Prosecution Insights
Last updated: May 29, 2026
Application No. 18/198,125

TOKENIZED ASSET EXCHANGE

Final Rejection §101
Filed
May 16, 2023
Examiner
SUBRAMANIAN, NARAYANSWAMY
Art Unit
3691
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Wells Fargo Bank N A
OA Round
4 (Final)
29%
Grant Probability
At Risk
5-6
OA Rounds
11m
Est. Remaining
60%
With Interview

Examiner Intelligence

Grants only 29% of cases
29%
Career Allowance Rate
153 granted / 533 resolved
-23.3% vs TC avg
Strong +31% interview lift
Without
With
+31.0%
Interview Lift
resolved cases with interview
Typical timeline
4y 0m
Avg Prosecution
22 currently pending
Career history
567
Total Applications
across all art units

Statute-Specific Performance

§101
54.3%
+14.3% vs TC avg
§103
34.6%
-5.4% vs TC avg
§102
2.8%
-37.2% vs TC avg
§112
4.1%
-35.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 533 resolved cases

Office Action

§101
DETAILED ACTION 1. 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 filed on February 19, 2026. Amendments to claim 6 have been entered. Claims 6, 7, and 10-15 are pending and have been examined. The statement of reasons for the indication of allowable subject matter (over prior art) was already stated in the Office action mailed on May 15, 2025 and hence not repeated here. The rejections and response to arguments are stated below. Claim Rejections - 35 USC § 101 2. 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. 3. Claims 6, 7, and 10-15 are rejected under 35 U.S.C. § 101 because the claimed invention is directed to an abstract idea without significantly more. The claim(s) recite(s) a system for receiving a loan tokenization request corresponding to a loan; in response to receiving the loan tokenization request, generating a loan token by tokenizing the loan; and transferring the loan token to the first digital wallet, which is considered a judicial exception because it falls under the category of “Certain Methods of organizing human activity” such as fundamental economic practice as well as commercial or legal interactions including agreements as discussed below. This judicial exception is not integrated into a practical application as discussed below. The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception as discussed below. Analysis Step 1: In the instant case, exemplary claim 6 is directed to a system. Step 2A – Prong One: The limitations of “A system comprising a data processing system, the data processing system comprising memory and one or more processors configured to: receive, from a first computing system, a commitment request corresponding to first funds and an agreement; in response to receiving the commitment request, generate first tokens by tokenizing the first funds and generate an agreement token by tokenizing the agreement, tokenizing the first funds comprises: generate a funds metadata object comprising metadata of the first funds and at least one key associated with the funds metadata object; and generate a funds metadata object comprising metadata of the first funds and at least one public-private key pair associated with the funds metadata object, the public key derived from the private key and configured to verify access to the first tokens, the private key configured to decrypt the first tokens, wherein the funds metadata comprises at least one of video, a code, audio, text, any media or digital representation, or executable programs; and generate, based on the funds metadata object, the first tokens comprising a link to the funds metadata object: and tokenizing the agreement comprises: generate an agreement metadata object comprising metadata of the agreement and one or more attributes to define a transfer of the first tokens associated with the agreement, and generate, based on the agreement metadata object, the agreement token comprising a link to the agreement metadata object and one or more restrictions for the transfer of the first tokens based on the one or more attributes; verify a second digital wallet using the public key, the public key operable to resolve the one or more restrictions for the transfer of the first tokens to improve security of an exchange of the first tokens and the agreement token; decrypt the first tokens and the agreement token using the private key that is associated with the public key in the public-private key pair, in response to verifying the second digital wallet; transmit the decrypted first tokens to a first digital wallet; transmit the decrypted agreement token to the second digital wallet associated with the first computing system; receive a loan tokenization request corresponding to a loan that is based on the transmitted first tokens and the agreement token; in response to receiving the loan tokenization request, generate a loan token by tokenizing the loan; and transfer the loan token to the first digital wallet” as drafted, when considered collectively as an ordered combination without the italicized portions, is a process that, under the broadest reasonable interpretation, covers the category of “Certain Methods of organizing human activity” such as fundamental economic practice as well as commercial or legal interactions including agreements. The steps of “generating a loan token by tokenizing the loan; and transferring the loan token to the first digital wallet” is a fundamental economic practice such as generating a loan. The steps of “receive, from a first computing system, a commitment request corresponding to first funds and an agreement; ……. in response to receiving the loan tokenization request, generate a loan token by tokenizing the loan; and transfer the loan token to the first digital wallet” considered collectively is a form of fulfilling agreements. Hence, the steps of the claim, considered collectively as an ordered combination without the italicized portions, covers the abstract category of “Certain Methods of organizing human activity”. That is, other than, a data processing system comprising memory and one or more processors, a first computing system, public-private key pair, private key, a public key, funds metadata objects wherein the funds metadata comprises at least one of video, a code, audio, text, any media or digital representation, or executable programs; agreement meta objects, funds tokens, loan tokens, first tokens including links, encryption and decryption, a first digital wallet and a second digital wallet nothing in the claim precludes the steps from being performed as a method of organizing human activity. If the claim limitations, under the broadest reasonable interpretation, covers methods of organizing human activity 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: The judicial exception is not integrated into a practical application. In particular, the claim only recites the additional elements of a data processing system comprising memory and one or more processors, a first computing system, public-private key pair, private key, a public key, funds metadata objects wherein the funds metadata comprises at least one of video, a code, audio, text, any media or digital representation, or executable programs; agreement meta objects, funds tokens, loan tokens, first tokens including links, encryption and decryption, a first digital wallet and a second digital wallet to perform all the steps. A plain reading of Figures 1-4 and descriptions in at least paragraphs [0020] – [0035] reveals that the one or more processors may be generic processors suitably programmed to perform the associated functions. The memory, the first computing system with associated digital wallets, public-private key pair, private key, a public key, funds metadata objects including a code, audio, text, any media or digital representation, or executable programs, and the tokens including links are broadly interpreted to correspond to generic computer components suitably programmed to perform the associated functions. Similarly, the other tokens such as funds tokens, loan tokens, agreement tokens are broadly interpreted to correspond to generic computer components suitably programmed to perform the associated functions. The first digital wallet and a second digital wallet, encryption and decryption are broadly interpreted to correspond to generic computer components suitably programmed to perform the associated functions. Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. The additional elements in all the steps are recited at a high-level of generality (i.e., as generic computer components performing generic computer functions) such that it amounts no more than mere instructions to apply the exception using generic computer components. 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. Hence, claim 6 is directed to an abstract idea. Step 2B: The claim does 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, using the additional elements (identified above) to perform the claimed steps amounts to no more than mere instructions to apply the exception using a generic computer component. The additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Hence, independent claim 6 is not patent eligible. Dependent claims 7, and 10-15, when analyzed as a whole are held to be patent ineligible under 35 U.S.C. 101 because the additional recited limitations only refine the abstract idea further. For instance, in claim 7, the step “wherein the one or more processors are further configured to, in response to receiving a conversion request associated with the first tokens, convert the first tokens into fiat funds and transfer the fiat funds into a funds account associated with the one or more processors” under the broadest reasonable interpretation, is a further refinement of methods of organizing human activity because this step describes the intermediate steps of the underlying process. In claim 10, the steps “wherein the one or more processors are further configured to: generate, based on servicing tape loan data associated with the loan, a data report comprising loan yield; and tokenize the servicing tape loan data” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps further describe the intermediate steps of the underlying process. In claim 11, the steps “wherein the one or more processors are further configured to: receive second funds based on the loan yield; generate second tokens by tokenizing the second funds; and transfer the second tokens to the second digital wallet” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps further describe the intermediate steps of the underlying process. In claim 12, the steps “wherein the one or more processors are further configured to, in response to receiving a conversion request associated with the second tokens, convert the second tokens into fiat funds and transfer the fiat funds into a first funds account” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps further describe the intermediate steps of the underlying process. In claim 13, the steps “wherein the one or more processors are further configured to: receive a payment indication associated with third funds; in response to receiving the payment indication, generate third tokens by tokenizing the third funds; transfer the third tokens to the first digital wallet; determine, based on the servicing tape loan data and the third funds, whether the loan is paid off; and in response to determining that the loan is paid off, burn the loan token” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps further describe the intermediate steps of the underlying process. In claim 14, the step “wherein burning the loan token comprises transmitting the loan token to an un-spendable address of a digital wallet” under the broadest reasonable interpretation, is a further refinement of methods of organizing human activity because this step further describes the intermediate steps of the underlying process. In claim 15, the steps “wherein the one or more processors are further configured to, in response to receiving a conversion request associated with the third tokens, convert the third tokens into fiat funds and transfer the fiat funds into a funds account associated with the one or more processors” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps further describe the intermediate steps of the underlying process. In all the dependent claims, the judicial exception is not integrated into a practical application because the limitations are recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using generic computer components. Also, the claims do not affect an improvement to another technology or technical field; the claims do not amount to an improvement to the functioning of a computer system itself; the claims do not affect a transformation or reduction of a particular article to a different state or thing; and the claims do not move beyond a general link of the use of an abstract idea to a particular technological environment. In addition, the dependent claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. The additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. The claims as a whole, do not amount to significantly more than the abstract idea itself. For these reasons, the dependent claims also are not patent eligible. Response to Arguments 4. In response to Applicants arguments on pages 5-10 of the Applicant’s remarks that the claims are patent-eligible under 35 USC 101 when considered under MPEP 2106, the Examiner respectfully disagrees. The fact that the claims are Patent-Ineligible when considered under the MPEP 2106 has already been addressed in the rejection and hence not all the details of the rejection are repeated here. Response to Applicants’ arguments regarding Step 2A – Prong one: The claim(s) recite(s) a system for a system for receiving a loan tokenization request corresponding to a loan; in response to receiving the loan tokenization request, generating a loan token by tokenizing the loan; and transferring the loan token to the first digital wallet, which is considered a judicial exception because it falls under the category of “Certain Methods of organizing human activity” such as fundamental economic practice as well as commercial or legal interactions including agreements as discussed, which is considered a judicial exception because it falls under the category of “Certain Methods of organizing human activity” such as fundamental economic practice as well as commercial or legal interactions including agreements as discussed in the rejection. The additional elements recited in the claim are suitably programmed computer components that are used as tools, in their ordinary capacity, to apply the abstract idea. The fact that the steps are performed in a digital environment do not make them any less abstract. Hence, the claims recite an abstract idea. The claimed limitations including “a computing system that generates metadata objects based on deposited funds and a specified agreement, verifies a mobile wallet by using public keys to establish access to the tokens, and decrypts the tokens by using public keys of the mobile wallet to form a private key that can decrypt the tokens on behalf of the user of the mobile wallet. As amended, the claims recite a specific, computer system for securely accessing tokens associated with a different mobile wallet within a blockchain network” may be characterized as an improvement in the abstract idea of “receiving a loan tokenization request corresponding to a loan; in response to receiving the loan tokenization request, generating a loan token by tokenizing the loan; and transferring the loan token to the first digital wallet”, using the additional elements as tools in their ordinary capacity to apply the abstract idea. The Examiner does not see the parallel between the applicant’s claims and those cases cited on page 7 of the remarks, including Example 47 and Example 39 SME examples. Therefore, the Applicant’s arguments are not persuasive. Response to Applicants’ arguments regarding Step 2A - Prong two and Step 2B: According to MPEP 2106, limitations that are indicative of integration into a practical application include: Improvements to the functioning of a computer, or to any other technology or technical field - see MPEP 2106.05(a) Applying or using a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition Applying the judicial exception with, or by use of, a particular machine - see MPEP 2106.05(b) Effecting a transformation or reduction of a particular article to a different state or thing - see MPEP 2106.05(c) Applying or using the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception - see MPEP 2106.05(e). In the instant case, the judicial exception is not integrated into a practical application, because none of the above criteria is met. The claim (exemplary claim 6) only recites the additional elements of a data processing system comprising memory and one or more processors, a first computing system, public-private key pair, private key, a public key, funds metadata objects wherein the funds metadata comprises at least one of video, a code, audio, text, any media or digital representation, or executable programs; agreement meta objects, funds tokens, loan tokens, first tokens including links, encryption and decryption, a first digital wallet and a second digital wallet to perform all the steps. A plain reading of Figures 1-4 and descriptions in at least paragraphs [0020] – [0035] reveals that the one or more processors may be generic processors suitably programmed to perform the associated functions. The memory, the first computing system with associated digital wallets, public-private key pair, private key, a public key, funds metadata objects including a code, audio, text, any media or digital representation, or executable programs, and the tokens including links are broadly interpreted to correspond to generic computer components suitably programmed to perform the associated functions. Similarly, the other tokens such as funds tokens, loan tokens, agreement tokens are broadly interpreted to correspond to generic computer components suitably programmed to perform the associated functions. The first digital wallet and a second digital wallet, encryption and decryption are broadly interpreted to correspond to generic computer components suitably programmed to perform the associated functions. Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. The additional elements in all the steps are recited at a high-level of generality (i.e., as generic computer components performing generic computer functions) such that it amounts no more than mere instructions to apply the exception using generic computer components. 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. Tokenizing the funds and the agreement separately is a business decision, using computer components as tools in their normal capacity, to a problem rooted in an abstract idea. Also contrary to Applicant’s assertion that the Office action oversimplifies the subject matter claimed by describing the claims at a high level of abstraction and untethered from the language of the claims, the Examiner would like to point out that all limitations of all claims have been fully considered (in the rejections). Abstract ideas can be characterized at different levels of abstraction. (See Apple, Inc. v. Ameranth, Inc., 842 F.3d 1229, 1240-41 (Fed. Cir. 2016) (“An abstract idea can generally be described at different levels of abstraction.”)). The alleged advantages such as “avoiding/reducing wasted computing resources and security vulnerabilities through the exchange or transfer of tokens (e.g., funds) ….. receiving a deposit of tokens from a client system …. preventing [an] output of the restricted tokens... permitting access to the restricted tokens based on a private key ….. decrypting the token using the public key to verify the digital signature came from the particular private key” are due to improvements in the abstract idea using the additional elements as tools in their ordinary capacity. An improvement in abstract idea is still abstract. It does not involve any improvements to another technology, technical field, or improvements to the functioning of the computer itself. The claimed features including those recited on pages 8-9 of the remarks such as “generating, based on the agreement metadata object, the agreement token comprising a link to the agreement metadata object and one or more restrictions for the transfer of the first tokens based on the one or more attributes ….. verifying a second digital wallet using the public key, the public key operable to resolve the one or more restrictions for the transfer of the first tokens to improve security of an exchange of the first tokens and the agreement token ….. decrypting the first tokens and the agreement token using the private key that is associated with the public key in the public-private key pair, in response to verifying the second digital wallet ……. transmitting the decrypted first tokens and the decrypted agreement token” may, at best, be characterized as an improvement in the abstract idea of “receiving a loan tokenization request corresponding to a loan; in response to receiving the loan tokenization request, generating a loan token by tokenizing the loan; and transferring the loan token to the first digital wallet”, using the additional elements as tools in their ordinary capacity to apply the abstract idea. The additional elements (identified in the claim) are suitably programmed generic computer components used to apply the abstract idea. An improvement in abstract idea is still abstract (SAP America v. Investpic *2-3 (“We may assume that the techniques claimed are “groundbreaking, innovative, or even brilliant,” but that is not enough for eligibility. Association for Molecular Pathology v. Myriad Genetics, Inc., 569 U.S. 576, 591 (2013); accord buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1352 (Fed. Cir. 2014). Nor is it enough for subject-matter eligibility that claimed techniques be novel and nonobvious in light of prior art, passing muster under 35 U.S.C. §§ 102 and 103. See Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66, 89–90 (2012); Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 1151 (Fed. Cir. 2016) (“A claim for a new abstract idea is still an abstract idea). The additional elements (identified in the rejection) are suitably programmed generic computer components used to apply the abstract idea. As discussed in the rejection, the additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Therefore, the Applicant’s arguments are not persuasive. For these reasons and those discussed in the rejection, the rejections under 35 USC § 101 are maintained. Conclusion 5. The prior art made of record and not relied upon is considered pertinent to applicant's disclosure: (a) Gu; Huawei et al. (US Pub. 2024/0412181 A1) discloses techniques and apparatus for efficiently processing transactions on a blockchain. An example method generally includes receiving, at a relay service, a request to execute a transaction on a blockchain. Generally, the request includes a request to transfer a quantity of a first type of token on the blockchain from a transmitter wallet to a receiver wallet identified in the request and incurs a transaction overhead on the blockchain in a second type of token. The request is modified based on the quantity of the first type of token, the transaction overhead in the second type of token, and a policy defining a source from which the transaction overhead is to be retrieved. The transaction is executed on the blockchain based on the modified request without transferring the second type of token from the transmitter wallet to satisfy the transaction overhead. 6. Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). 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 extension fee 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 date of this final action. Any inquiry concerning this communication or earlier communications from the Examiner should be directed to Narayanswamy Subramanian whose telephone number is (571) 272-6751. The examiner can normally be reached Monday-Friday from 9:00 AM to 5:00 PM. If attempts to reach the examiner by telephone are unsuccessful, the examiner's supervisor, Abhishek Vyas can be reached at (571) 270-1836. The fax number for Formal or Official faxes and Draft to the Patent Office 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. /Narayanswamy Subramanian/ Primary Examiner Art Unit 3691 March 29, 2026
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Prosecution Timeline

Show 8 earlier events
Nov 03, 2025
Request for Continued Examination
Nov 09, 2025
Response after Non-Final Action
Nov 26, 2025
Non-Final Rejection mailed — §101
Jan 12, 2026
Interview Requested
Feb 12, 2026
Examiner Interview Summary
Feb 12, 2026
Applicant Interview (Telephonic)
Feb 19, 2026
Response Filed
Apr 01, 2026
Final Rejection mailed — §101 (current)

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Prosecution Projections

5-6
Expected OA Rounds
29%
Grant Probability
60%
With Interview (+31.0%)
4y 0m (~11m remaining)
Median Time to Grant
High
PTA Risk
Based on 533 resolved cases by this examiner. Grant probability derived from career allowance rate.

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