless settlement of a retail transaction from a customer information terminal by reading the settlement brand from the customer information terminal with a scanner; sending a notification to a settlement server via communication interface, the notification indicating a payment amount for a transaction and a settlement brand for a cashless settlement of the transaction; detecting brand information and message data included in payment result data returned from the settlement server in response to the notification; editing data to be output to incorporate the detected brand information and message data; and outputting the edited data. The claim features in italics above as drafted, under its broadest reasonable interpretation are certain methods of organizing human activity (fundamental economic practices and managing personal behavior or relationships or interactions between people) performed by generic computer components. That is, other than reciting “processor, scanner, display, printer, and communication interface”, nothing in the claim element precludes the step from practically being a method of organized human activity. For example, but for the “processor, scanner, display, printer, and communication interface”, the above underlined limitations in the context of this claim encompasses certain methods of organizing human activity. If the claim limitations, under its broadest reasonable interpretation, covers managing personal behavior or relationships or interactions between people and fundamental economic practices, but for the recitation of generic computer components, then it falls within the “certain methods of organizing human activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea. Step 2A – Prong Two - Abstract Idea Analysis This judicial exception is not integrated into a practical application. In particular, the claim only recites 5 additional elements – “processor, scanner, display, printer, and communication interface”. They are recited at a high-level of generality (i.e., as a generic processor performing generic computer functions) such that it amounts no more than mere instructions to apply the exception using a generic computer component (MPEP 2106.05(f)), data gathering, which is a form of insignificant extra-solution activity (MPEP 2106.05(g)), and linking the use of the judicial exception to a particular technological environment or field of use (MPEP 2106.05(h)). Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. The claim is directed to an abstract idea. Step 2B - Significantly More Analysis 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 of “processor, scanner, display, printer, and communication interface” amounts to no more than mere instructions to apply the exception using a generic computer component, insignificant extra-solution activity, and linking the use of the judicial exception to a particular technological environment or field of use. Mere instructions to apply the exception using a generic computer component, insignificant extra-solution activity, and linking the use of the judicial exception to a particular technological environment or field of use, cannot provide an inventive concept. Further, the background and specification does not provide any indication that the “processor, scanner, display, printer, and communication interface” is anything other than a generic, off-the-shelf computer components. For these reasons, there is no inventive concept. Prior Art considered relevant to Applicant’s disclosure US 2016/0086454 A1 to Kelly et al. teaches receiving, by a server via a network, transaction information descriptive of a money transfer transaction initiated at a point of entry device. The transaction information includes information that identifies a location of the point of entry device. The method includes determining, by the server, receipt information to be included in a receipt for the money transfer transaction. The receipt information may be determined based, at least in part, on the transaction information, and at least a portion of the receipt information included in the receipt satisfies regulatory requirements associated with the location of the point of entry device. The method includes generating, by the server, the receipt that includes the receipt information, and transmitting the receipt from the server to the point of entry device via the network. (abstract) US 2019/0244224 A1 to Tonnison et al. teaches means for said account associated with said entity or issuer to create an e-receipt or e-invoice by inputting item data in an e-receipt or e-invoice template, wherein said e-receipt or e-invoice template further including but not limited to said issuer's information, detailed item information, payment method, and total amount; means for said account associated with said issuer to customize e-receipts or e-invoices, wherein logos or designs are inserted; means for said account associated with said issuer to send said e-receipt or e-invoice to an account associated with a recipient by entering said recipient's account name on online expense application or said recipient's email address with said service computer system (see claim 3) 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 JOSEPH M MUTSCHLER whose telephone number is (313)446-6603. The examiner can normally be reached 0600-1430. 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, Florian Zeender can be reached at (571)272-6790. 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. /JOSEPH M MUTSCHLER/Examiner, Art Unit 3627 /A. Hunter Wilder/Primary Examiner, Art Unit 3627
Read full office action

Prosecution Timeline

Feb 16, 2023
Application Filed
Apr 17, 2025
Non-Final Rejection — §101
Jul 22, 2025
Response Filed
Oct 31, 2025
Final Rejection — §101 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

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ACCOUNTING PROCESSING METHOD, REGISTRATION PROCESSING METHOD, ACCOUNTING DEVICE, AND STORAGE MEDIUM
2y 5m to grant Granted Mar 31, 2026
Patent 12586049
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2y 5m to grant Granted Mar 24, 2026
Patent 12579530
SYSTEM AND METHOD FOR PROVIDING A REAL-TIME PAYMENT BETWEEN A CUSTOMER FINANCIAL INSTITUTION ACCOUNT AND A MERCHANT FINANCIAL INSTITUTION ACCOUNT FOR A TRANSACTION BASED ON A DIRECT COMMUNICATION BETWEEN A USER DEVICE AND A POINT-OF-SALE DEVICE
2y 5m to grant Granted Mar 17, 2026
Patent 12567052
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Patent 12536518
MODULAR TRANSACTION TERMINAL ARCHITECTURE
2y 5m to grant Granted Jan 27, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

3-4
Expected OA Rounds
60%
Grant Probability
99%
With Interview (+48.2%)
2y 10m
Median Time to Grant
Moderate
PTA Risk
Based on 227 resolved cases by this examiner. Grant probability derived from career allow rate.

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