DETAILED ACTION
This office action is in response to communication filed on 14 April 2026.
Claims 1 – 20 are presented for examination.
The following is a FINAL office action upon examination of application number 18/188857. Claims 1 – 20 are pending in the application and have been examined on the merits discussed below.
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 .
Response to Amendment
In the response filed 14 April 2026, Applicant amended claims 1, 10, and 19.
Amendments to claims 1, 10, and 19 are insufficient to overcome the 35 USC § 101 rejection. Therefore, the 35 USC § 101 rejection of claims 1 – 20 are maintained.
Response to Arguments
Applicant's arguments filed 14 April 2026 have been fully considered but they are not persuasive.
In the remarks regarding the 35 USC 101 rejection of claims 1 – 20, Applicant argues that any abstract ideas claimed are integrated into a practical application. Examiner respectfully disagrees. Claim 1 can be performed with human mind or with pen and paper, as steps such as retraining a model, absent further description in claims, could be merely updating the databases from which models use as their parameters to apply to their algorithm. Accounts receivable and other accounting data has long been calculated before technology was applied, and the instant claims similarly do not require technology. There is no integration into an abstract idea, because classification models used to predict payment behavior is a business problem, not a technical problem. While late payments to a business are a problem, it is not a technology problem. As this is not a technical problem requiring technology, there is no claim to a specific technological process. Improvement to a model is not an improvement to a computer. The steps claimed amount to providing new parameters without any change the model itself, which is not significantly more. While the determination of daily cash position for the future may be an improvement in the business field of finance, this is not an improvement to a technical field or technology, nor is there a requirement for technology to perform calculations and make predictions for cash positions. This is merely an “apply it” situation, where computer implementation is not necessary to carry out the steps. The 35 USC 101 rejection is proper and maintained.
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 the judicial exception of abstract ideas without significantly more. The independent claims recite receiving first accounts receivable data comprising an indication that a first account receivable was paid as of the first point in time, extracting updated training data for an accounts receivable model which is a classification model that generates an output indicating whether an input account receivable will be paid or unpaid at an input future time period, updated training data comprises first training data based on first account receivable indicated by the first accounts receivable data as being paid, the first training data item describing an open date on which the first account receivable was opened and a fulfillment date on which the first account receivable was paid; and a second training data item based on a second account receivable indicated by the first accounts receivable data as being unpaid, the second training data item describing an open date on which the second account receivable was opened, retraining accounts receivable model using updated training data, after retraining accounts receivable model, executing the accounts receivable model for a plurality of accounts receivable described by the first accounts receivable data and a plurality of future time periods to determine states of respective accounts receivable of the plurality of accounts receivable over the respective plurality of future time periods; determining respective cash input positions for a plurality of future time periods using first accounts payable data, determining respective net positions for the plurality of future time periods using the respective cash input and output positions, a net position for a first time period being positive and a net position for a second time period being positive, determining a first positive tranche comprising a portion of the net position for the first and second time periods, and sending a first purchase instruction to an investment system that requests purchase of a security. This judicial exception is not integrated into a practical application. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. The eligibility analysis in support of these findings is provided below, in accordance section 2106 of the MPEP (hereinafter, MPEP 2106).
With respect to Step 1 of the eligibility inquiry (as explained in MPEP 2106), it is noted that the system, the method, and the machine readable medium are directed to an eligible categories of subject matter. Step 1 is satisfied.
With respect to Step 2A prong 1 of MPEP 2106, it is next noted that the claims recite an abstract idea by reciting concepts of fundamental economic principles or practices such as cash flow and securities purchases, which falls into the “certain methods of organizing human activity” group within the enumerated groupings of abstract ideas set forth in the MPEP 2106. The claimed invention also recites an abstract idea that falls within the mental processes grouping, as there are determining steps throughout. Additionally, the mathematical model being trained with new data is in the abstract idea grouping of mathematical concepts. The limitations reciting the abstract ideas in independent claims are receiving first accounts receivable data comprising an indication that a first account receivable was paid as of the first point in time, extracting updated training data for an accounts receivable model which is a classification model that generates an output indicating whether an input account receivable will be paid or unpaid at an input future time period, updated training data comprises first training data based on first account receivable indicated by the first accounts receivable data as being paid, the first training data item describing an open date on which the first account receivable was opened and a fulfillment date on which the first account receivable was paid; and a second training data item based on a second account receivable indicated by the first accounts receivable data as being unpaid, the second training data item describing an open date on which the second account receivable was opened, retraining accounts receivable model using updated training data, after retraining accounts receivable model, executing the accounts receivable model for a plurality of accounts receivable described by the first accounts receivable data and a plurality of future time periods to determine states of respective accounts receivable of the plurality of accounts receivable over the respective plurality of future time periods; determining respective cash input positions for a plurality of future time periods using first accounts payable data, determining respective net positions for the plurality of future time periods using the respective cash input and output positions, a net position for a first time period being positive and a net position for a second time period being positive, determining a first positive tranche comprising a portion of the net position for the first and second time periods, and sending a first purchase instruction to an investment system that requests purchase of a security.
With respect to Step 2A Prong Two of the MPEP 2106, the judicial exception is not integrated into a practical application. The additional elements are directed to a computing system, processor, and machine-readable medium, to implement the abstract idea. However, these elements fail to integrate the abstract idea into a practical application because they are directed to the use of generic computing elements to perform the abstract idea, which is not sufficient to amount to a practical application (as noted in the MPEP 2106) and is tantamount to simply saying “apply it” using a general purpose computer, which merely serves to tie the abstract idea to a particular technological environment by using the computer as a tool to perform the abstract idea, which is not sufficient to amount to particular application.
Accordingly, because the Step 2A Prong One and Prong Two analysis resulted in the conclusion that the claims are directed to an abstract idea, additional analysis under Step 2B of the eligibility inquiry must be conducted in order to determine whether any claim element or combination of elements amount to significantly more than the judicial exception.
With respect to Step 2B of the eligibility inquiry, it has been determined that the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. The additional limitations are directed to: a computing system, processor, and machine-readable medium. These elements have been considered, but merely serve to tie the invention to a particular operating environment, though at a very high level of generality and without imposing meaningful limitation on the scope of the claim. This does not amount to significantly more than the abstract idea, and it is not enough to transform an abstract idea into eligible subject matter. Such generic, high-level, and nominal involvement of a computer or computer-based elements for carrying out the invention merely serves to tie the abstract idea to a particular technological environment, which is not enough to render the claims patent-eligible, as noted at pg. 74624 of Federal Register/Vol. 79, No. 241, citing Alice, which in turn cites Mayo. This is further evidenced by the fact that the method claims do not positively recite any technology at all.
In addition, when taken as an ordered combination, the ordered combination adds nothing that is not already present as when the elements are taken individually. There is no indication that the combination of elements integrates the abstract idea into a practical application. Their collective functions merely provide conventional computer implementation. Therefore, when viewed as a whole, these additional claim elements do not provide meaningful limitations to transform the abstract idea into a practical application of the abstract idea or that the ordered combination amounts to significantly more than the abstract idea itself.
The dependent claims have been fully considered as well, however, similar to the finding for claims above, these claims are similarly directed to the abstract idea of concepts of further determinations and sending of purchase instructions, by way of example, without integrating it into a practical application and with, at most, a general purpose computer that serves to tie the idea to a particular technological environment, which does not add significantly more to the claims. The ordered combination of elements in the dependent claims (including the limitations inherited from the parent claim(s)) add nothing that is not already present as when the elements are taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. Their collective functions merely provide conventional computer implementation. Accordingly, the subject matter encompassed by the dependent claims fails to amount to significantly more than the abstract idea.
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 AMANDA GURSKI whose telephone number is (571)270-5961. The examiner can normally be reached Monday to Thursday 7am to 5pm EST.
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/AMANDA GURSKI/Primary Examiner, Art Unit 3625
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