DETAILED ACTION
This office action is in response to communication filed on 19 December 2025.
Claims 1 – 20 are presented for examination.
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 .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 19 December 2025 has been entered.
Response to Amendment
In the response filed 19 December 2025, 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 19 December 2025 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. Applicant argues that Example 39 from the July 2024 USPTO 101 guidance is comparable to their claim as Example 39 training a neural network for facial detection. The manner of training in this example involves transformation applied to digital facial images that modify those original images. Applicant’s claims only describe extracting training data from an accounts receivable model (mathematical) and using that data to train and retrain a model. This is equivalent 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 comprising determining a plurality of training data items from the first accounts receivable data, each respective data item describing an open date on which an account receivable was opened, an amount of the account receivable, a counter part of the account receivable, and a fulfillment date on which the account receivable was fulfilled, retraining accounts receivable model using updated training data, retraining comprises executing the accounts receivable model using first training data item to generate a predicted fulfillment date, comparing the predicted fulfilment date to one indicated by the first training data item, and retraining the accounts receivable model at least in part by modifying the accounts receivable model, executing the accounts receivable model after retraining the accounts 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, receiving first accounts payable data describing accounts payable at the first point in time, 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 comprising determining a plurality of training data items from the first accounts receivable data, each respective data item describing an open date on which an account receivable was opened, an amount of the account receivable, a counter part of the account receivable, and a fulfillment date on which the account receivable was fulfilled, retraining accounts receivable model using updated training data, retraining comprises executing the accounts receivable model using first training data item to generate a predicted fulfillment date, comparing the predicted fulfilment date to one indicated by the first training data item, and retraining the accounts receivable model at least in part by modifying the accounts receivable model, executing the accounts receivable model after retraining the accounts 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, receiving first accounts payable data describing accounts payable at the first point in time, 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
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/AMANDA GURSKI/Primary Examiner, Art Unit 3625