DETAILED ACTION
1. 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 .
2. Status of Application and Claims
Claims 1-46 are pending.
Claims 1, 11, and 19 were amended or newly added in the Applicant’s filing on 12/26/2025 and 4/16/2026.
This office action is being issued in response to the Applicant's filing on 12/26/2025 and 4/16/2026.
3. Claim Interpretation
The subject matter of a properly construed claim is defined by the terms that limit its scope when given their broadest reasonable interpretation. see MPEP §2013(I)(C). Specifically, the “broadest reasonable construction ‘in light of the specification as it would be interpreted by one of ordinary skill in the art.’” See MPEP §2111, citing Phillips v. AWH Corp., 75 USPQ2d 1321, 1329 (Fed. Cir. 2005). However, “[t]hough understanding the claim language may be aided by explanations contained in the written description, it is important not to import into claim limitations that are not part of the claim.” See MPEP §2111.01, citing Superguide Corp. v. DirecTV Enterprises, Inc., 69 USPQ2d 1865, 1868 (Fed. Cir. 2004). Construing claims broadly during prosecution is not unfair to the applicant, because the applicant has the opportunity to amend the claims to obtain more precise claim coverage. See MPEP §2111, citing In re Yamamoto, 222 USPQ 934, 936 (Fed. Cir. 1984).
As a general matter, grammar and the plain meaning of terms as understood by one having ordinary skill in the art used in a claim will dictate whether, and to what extent, the language limits the claim scope. See MPEP §2013(I)(C). Language that suggests or makes a feature or step optional but does not require that feature or step does not limit the scope of a claim under the broadest reasonable claim interpretation. See MPEP §2013(I)(C).
As such, claim limitations that contain statement(s) such as “if,” “may,” “might,” “can,” and “could” are treated as containing optional language. See MPEP §2013(I)(C). As matter of linguistic precision, optional claim elements do not narrow claim limitations, since they can always be omitted. See MPEP §2013(I)(C).
Similarly, a method step exercised or triggered upon the satisfaction of a condition, where there remains the possibility that the condition was not satisfied under the broadest reasonable interpretation, is an optional claim limitation. See MPEP §2111.04(II). As the Applicant does not address what happens should the optional claim limitations fail, Examiner assumes that nothing happens (i.e., the method stops). An alternate interpretation is that merely the claim limitations based upon the condition are not triggered or performed.
In addition, when a claim requires selection of an element from a list of alternatives, the prior art teaches the element if one of the alternatives is taught by the prior art. See MPEP §2143.03, citing Fresenius USA, Inc. v. Baxter Int’l, Inc., 582 F.3d 1288, 1298 (Fed. Cir. 2009);
Language in a method or system claim that states only the intended use or intended result, but does not result in a manipulative difference in the steps of the method claim nor a structural difference between the system claim and the prior art, fails to distinguish the claims from the prior art.
The following types of claim language may raise a question as to its limiting effect (this list is not exhaustive):
Statements of intended use or field of use, including statements of purpose or intended use in the preamble. See MPEP §2111.02;
Clauses such as “adapted to”, “adapted for”, “wherein”, and “whereby.” See MPEP §2111.04;
Contingent limitations. See MPEP §2111.04(II);
Printed matter. See MPEP §2111.05; and
Functional language associated with a claim term. See MPEP §2181.
As such, while all claim limitations have been considered and all words in the claims have been considered in judging the patentability of the claimed invention, the following italicized, underlined and/or boldened language is interpreted as not further limiting the scope of the claimed invention.
Additionally, the following italicized, underlined and emboldened language is not necessarily an exhaustive list of claim language that is interpreted as not further limiting the scope of the claimed invention. Applicant should review all claims for additional claim interpretation issues.
Claim 1 recites a system to:
identify, responsive in real-time to the determination of the reimbursement amount based at least in part on the rule relating to satisfying the threshold for the time interval for reimbursement and based on a preconfigured mapping of the electronic account, a destination purse, different from the first purse, for receipt of the reimbursement amount, wherein the destination purse is i) configured with having different restrictions relative to the first purse from which the first amount is transferred to the entity to allow unrestricted transfers of funds within the destination purse, and ii) maintained on a server remote from the one or more processors.
A system claim is defined the method steps that the structural elements of said system are configured to perform or, when the system is executing stored instructions, the method steps to be performed by the structural elements of said system.
However, structural elements outside the recited system are not part of the recited system. The system is communicating with a server (i.e., a structural element outside the system) wherein resides a purse (i.e., a structural element outside the system). The method steps performed by structural elements outside the recited system have no patentable weight.
Claims 19, due to similar claim language, result in a similar claim interpretation.
Claim 1 recites a system to:
identify, responsive in real-time to the determination of the reimbursement amount based at least in part on the rule relating to satisfying the threshold for the time interval for reimbursement and based on a preconfigured mapping of the electronic account, a destination purse, different from the first purse, for receipt of the reimbursement amount, wherein the destination purse is i) configured with having different restrictions relative to the first purse from which the first amount is transferred to the entity to allow unrestricted transfers of funds within the destination purse, and ii) maintained on a server remote from the one or more processors.
The restrictions of the destination purse pertain to nonfunctional descriptive material and are not functionally involved in the steps recited. Thus, this descriptive material will not distinguish the claimed invention from the prior art in terms of patentability. See MPEP §2111.05 (III).
Examiner notes that the system/method pertains to transferring funds into a destination purse. The restrictions pertain to potential future transactions from the destination purse.
Claims 11 and 19, due to similar claim language, result in a similar claim interpretation.
Claim 11 recites a method comprising:
determining, by the one or more processors, a reimbursement amount related to the first electronic transaction and based on eligibility of reimbursement according to one or more rules including a rule relating to satisfying a threshold for a time interval for reimbursement;
selecting, by the one or more processors, responsive in real-time to the determination of the reimbursement amount based at least in part on the rule relating to satisfying the threshold for the time interval for reimbursement and based on a preconfigured mapping of the electronic account, a destination purse, different from the first purse, for receipt of the reimbursement amount, wherein the destination purse is i) configured with different restrictions relative to at least one of the plurality of purses linked with the electronic account to allow unrestricted transfers of funds within the destination purse, and ii) maintained on a server remote from the one or more processors;
…
transmit, responsive in real-time relative to the identification of the destination purse, and upon satisfaction of the rule comprising the threshold of the time interval for reimbursement, data packets to cause a transfer of the reimbursement amount to the destination purse having the different restrictions relative to the first purse.
The broadest reasonable interpretation of a method (or process) claim having contingent limitations requires only those steps that must be performed and does not include steps that are not required to be performed because the condition(s) precedent is not met. See MPEP §2111.04(II).
Usage of the term and/or phrase “based at least in part on the rule relating to satisfying the threshold for the time interval for reimbursement” and “upon satisfaction of the rule comprising the threshold of the time interval for reimbursement” in Claim 11 suggests that there remains the possibility that the contingent limitations are not performed as the condition(s) precedent is not met. For example, the method determines a reimbursement amount of zero related to the first electronic transaction and based on eligibility of reimbursement according to one or more rules including a rule relating to satisfying a threshold for a time interval for reimbursement. The claim, as written, does not establish that the “rule relating to satisfying a threshold for a time interval for reimbursement” has been satisfied.
Therefore, the claim limitations based upon the condition are optional claim limitations. As a matter of linguistic precision, optional claim limitations do not narrow the scope of the invention, since they can always be omitted. See MPEP §2111.04(II).
As the Applicant does not address what happens should the optional claim limitation(s) fail, Examiner assumes that nothing happens (i.e., the method stops). An alternate interpretation is that merely the claim limitations based upon the condition are not triggered or performed.
Claim 11 recites a method comprising:
selecting, by the one or more processors, responsive in real-time to the determination of the reimbursement amount based at least in part on the rule relating to satisfying the threshold for the time interval for reimbursement and based on a preconfigured mapping of the electronic account, a destination purse, different from the first purse, for receipt of the reimbursement amount, wherein the destination purse is i) configured with different restrictions relative to at least one of the plurality of purses linked with the electronic account to allow unrestricted transfers of funds within the destination purse, and ii) maintained on a server remote from the one or more processors;
Method claims are defined by the method steps being actively performed, not method steps that may or may not be performed. Reciting a system element in a method claim is configured to perform a method step (i.e., to allow unrestricted transfers of funds within the destination purse) does not mean that the method step is actually performed (i.e., to allow unrestricted transfers of funds within the destination purse).
Method claims are defined by the method steps being actively performed, not method steps performed in the past (i.e., maintaining). Claiming method steps in the past tense (i.e., maintained) can be interpreted as the method steps performed in the past are outside the scope of the claimed method. Alternatively stated, the scope of the claimed method are the active method steps which are building off a pre-existing state. The method steps performed for creation of the pre-existing state are outside the scope of the claimed invention.
4.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 1-46 are rejected under 35 U.S.C. § 101 because the claimed invention is directed to an abstract idea without significantly more.
STEP 1
The claimed invention falls within one of the four statutory categories of invention (i.e., process, machine, manufacture and composition of matter). See MPEP §2106.03. The claimed invention discloses a method, a system configured to perform a method and/or an article of manufacture comprising a computer readable medium.
STEP 2A – PRONG ONE
The claim(s) recite(s) a method, a system to perform a method and a computer-readable medium containing instructions to perform a method comprising:
receiving … from … an entity external and remote … an indication to execute a first … transaction as a single transaction at the entity …, the execution of the first … transaction to use an … account linked with a plurality of purses;
conducting, …. responsive to receiving the indication and a selection of a first purse of a plurality of purses, the first … transaction comprising transferring a first amount of the first … transaction from the first purse of the … account and providing the first amount to the entity;
determining, …, a reimbursement amount related to the first … transaction that and based on eligibility of reimbursement according to one or more rules including a rule relating to satisfying a threshold for a time interval for reimbursement;
selecting, …, responsive in real-time to the determination of the reimbursement amount for the based at least in part on the rule relating to satisfying the threshold for the time interval for the reimbursement and based on a preconfigured mapping of the … account a destination purse different from the first purse, different from the first purse, based on the preconfigured mapping of the account, for receipt of the reimbursement amount, wherein the destination purse is i) configured with different restrictions relative to the at least one of the plurality of purses linked with the … account …;
providing … responsive in real-time relative to the selection of the destination purse, and upon satisfaction of the rule comprising the threshold of the time interval for reimbursement, data … to cause a transfer of the reimbursement amount to the destination purse having the different restrictions relative to the at least one of the plurality of purses; and
transmitting, …, responsive in real-time relative to causing the transfer of the reimbursement amount to the destination purses …, a notification to a user … linked to the … account and the notification indicates the reimbursement amount transferring to the destination purse having different restrictions relative to the at least one of the plurality of purses.
These limitations, as drafted, recite a method and/or a system configured to perform a method that, under its broadest reasonable interpretation, covers a series of steps instructing how to transfer funds between financial purses/accounts which is a fundamental economic practice, a sub-category of certain method(s) of organizing human activity, an enumerated grouping of abstract ideas. See MPEP §2106.04(a)(2)(II)(A).
STEP 2A – PRONG TWO
The claimed invention recites additional elements (i.e., computer elements) of a processor (Claim(s) 1, 11 and 19), a memory (Claim(s) 1, 11 and 19), device(s) (Claim(s) 1, 11 and 19), secure network protocol(s) (Claim(s) 1, 11 and 19), an electronic account (Claim(s) 1, 11 and 19) and an electronic transaction (Claim(s) 1, 11 and 19).
The claimed invention does not include additional elements that integrate the judicial exception into a practical application of the exception because the claims do not provide improvements to another technology or technical field; improvements to the functioning of the computer itself; are not applying or using a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition; are not applying the judicial exception with or by use of a particular machine; are not effecting a transformation or reduction of a particular article to a different state or thing; and are not applying the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment. See MPEP §2106.04(d).
The additional elements are recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using a generic computer component. See MPEP §2106.05(f). Alternately, the additional elements amount to no more than generally linking the exception to a particular technological environment or field of use. See MPEP §2106.05(h). Accordingly, these additional element(s), when considered separately and as an ordered combination, do not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea.
Accordingly, the claimed invention is directed to an abstract idea without a practical application.
STEP 2B
Upon reconsideration of the indicia noted under Step 2A in concert with the Step 2B considerations, the additional claim element(s) amounts to adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer. See MPEP §2106.07(a)(II). The same analysis applies in Step 2B, i.e., mere instructions to apply an exception using a generic computer component cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. The claim does not provide an inventive concept significantly more than the abstract idea.
Accordingly, these additional elements, when considered separately and as an ordered combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
DEPENDENT CLAIMS
Dependent Claim(s) 2-10 and 12-46 recite claim limitations that further define the abstract idea recited in respective independent Claim(s) 1 and 11. As such, the dependent claims are also grouped an abstract idea utilizing the same rationale as previously asserted against the independent claims.
Dependent Claim(s) recite additional elements (i.e., computer elements) of a short message service protocol (Claim(s) 4 and 14) and server(s) (Claim(s) 21, 24, 35 and 46).
In each case, the additional element(s) are recited at a high level of generality such that these additional element(s) amount to no more than mere instructions to apply the exception using a generic computer component.
The dependent claims do not include any additional elements that integrate the abstract idea into a practical application of the judicial exception or are sufficient to amount to significantly more than the judicial exception when considered both individually and as an ordered combination utilizing the same rationale as previously asserted against the independent claims.
Accordingly, the dependent claim(s) are also not patent eligible.
Appropriate correction is requested.
5. Claim Rejections - 35 USC § 103
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.
The factual inquiries set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
1. Determining the scope and contents of the prior art.
2. Ascertaining the differences between the prior art and the claims at issue.
3. Resolving the level of ordinary skill in the pertinent art.
4. Considering objective evidence present in the application indicating obviousness or nonobviousness.
Claim(s) 1-46 are rejected under 35 U.S.C. 103 as obvious over Pletz (US PG Pub. 2014/0297307) in view of Pourfallah (US PG Pub. 2012/0253852).
Regarding Claim 11, Pletz discloses a method comprising:
receiving, by one or more processors from a first device (merchant point-of-sale) of an entity external and remote from the one or more processors (of a third-party administrator), via one or more secure network protocols established using encryption, an indication to execute a first electronic transaction as a single transaction at the entity via the one or more secure network protocols, the execution of the first transaction to use an electronic account linked with a plurality of purses (multi-purse credit card). (see para. 49 and 56);
conducting, by the one or more processors coupled with memory, via the one or more secure network protocols and responsive to receiving of the indication and a selection of a first purse of the plurality of purses the first electronic transaction comprising transferring a first amount of the first electronic transaction from the first purse (credit card) of the electronic account and provide the first amount (full dollar amount of purchase) to the entity (merchant). (see para. 61-66);
determining, by the one or more processors, a reimbursement amount (reimbursement payment amount) related to the first electronic transaction and based on eligibility of reimbursement according to one or more rules (e.g., qualifying product). (see para. 67);
selecting, by the one or more processors, responsive in real-time to the determination of the reimbursement amount based at least in part on the rule (e.g., qualifying product) and based upon a preconfigured mapping (linking) of the electronic account, a destination purse (investment account or checking account) different from the first purse (credit card) for receipt of the reimbursement amount (reimbursement payment amount). (see para. 38, 43 and 67-70);
wherein the destination purse (investment account or checking account) is (i) configured with different restrictions relative to at least one of the plurality of purses (FSA account, which has restrictions pertaining to qualified purchases), and (ii) maintained on a server (at financial institution) remote from the one or more processors (of the third-party administrators). (see para. 38, 43 and 67-70);
the destination purse having different restrictions (qualifying and non-qualifying purchases) relative to at least one of the plurality of purses (accounts) linked with the electronic account. (see abstract); and
providing, by the one or more processors, responsive in real-time relative to the selection of the destination purse (investment account), data packets to cause a transfer of the reimbursement amount (reimbursement payment amount) to the second purse (investment account). (see para. 43 and 67-70).
Pletz does not explicitly teach a method wherein the destination purse (investment or checking account) allows unrestricted transfer of funds within the destination purse. Pletz is silent regarding whether the destination purse has any restrictions pertaining to the transfer of funds.
Assuming Pletz discloses a destination purse configured with restrictions that prevented unrestricted transfers of funds within the destination purse, it would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to eliminate a restriction, since it has been held that mere omission of an element and its function in a combination, without more, involves only routine skill in the art. see MPEP §2144.04 (II).
Regardless, Porfallag discloses a method comprising utilization of a plurality of purses (accounts), wherein one purse (checking account, an non-restricted-use account) is (i) configured with different restrictions relative to at least one of the plurality of purses (FSA, a restricted-use account) to allow unrestricted transfers of funds within the one purse (unrestricted account). (see para. 68-71).
Pletz does not teach a method wherein the one or more rules include a rule relating to satisfying a threshold for a time interval for reimbursement; providing, upon satisfaction of the rule comprising the threshold of time interval for reimbursement, data packets to transfer to cause a transfer of the reimbursement amount to the destination purse; or transmitting, by the one or more processors, responsive to real-time relative to causing the transfer of the reimbursement amount to the destination purse, via the one or more secure network protocols, a notification to a user mobile device to cause the user mobile device, a graphical user interface element corresponding to the notification, wherein the user mobile device is linked to the electronic account and the notification indicates the reimbursement amount to the destination purse having the different restrictions relative to the at least one plurality of purses.
Pourfallah discloses a method wherein the one or more rules relating to satisfying a threshold for a time interval for reimbursement (reimbursements are only valid if during the appropriate year). (see para. 148 and 150).
Pourfallah discloses a method comprising:
providing, upon satisfaction of the rule comprising the threshold of time interval for reimbursement, data packets to transfer to cause a transfer of the reimbursement amount to the destination purse. (see fig. 16A-16E; para. 56 and 304-314); and
comprising transmitting, by the one or more processors, responsive to real-time relative to causing the transfer of the reimbursement amount to the destination purse, via the one or more secure network protocols, a notification to a user mobile device to cause the user mobile device to display, on a display device of the user display device, a graphical user interface element corresponding to the notification, wherein the user mobile device is linked to the electric account and the notification indicates the reimbursement amount (crediting of the user’s account) to the destination purse. (see fig. 16A-16E; para. 56 and 304-314).
It would have been obvious to one of ordinary skill in the art at the effective filing date of the invention to have modified Pletz by incorporating the notification of the user concerning a reimbursement, as disclosed by Pourfallah, thereby keeping the user informed about the status of their reimbursement, as suggested by Pletz, which notifies via credit statements. (see para. 70).
Regarding Claim 12, Pletz discloses a method comprising selecting, by the one or more processors, based on a first category (allowable goods and services) associated with the first electronic transaction and a preconfigured mapping of (linking) the electronic account, the first purse (HSA account) of the plurality of purses allocated to the electronic account, the first purse configured to allow transfers of funds exempt from payroll tax deductions (medical tax deduction) to be used to conduct approved transactions. (see para. 38.)
Regarding Claim 13, Pletz discloses a method comprising receiving, by the one or more processors, from the first device (POS terminal) of the entity (merchant) external and remote from the one or more processors, via the one or more secure network protocols established using encryption, a one or more data packets generated by the first device to conduct the first electronic transaction, the one or more data packets comprising: i) an identifier of a first category of transactions (product or service code), ii) an identifier of the electronic account (credit card information), and iii) an indication of a transaction amount (price) of the first electronic transaction (purchase). (see para. 49, 56 and 61.)
Regarding Claim 14, Pletz does not teach a method comprising transmitting, by the one or more processors, the notification to the user movile device via a short message service (“SMS”) protocol.
Purfallah discloses a method comprising transmitting, by the one or more processors, the notification to the user movile device via a short message service (“SMS”) protocol. (see para. 122.)
It would have been obvious to one of ordinary skill in the art at the effective filing date of the invention to have modified Pletz and Purfallah by incorporating utilization of a short message service protocol, as disclosed by Pourfallah, thereby utilizing a conventional and standard messaging mechanism.
Regarding Claim 15, Pletz discloses a method comprising:
using, by the one or more processors, a first policy to select the first purse (credit card) based on a first category (credit card’s BIN) associated with the first electronic transaction and the preconfigured mapping (linking) of the electronic account. (see para. 62); and
using, by the one or more processors, a second policy to determine the reimbursement amount related to the first amount (price) of the first electronic transaction and the time interval (date/time of purchase). (see para. 61-62.)
Regarding Claim 16, Pletz discloses a method comprising using, by the one or more processors, a policy to determine the reimbursement amount based on the first amount of the first electronic transaction and the time interval. (see para. 61-62.)
Pletz does not teach a method wherein the policy limits a total reimbursement amount for a first category associated with the first electronic transaction within the time interval.
Pourfallah discloses a method wherein the policy limits a total reimbursement amount for a first category associated with the first electronic transaction within the time interval. (see para. 168 and 214).
It would have been obvious to one of ordinary skill in the art at the effective filing date of the invention to have modified Pletz and Pourfallah by a reimbursement limit, as disclosed by Pourfallah, thereby comporting to the standard and conventional operation of an HSA account.
Regarding Claim 17, Pletz does not teach a method comprising determining, by the one or more processors, responsive to a request from the user device associated with the electronic account, to transmit the notification pursuant to the first electronic transaction.
Pourfallah a method comprising determining, by the one or more processors, responsive to a request from the user device associated with the electronic account, to transmit the notification pursuant to the first electronic transaction. (see para. 149.)
It would have been obvious to one of ordinary skill in the art at the effective filing date of the invention to have modified Pletz and Pourfallah by incorporating the notification of the user concerning a reimbursement, as disclosed by Pourfallah, thereby keeping the user informed about the status of their reimbursement, as suggested by Pletz, which notifies via credit statements.
Regarding Claim 18, Pletz discloses a method comprising:
receiving, by the one or more processors, a request to conduct a second electronic transaction (second portion of split transaction) at the entity. (see para. 71-84);
determining, by the one or more processors, based at least in part on a second category associated with the second electronic transaction, to use a different purse (debit card) of the plurality of purses, the different purse (credit card) having unrestricted funds (for non-qualified purchases). (see abstract; para. 47 and 71-84); and
conducting, by the one or more processors, responsive to the determination to use the different pursue, the second electronic transaction to transfer funds from the purse to the entity. (see para. 71-84.)
It would have been obvious to one of ordinary skill in the art at the effective filing date of the invention to have modified Pletz and Pourfallah by incorporating the different restrictions on purses, as disclosed by Evans, thereby acknowledging the potential of different restrictions on different purses, as disclosed by Evans.
Regarding Claims 11-20, such claims recite substantially similar limitations as claimed in previously rejected claims and, therefore, would have been obvious based upon previously rejected claims or are otherwise disclosed by the prior art applied in previously rejected claims.
Regarding Claims 1-7 such claims recite substantially similar limitations as claimed in previously rejected claims and, therefore, would have been obvious based upon previously rejected claims or are otherwise disclosed by the prior art applied in previously rejected claims.
Regarding Claim 8, Pletz discloses a system comprising to select the first purse responsive to a determination that a first category associated with the first electronic transaction corresponds to a prescription purchase. (see para. 37.)
Regarding Claim 9 such claims recite substantially similar limitations as claimed in previously rejected claims and, therefore, would have been obvious based upon previously rejected claims or are otherwise disclosed by the prior art applied in previously rejected claims.
Regarding Claim 10, Pletz does not teach a system to receive a request from the client device for information about the electronic account; authenticate the request from the client device based on credentials associated with the request; access a data record in memory for the electronic account, the data record comprising a first available amount for the first purse and a second available amount for the second purse; and provide, for display on the client device, a second notification that indicates the first available amount and the second available amount.
Pourfallah discloses a system to:
receive a request from the user device for information about the electronic account. (see para. 121);
authenticate the request from the user device based on credentials associated with the request. (See para. 121);
access a data record in memory for the electronic account, the data record comprising a first available amount for the first purse (FSA account) and a second available amount (line of credit) of the plurality of purses. (see para. 43 and 149); and
provide, for display on the user device, a second notification that indicates the first available amount and the second available amount. See para. 43-149.
It would have been obvious to one of ordinary skill in the art at the time effective filing date of the invention to have modified Pletz and Pourfallah by incorporating the notification of the user concerning a reimbursement, as disclosed by Pourfallah, thereby keeping the user informed about their remaining balances, as suggested by Pletz.
Regarding Claims 19-20, such claims recite substantially similar limitations as claimed in previously rejected claims and, therefore, would have been obvious based upon previously rejected claims or are otherwise disclosed by the prior art applied in previously rejected claims.
Regarding Claim 21, Pletz discloses a system wherein the destination purse is maintained on a server (financial institution) remote from the one or more processors. (see fig. 1).
Regarding Claim 22, Pletz does not explicitly teach a system wherein the destination purse (investment account) is configured to allow transfers of unrestricted funds.
However, Pletz discloses a system wherein purses are configured to allow transfer of unrestricted funds (for non-qualified purchases). (see abstract).
It would have been obvious to one of ordinary skill in the art at the effective filing date of the invention to have modified Pletz and Pourfallah by incorporating different restrictions on purses, as suggested by Pletz, thereby acknowledging the potential of different restrictions on different purses, as disclosed by Pletz.
Regarding Claim 23, Pletz discloses a system wherein the destination purse is linked with the electronic account (credit/debit account). (see para. 45).
Regarding Claim 24, such claims recite substantially similar limitations as claimed in previously rejected claims and, therefore, would have been obvious based upon previously rejected claims or are otherwise disclosed by the prior art applied in previously rejected claims.
Regarding Claim 25, Pletz discloses a system wherein the destination purse is linked with a debit card. (see para. 47).
Regarding Claim 26, such claims recite substantially similar limitations as claimed in previously rejected claims and, therefore, would have been obvious based upon previously rejected claims or are otherwise disclosed by the prior art applied in previously rejected claims.
Regarding Claim 27, Pletz discloses a system wherein the plurality of purses comprise at least one of a flexible spending account, a healthcare savings account, a dependent care account, or a transport account. (see abstract).
Regarding Claim 28, Pletz discloses a system comprising the one or more processors to: transfer the reimbursement amount from the at least one of the flexible spending account, the healthcare savings account, the dependent care account, or the transport account to the destination purse. (see para. 17).
Regarding Claim 29, Pletz discloses a system comprising the one or more processors to use a policy (rules or programming) to select the at least one of the flexible spending account, the healthcare savings account, the dependent care account, or the transport account from which to transfer the reimbursement amount to the destination purse. (see Claim 1).
Regarding Claim 30, Pletz discloses a system comprising the one or more processors to: select the at least one of the flexible spending account, the healthcare savings account, the dependent care account, or the transport account, from which to transfer the reimbursement amount to the destination purse, based on a first category (eligible expense) associated with the first electronic transaction and the preconfigured mapping (linking) of the electronic account. (see para. 37-38, 43 and 67-70).
Regarding Claim 31, Pletz does not teach a system comprising the one or more processors to determine that a transaction amount of the first electronic transaction is greater than an amount of funds available in the first purse; and cause the transfer of the first amount from the first purse, wherein the first amount is less than the transaction amount of the first electronic transaction, wherein a remaining amount of the first electronic transaction is transferred from the destination purse to the entity, and the remaining amount is based at least in part on a difference between the transaction amount and the first amount.
Pourfallah discloses a system comprising the one or more processors to:
determine that a transaction amount of the first electronic transaction ($100) is greater than an amount of funds ($75) available in the first purse (FSA account). (see fig. 5F; para. 150); and
cause the transfer of the first amount ($75) from the first purse (FSA account), wherein the first amount is less than the transaction amount ($100) of the first electronic transaction, wherein a remaining amount ($25) of the first electronic transaction is transferred from the destination purse (LOC) to the entity, and the remaining amount ($25) is based at least in part on a difference between the transaction amount ($100) and the first amount ($75). (see fig. 5F; para. 150).
It would have been obvious to one of ordinary skill in the art at the effective filing date of the invention to have modified Pletz and Pourfallah by incorporating the ability to split payments across multiple accounts/purses, as disclosed by Pourfallah, to account for an account/purse having insufficient funds.
Regarding Claim 32, Pletz discloses a method comprising the one or more processors to determine the reimbursement amount based at least in part on the remaining amount. (see abstract).
Regarding Claims 33-46, such claims recite substantially similar limitations as claimed in previously rejected claims and, therefore, would have been obvious based upon previously rejected claims or are otherwise disclosed by the prior art applied in previously rejected claims.
6. Response to Arguments
Applicant's arguments filed 12/26/2025 have been fully considered but they are not persuasive.
§101 Rejection
Step 2A Prong Two
Applicant argues that the claimed invention recites a practical application, specifically “an improvement in the functioning of a computer, or an improvement to other technology or technical field,” and, as such, satisfies Step 2A Prong Two of the §101 Guidelines. See Arguments, pp. 15-17.
Specifically, Applicant argues:
Indeed, the Specification describes a technical solution to the problem of efficiently managing and automating multi-purse electronic transactions, including real-time reimbursement and notification, across different merchant categories and account restrictions. (See, e.g., Specification, pages 2, 3, 5, 21-22, and 27-28). To do so, the technology provides:
automated, real-time crediting of a reimbursement purse on a multi-purse card when a claim is approved, allowing for immediate, unrestricted use of reimbursed
funds (See, e.g., Specification, pages 2, 21, 22, and 29);
policy-driven selection of purses based on merchant category codes (MCCs), transaction types, and configurable rules, ensuring compatibility with electronic
account constraints (See, e.g., Specification, pages 2, 21, 22, and 26-28); and
real-time notifications to users via electronic messaging, improving transparency and user experience (See, e.g., Specification, pages 2, 21, 22, 30, and 31). See Arguments, p. 15 – emphasis added.
The Examiner respectfully disagrees.
In DDR Holdings, LLC v. Hotels.com, the U.S. Court of Appeals stated:
As an initial matter, it is true that the claims here are similar to the claims in the cases discussed above in the sense that the claims involve both a computer and the Internet. But these claims stand apart because they do not merely recite the performance of some business practice known from the pre-Internet world along with the requirement to perform it on the Internet. Instead, the claimed solution is necessarily rooted in computer technology in order to overcome a problem specifically arising in the realm of computer networks. See DDR Holdings, LLC v. Hotels.com, 113 USPQ2d 1097, 1106 (Fed. Cir. 2014) – emphasis added.
In the instant case, the problem that the claimed invention is designed to overcome, efficiently managing and multi-purse transactions, is not a problem specifically arising from the realm of computers. This problem is a standard business problem that exists outside the realm of computers and existed before the age of computers.
The claimed invention does provide “a technical solution to the problem of efficiently managing and automating multi-purse electronic transactions” in that the claimed invention utilizes technology to efficiently manage and automate multi-purse electronic transactions.
However, the specification does not provide any evidence that there is even a technology-based problem to be solved. For example, the specification does not provide any evidence that existing technology was not capable of performing the claimed functions but for the claimed technical solution.
The Examiner is not disputing the benefits to be derived from claimed invention (e.g., real-time notifications improving transparency and user experience). The Examiner is merely asserting that there is no technological problem (e.g., existing technology was incapable of transmitting real-time notifications) to be solved.
Examiner asserts that the claimed invention is analogous to Electric Power Group LLC v. Alstom SA (Fed. Cir. 2016), wherein the court stated:
The claims here are unlike the claims in Enfish. There, we relied on the distinction made in Alice between, on one hand, computer-functionality improvements and, on the other, uses of existing computers as tools in aid of processes focused on “abstract ideas” (in Alice, as in so many other § 101 cases, the abstract ideas being the creation and manipulation of legal obligations such as contracts involved in fundamental economic practices). Enfish, 822 F.3d at 1335-36; see Alice, 134 S. Ct. at 2358-59. That distinction, the Supreme Court recognized, has common-sense force even if it may present line-drawing challenges because of the programmable nature of ordinary existing computers. In Enfish, we applied the distinction to reject the § 101 challenge at stage one because the claims at issue 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, 2016 U.S. App. LEXIS 11687, 2016 WL 3514158, at *5; cf. Alice, 134 S. Ct. at 2360 (noting basic storage function of generic computer). The present 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. see Electric Power Group LLC v. Alstom SA, 119 USPQ2d 1739, 1742 (Fed. Cir. 2016) – emphasis added.
The claimed invention is not an improvement to computer technology or computer functionality. Rather, the claimed invention is applying a computer’s existing capabilities to implement a particular abstract idea. As in Electric Power Group, the focus of the claimed invention is not on an improvement in computers as tools but on improving an abstract idea (i.e., efficiently managing and automating multi-purse electronic transactions) that uses computers as tools.
Applicant argues that the claimed invention is analogous to Example 34: System for Filtering Internet Content. See Arguments, p. 34.
As a preliminary matter, the Examiner notes that Office Examples are meant to be for training purposes and do not have the force of legal precedent.
Further, claim 1 of Example 1 was found to integrate the abstract idea into a practical application because:
Further, these limitations confine the abstract idea to a particular, practical application of the abstract idea and, as explained in the specification, this combination of limitations is not well‐ understood, routine or conventional activity. Unlike the claimed system, previous content filtering systems were able to be modified by end users when the systems were located on local client computers rather than on the ISP server and were dependent on hardware and software on the local computer, or limited to a configuration based on the particular local client computer, local server, or ISP server. In addition, these limitations do not simply recite an instruction to apply the abstract idea of filtering content on the Internet or to perform the abstract idea on a generic set of computers. Instead, the claim recites a “technology‐based solution” of filtering content on the Internet that overcomes the disadvantages of prior art filtering systems. Thus, when viewed as an ordered combination, the claim limitations amount to significantly more than the abstract idea of content filtering (Step 2B: Yes). The claim is patent eligible. See Subject Matter Eligibility Examples: Business Methods, December 2016, p. 4.
Example 34 was deemed an improvement as its specification provided sufficient details to establish that the invention was providing an improvement. The specification established the technological problem (i.e., end users circumventing local-based filtering controls) and the technological solution (i.e., remote-based filtering control), as in DDR Holdings, LLC v. Hotels.com (Fed. Cir. 2014).
In the instant case, the specification does not provide any evidence that there is a technology-based problem to be solved nor that the claimed invention has presented a technology-based solution to a technology-based problem. The problem that the claimed invention is designed to overcome, efficiently managing and automating multi-purse transactions, is not a problem specifically arising from the realm of computers. This problem is a standard business problem that exists outside the realm of computers and existed before the age of computers.
Step 2B
Applicant argues that the additional elements amount to “significantly more” than the abstract idea and, as such, satisfies Step 2B of the §101 Guidelines. See Arguments, p. 17.
The Examiner respectfully disagrees.
The claim(s) do not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Upon reconsideration of the indicia noted under Step 2A in concert with the Step 2B considerations, the additional claim element(s) amounts to no more than mere instructions to apply the exception using generic computer components. The same analysis applies in Step 2B, i.e., mere instructions to apply an exception using a generic computer component cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. The claim does not provide an inventive concept significantly more than the abstract idea.
Accordingly, these additional elements, when considered separately and as an ordered combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
MPEP §2106.04(d) recites:
The courts have also identified limitations that did not integrate a judicial exception into a practical application:
Merely reciting the words “apply it” (or an equivalent) with the judicial exception, or merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea, as discussed in MPEP § 2106.05(f); [and]
Generally linking the use of a judicial exception to a particular technological environment or field of use, as discussed in MPEP § 2106.05(h).
Examiner asserts that the additional elements amount to merely (1) including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea, or alternatively, (2) merely links the use of a judicial exception to a particular technological environment or field of use.
§103 Rejection
Applicant argues that the previously asserted prior art (Pletz and Pourfallah) does not teach or suggest the newly amended claim language. See Arguments, pp. 18-22.
The §103 Rejection has been rewritten and the prior art remapped to account for the newly amended claim language.
Examiner also directs the Applicant’s attention to the Claim Interpretation section which directly addresses the newly amended claim language.
7. 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 JASON M BORLINGHAUS whose telephone number is (571)272-6924. The examiner can normally be reached M-F 9-5.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Calvin L Hewitt II can be reached on 571-272-6709. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/Jason M. Borlinghaus/Primary Examiner, Art Unit 3692 May 11, 2026
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