DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, 18/200,549, filed 05/22/2023 is a Continuation of 13/859,841, filed 04/10/2013, which claims priority from US Provisional Application 61/622,490, filed 04/10/2012.
The effective filing date is after the AIA date of March 16, 2013, and so the application is being examined under the “first inventor to file” provisions of the AIA .
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
Status of the Application
This Final Office Action is in response to Applicant’s Amendment filed on 05/26/2026.
Claims 21, 22, 28, 29, 35, 43, 46, and 49-61 are pending, of which claims 21, 28, and 35 are independent.
In the most recent amendment, no claims have been amended, cancelled, or newly added.
All pending claims have been examined on the merits.
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 21, 22, 28, 29, 35, 43, 46, and 49-61 are rejected under 35 U.S.C. §101 because the claimed invention is directed to non-statutory subject matter. The claimed invention is directed to an abstract idea, without “significantly more”.
The abstract idea elements in independent claim 21 are shown in regular font. The “additional elements” are shown in underlined font:
21. (Currently Amended) A system, comprising:
a computing device comprising a processor and a memory; and
machine-readable instructions stored in the memory that, when executed by the processor, cause the computing device to at least:
receive a transfer request comprising instructions to effectuate an immediate electronic wire transfer from a sending account held by a first holder to a receiving account held by a second holder as an immediate electronic intrabank wire transfer, the sending account being hosted by a first server of a first financial institution and the receiving account being hosted by a second server of a second financial institution;
search a database of proxy accounts that are associated with a plurality of financial institution servers to identify a proxy account that is hosted by the second server;
process an intermediary transfer from the sending account to the proxy account; and
initiate an immediate electronic intrabank wire transfer from the proxy account to the receiving account.
More specifically, claims 21, 22, 28, 29, 35, 43, 46, and 49-61 recite an abstract idea: “Certain Methods of Organizing Human Activity", specifically “Commercial or Legal Interactions (Including Agreements in the form of Contracts; Legal Obligations; Advertising, Marketing, or Sales Activities or Behaviors; Business Relations)”, as discussed in MPEP §2106(a)(2) Parts (I) and (II), and in the 2019 Revised Patent Subject Matter Eligibility Guidance.
The “Commercial or Legal Interactions” elements include:
“the sending account being hosted by a first server of a first financial institution”.
“the receiving account being hosted by a second server of a second financial institution”.
“process an intermediary transfer from the sending account to the proxy account”.
The “additional elements” are: “a processor”, “a memory”, “a first server of a first financial institution”, and “a second server of a second financial institution”.
The additional “extra-solution activities” are:
“[machine-readable instructions] stored in the memory”.
“receive a transfer request comprising instructions to effectuate an immediate electronic wire transfer from a sending account held by a first holder to a receiving account held by a second holder as an immediate electronic intrabank wire transfer”.
“search a database of proxy accounts that are associated with a plurality of financial institution servers”.
“initiate an immediate electronic intrabank wire transfer from the proxy account to the receiving account”.
This abstract idea is not integrated into a practical application, because:
The claim recites an abstract idea with additional generic computer elements. The generically recited computer elements (“a processor”, “a memory”, “a first server of a first financial institution”, and “a second server of a second financial institution”) do not add a meaningful limitation to the abstract idea, because they amount to simply implementing the abstract idea on a computer. The claim amounts to adding the words "apply it" (or an equivalent) with the abstract idea, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea.
The extra-solution activities (“[machine-readable instructions] stored in the memory”, “receive a transfer request comprising instructions to effectuate an immediate electronic wire transfer from a sending account held by a first holder to a receiving account held by a second holder as an immediate electronic intrabank wire transfer”, “search a database of proxy accounts that are associated with a plurality of financial institution servers”, and “initiate an immediate electronic intrabank wire transfer from the proxy account to the receiving account”) do not add a meaningful limitation to the method, as they are insignificant extra-solution activity;
The combination of the abstract idea with the additional elements (generically recited computer elements), and/or with the extra-solution activities, does not integrate the abstract idea into a practical application.
The claims do not include additional elements that are sufficient to amount to significantly more than the abstract idea, because:
When considering the elements "alone and in combination" (“a processor”, “a memory”, “a first server of a first financial institution”, and “a second server of a second financial institution”), they do not add significantly more (also known as an "inventive concept") to the exception, because they amount to simply implementing the abstract idea on a computer. Instead, they merely add the words "apply it" (or an equivalent) with the abstract idea, or mere instructions to implement an abstract idea on a computer, or merely use a computer as a tool to perform an abstract idea.
In regards to the extra solution activities (“[machine-readable instructions] stored in the memory”, “receive a transfer request comprising instructions to effectuate an immediate electronic wire transfer from a sending account held by a first holder to a receiving account held by a second holder as an immediate electronic intrabank wire transfer”, “search a database of proxy accounts that are associated with a plurality of financial institution servers”, and “initiate an immediate electronic intrabank wire transfer from the proxy account to the receiving account”), are well-understood, routine, conventional computer functions recognized by the court decisions listed in MPEP § 2106.05(d)(II).
More specifically, in regards to the “receive” (“receive a transfer request comprising instructions to effectuate an immediate electronic wire transfer from a sending account held by a first holder to a receiving account held by a second holder as an immediate electronic intrabank wire transfer”) and “transmit” (“initiate an immediate electronic intrabank wire transfer from the proxy account to the receiving account”) steps, see the court cases OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1093 (Fed. Cir. 2015) (sending messages over a network) and (presenting offers and gathering statistics), OIP Techs., 788 F.3d at 1362-63, 115 USPQ2d at 1092-93; buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014) (computer receives and sends information over a network).
Moreover, in regards to the “[machine-readable instructions] stored in the memory” step (which is equivalent to a “storing” step), see the court cases Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015) (storing and retrieving information in memory); and OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1092-93 (Fed. Cir. 2015) (storing and retrieving information in memory).
Moreover, in regards to the “search a database of proxy accounts that are associated with a plurality of financial institution servers” step, this is a “mere data gathering [step] in conjunction with an … abstract idea”. See CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375, 99 USPQ2d 1690, 1694 (Fed. Cir. 2011) (Holding that a step of obtaining information about credit card transactions so that the information can be analyzed by an abstract mental process is mere data gathering in conjunction with a law of nature or abstract idea) (see MPEP §§ 2106.05(I)(A) and 2106.05(g))
Independent claims 28 and 35 are rejected on the same grounds as independent claim 21, plus also on the grounds that independent claim 28 recites a computer-readable medium, which is merely another generic computer component.
All dependent claims are also rejected, because they merely further define the abstract idea.
Response to Amendments
Re: Claim Rejections - 35 USC § 101
In regards to the 35 USC § 101 rejection, it has been maintained, in response to Applicant’s amendments to the independent claims.
In pages 12 and 13 of the Request for Reconsideration filed on May 26, 2026, the Applicant argues that the claims are not directed to an abstract idea.
The Examiner respectfully disagrees. The Examiner finds that the following claimed features are “Certain Methods of Organizing Human Activity", specifically “Commercial or Legal Interactions (Including Agreements in the form of Contracts; Legal Obligations; Advertising, Marketing, or Sales Activities or Behaviors; Business Relations)”, as discussed in MPEP §2106(a)(2) Parts (I) and (II), and in the 2019 Revised Patent Subject Matter Eligibility Guidance:
“the sending account being hosted by a first server of a first financial institution”.
“the receiving account being hosted by a second server of a second financial institution”.
“process an intermediary transfer from the sending account to the proxy account”.
In pages 13 through 16 of the Request for Reconsideration filed on May 26, 2026, the Applicant argues that even if the claims are directed to an abstract idea, they are still patent eligible under Step 2A, Prong Two, because the pending claims recite a “technological solution to a technological problem”.
The Examiner finds that the most important steps recited in the independent claims are not an improvement in technology, but instead an improvement in a business method:
“process an intermediary transfer from the sending account to the proxy account” (wherein the sending account and proxy account are hosted by two different financial institutions); and
“initiate an immediate electronic intrabank wire transfer from the proxy account to the receiving account” (wherein the proxy account and receiving account are hosted by the same financial institution).
In pages 17 and 18 of the Request for Reconsideration filed on May 26, 2026, the Applicant argues that even if the claims are directed to an abstract idea, they are still patent eligible under Step 2B, because the pending claims amount to “significantly more” than the abstract idea because the claims “contain an inventive concept”.
The Applicant specifically refers to the claimed step of “search a database of proxy accounts that are associated with a plurality of financial institution servers to identify a proxy account that is hosted by the second server”, however, the Examiner does not find that the independent claims as a whole recite a “technological solution to a technological problem”, but instead recite a business method solution (use of proxy accounts when transferring money between different banks, in order to enable the use of intrabank transfers, instead of the slower and more expensive interbank transfers) to a business method problem (reducing time and expense of transferring money between bank accounts).
Therefore, the 35 USC 101 rejection is maintained.
Re: Claim Rejections - 35 USC § 103
In regards to the 35 USC § 103 rejection, it has been withdrawn, in response to Applicant’s arguments regarding the independent claims, as presented in the Interview Summary dated May 18, 2026.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
US-2007/0179885-A1 to Bird et al. (“Bird”. Eff. Filed on Jan. 30, 2006. Published on Aug. 2, 2007). See para. [0045]:
Each PayLink™ server 110, 115, 117 and 119 is connected to a PayLink™ customer database (not shown) comprising customer registration data specific to the respective bank. Each PayLink™ customer database comprises data for each registered banking customer of the respective bank, including customer identification information, bank account information (such as account type, account number, and currency), and bank proxy interface (PayLink™) account information. Within each PayLink™ customer database, the bank account number is mapped to a PayLink™ account ID which is mapped to a registered user. Typically, a PayLink™ account ID is provided for each registered bank account. A user may have more than one registered bank account and therefore more than one PayLink™ account ID.
US-7,996,288-B1 to Stolfo. (“Stolfo”. Filed on Nov. 15, 2000. Published on Aug. 9, 2011). See col. 6, lines 30 to 45:
In step 208, the proxy financial account information is stored in a database. The authorized merchant's identity information is also stored in the database in linked relation to the proxy financial account information. This linking of the authorized merchant's identity to the user's proxy financial information can be implemented in a variety of ways known to one of ordinarily skill in the art of computer programming and system design. For example, the linking of merchant identity information with proxy financial information may be implemented by a “cross reference table” that associates specific proxy financial information such as a proxy credit card account number with specific merchant identifier codes. Since services like subscriptions may be purchased for long periods of time, the “linked” information advantageously is stored and available for authorization for a sufficient period of time so that users need not reinitiate private purchases.
However, neither Bird nor Stolfo, either individually or in combination, expressly teaches the following combination of claimed features of independent claim 21:
search a database of proxy accounts that are associated with a plurality of financial institution servers to identify a proxy account that is hosted by the second server;
process an intermediary transfer from the sending account to the proxy account; and
initiate an immediate electronic intrabank wire transfer from the proxy account to the receiving account.
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 should be directed to Examiner Ayal Sharon, whose telephone number is (571) 272-5614, and fax number is (571) 273-1794. The Examiner can normally be reached from Monday to Friday between 9 AM and 6 PM. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Christine M Behncke can be reached on (571) 272-8103. The fax number for the organization where this application or proceeding is assigned is 571-273-8300.
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Sincerely,
/Ayal I. Sharon/
Examiner, Art Unit 3695
August 12, 2026
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