DETAILED ACTION
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 5/4/2026 has been entered.
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 1-6, and 21-34 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (abstract idea) without significantly more.
Under the broadest reasonable interpretation, the following claim terms are presumed to have their plain meaning consistent with the specification as it would be interpreted by one of ordinary skill in the art. MPEP § 2111.
Step 1: Does the Claim Fall within a Statutory Category? (see MPEP 2106.03)
Claim 1 recites a system, which is a statutory category of invention (Step 1: YES). Claim 23 recites a system, which is a statutory category of invention (Step 1: YES). Claim 31 recites a product, which is a statutory category of invention (Step 1: YES).
Step 2A, Prong One: Is a Judicial Exception Recited? (see MPEP 2106.04(a)). Yes.
The claims are analyzed to determine whether it is directed to a judicial exception. The following claims identify the limitations that recite additional elements in bold and the abstract idea without bold. Underlined claim limitations denote newly added claim limitations:
The claims are analyzed to determine whether it is directed to a judicial exception. Claim 1, 23 and 31 recite a method comprising: receiving, via a graphical user interface, a request from a user over a network for a modification of a respective purchasing power associated with one or more respective transaction account; calculating a global purchasing capacity for the modification of the respective purchasing power associated with the one or more respective transaction accounts, the global purchasing capacity based at least in part on the respective purchasing power of each of the one or more respective transaction accounts associated with the user; retrieving, from a data store, a risk profile associated with the user, the risk profile comprising a plurality of credit factors; determining a risk exposure based at least in part on the risk profile and the global purchasing capacity; determining, based at least in part on the risk exposure, a maximum modification value for the respective purchasing power of the respective transaction accounts; receiving, via the graphical user interface, a modification amount for the modification of the respective purchasing power of the one or more respective transaction accounts associated with each of the one or more respective transaction accounts, wherein the modification amount is less than or equal to the maximum modification value; modifying the respective purchasing power of ones of the one or more respective transaction accounts based at least in part on the modification amount, thereby generation a modified respective purchasing power for the one or more respective transaction accounts; in response to modifying the respective purchasing power of the ones of the one or more respective transaction accounts, automatically updating the graphical user interface to display, in real time, a total input and global purchasing capacity, the total input based at least in part on the modification amount; in response to modifying the respective purchasing power, recalculating the global purchasing capacity based at least in part on the modified respective purchasing power, thereby generating a recalculated global purchasing capacity; and storing the recalculated global purchasing capacity in the data store; in response to storing the recalculated global purchasing capacity, automatically generating a notification message, the notification message comprising the modified respective purchasing power of the ones of the one or more respective transaction accounts; and transmitting the notification message to a client application in real time.
These limitations, as drafted, under its broadest reasonable interpretation, covers performance via certain methods of organizing human activity and mental processes, but for the recitation of generic computer components. Under human activity, the limitations are commercial interactions, such as business relations, as well as managing interactions between people, such as following rules or instructions. Under mental processes, the claims are capable of being performed in the human mind or through pen and paper. Accordingly, the claim recites an abstract idea. The mere recitation of generic computer components in the claims do not necessarily preclude that claim from reciting an abstract idea. (Step 2A-Prong 1: Yes. The claims recite an abstract idea).
Step 2A, Prong Two: Is the Abstract Idea Integrated into a Practical Application? (see MPEP 2106.04(d)). No.
The above judicial exception is not integrated into a practical application. particular, the claim recites the additional elements of a client application, system, computing device, processor, memory, a non-transitory computer readable medium, notification message, network, data store, and graphical user interface. The additional elements of a client application, system, computing device, processor, memory, and a non-transitory computer readable medium, notification message, network and data store, are just applying generic computer components to the recited abstract limitations (MPEP 2106.05(f)). The additional elements of first and second graphical user interfaces are generally linking the use of the judicial exception to a particular technological environment or field of use, for the particular technology of Graphical User Interfaces (MPEP 2106.05(h)). The computer components are recited at such a high-level of generality (i.e. as a generic computer components) such that it amounts to no more than mere instructions to apply the exception using generic computer components, and the claims fail to recite technological detail as to how the step of the judicial exception is accomplished. 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 and are at a high level of generality. (Step 2A-Prong 2: NO. The judicial exception is not integrated into a practical application).
Step 2B: Does the Claim Provide an Inventive Concept? (see MPEP 2106.05). No.
The claims are next analyzed to determine if there are additional claim limitations that individually, or as an ordered combination, ensure that the claim amounts to significantly more than the abstract ideas (whether claim provides inventive concept). As discussed with respect to Step 2A2 above, the additional elements of (a client application, system, computing device, processor, memory, and a non-transitory computer readable medium, notification message, network and data store and graphical user interface) in the claims amount to no more than mere instructions to apply the exception using a generic computer component and generally linking the use of GUI’s to judicial exception. The same analysis applies here in Step 2B, i.e., mere instructions to apply an exception using a generic computer component and generally linking the use of GUI’s to judicial exception cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. Viewing the limitations as an ordered combination does not add anything further than looking at the limitations individually. When viewed either individually, or as an ordered combination, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea itself. Therefore, the claims do not amount to significantly more than the recited abstract idea (Step 2B: NO; The claims do not provide significantly more, and are not patent eligible).
Claim 2 recites wherein the modification of the respective purchasing power associated with the one or more respective transaction account further comprises: a value for the modification of the respective purchasing power; or a reallocation of the respective purchasing power from a second transaction account to a first transaction account. These limitations are also part of the abstract idea identified in claim 1, and is similarly rejected under the same rationale as claim 1, supra.
Claim 3 recites wherein modifying the respective purchasing power is based at least in part on one or more of a max modification, the global purchasing capacity, or the risk exposure.
These limitations are also part of the abstract idea identified in claim 1, and is similarly rejected under the same rationale as claim 1, supra.
Claim 4 recites wherein determining the risk exposure further comprises: fetching the risk profile, the risk profile comprising a plurality of credit factors; and calculating the max modification based at least in part on the risk profile. These limitations are also part of the abstract idea identified in claim 1, and is similarly rejected under the same rationale as claim 1, supra.
Claim 5 recites further comprising: recalculating the respective purchasing power of at least one or more transaction accounts; sending a first notification, the first notification comprising a confirmation of the modification of the respective purchasing power; and sending a second notification, the second notification comprising at least one of the global purchasing capacity or the modified purchasing power of a first transaction account. These limitations are also part of the abstract idea identified in claim 1, and is similarly rejected under the same rationale as claim 1, supra.
Claim 6 recites further comprising: performing an authentication process; and identifying the one or more respective transaction accounts and the respective purchasing power associated with the one or more respective transaction account. These limitations are also part of the abstract idea identified in claim 1, and is similarly rejected under the same rationale as claim 1, supra.
Claim 21 recites further comprising: receiving a request to split a transaction; receiving, from a client application, a first selection, the first selection identifying a selected transaction to split; analyzing the selected transaction to determine a split eligibility, wherein the split eligibility is based at least in part on one or more splitting rules; receiving a second selection from the client application, the second selection identifying a second transaction account for splitting the selected transaction; and splitting the selected transaction between a first transaction account and the second transaction account. These limitations are also part of the abstract idea identified in claim 1, and the additional elements of the application are addressed in the Steps 2A2 and B as just applying generic computer components to the recited abstract limitations (MPEP 2106.05(f)) as in the claim 1 analysis above. Therefore, this claim is similarly rejected under the same rationale as claim 1, supra.
Claim 22 recites further comprising: creating a new transaction on the second transaction account based at least in part on a split of the selected transaction between the first transaction account and the second transaction account; applying a credit to the first transaction account; and updating a purchasing power of the first transaction account and the second transaction account. These limitations are also part of the abstract idea identified in claim 1, and is similarly rejected under the same rationale as claim 1, supra.
Claim 24 recites wherein the modification of the respective purchasing power associated with the one or more respective transaction account further comprises: a value for the modification of the respective purchasing power; or a reallocation of the respective purchasing power from a second transaction account to a first transaction account. These limitations are also part of the abstract idea identified in claim 23, and is similarly rejected under the same rationale as claim 23, supra.
Claim 25 recites wherein modifying the respective purchasing power is based at least in part on one or more of a max modification, the global purchasing capacity, or the risk exposure. These limitations are also part of the abstract idea identified in claim 23, and is similarly rejected under the same rationale as claim 23, supra.
Claim 26 recites fetch the risk profile, the risk profile comprising a plurality of credit factors; and calculate the max modification based at least in part on the risk profile. These limitations are also part of the abstract idea identified in claim 23, and is similarly rejected under the same rationale as claim 23, supra.
Claim 27 recites recalculate the respective purchasing power of at least one or more respective transaction accounts; send a first notification, the first notification comprising a confirmation of the modification of the respective purchasing power; and send a second notification, the second notification comprising at least one of the global purchasing capacity or the modified purchasing power of a first transaction account. These limitations are also part of the abstract idea identified in claim 23, and is similarly rejected under the same rationale as claim 23, supra.
Claim 28 recites perform an authentication process; and identify the one or more respective transaction accounts and the respective purchasing power associated with the one or more respective transaction accounts. These limitations are also part of the abstract idea identified in claim 23, and is similarly rejected under the same rationale as claim 23, supra.
Claim 29 recites receive a request to split a transaction; receive, from a client application, a first selection, the first selection identifying a selected transaction to split; analyze the selected transaction to determine a split eligibility, wherein the split eligibility is based at least in part on one or more splitting rules; receive a second selection from the client application, the second selection identifying a second transaction account for splitting the selected transaction; and split the selected transaction between a first transaction account and the second transaction account. These limitations are also part of the abstract idea identified in claim 23, and the additional elements of the application are addressed in the Steps 2A2 and B as just applying generic computer components to the recited abstract limitations (MPEP 2106.05(f)) as in the claim 23 analysis above. Therefore, this claim is similarly rejected under the same rationale as claim 23, supra.
Claim 30 recites create a new transaction on the second transaction account based at least in part on a split of the selected transaction between the first transaction account and the second transaction account; apply a credit to the first transaction account; and update a purchasing power of the first transaction account and the second transaction account. These limitations are also part of the abstract idea identified in claim 23, and is similarly rejected under the same rationale as claim 23, supra.
Claim 32 recites wherein the modification of the respective purchasing power associated with the one or more respective transaction account further comprises: a value for the modification of the respective purchasing power; or a reallocation of the respective purchasing power from a second transaction account to a first transaction account. These limitations are also part of the abstract idea identified in claim 31, and is similarly rejected under the same rationale as claim 31, supra.
Claim 33 recites wherein modifying the respective purchasing power is based at least in part on one or more of a max modification, the global purchasing capacity, or the risk exposure. These limitations are also part of the abstract idea identified in claim 31, and is similarly rejected under the same rationale as claim 31, supra.
Claim 34 recites fetch the risk profile, the risk profile comprising a plurality of credit factors; and calculate the max modification based at least in part on the risk profile. These limitations are also part of the abstract idea identified in claim 31, and is similarly rejected under the same rationale as claim 31, supra.
Response to Arguments
Applicant's arguments filed 5/4/2026 have been fully considered but they are not persuasive.
Applicant argues that the currently amended claims are a practical application (Applicant arguments, pg. 19), and that the amended claim 1 is a technical solution to a technical problem. Examiner disagrees. 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. The claims here are not directed to a specific improvement to computer functionality. Rather, they are directed to the use of conventional or generic technology in a well-known environment, without any claim that the invention reflects an inventive solution to any computer specific problem. More specifically, the claims are limited to a business solution to a technical problem, not a technical solution to a technical problem. Applicants own specification recites the following technical improvements: “Techniques described herein of enhanced financial account management and transaction capabilities provide a significant technical improvement by reducing database storage requirements (e.g., storing information for a new transaction account, storing information for the user, etc.), reducing network bandwidth requirements (e.g., related to evaluating and processing new transaction account applications), and improved data analysis and reporting (e.g., applying existing information for enhanced transaction account functionality). The techniques described herein of enhanced financial account management and transaction capabilities can also provide a significant technical benefit such as streamlining account management (e.g., using a single application, managing multiple transaction accounts using single credentials, etc.), optimized transaction account awards and benefits, and reduced operation costs (e.g., less equipment, fewer personnel, etc.)” (Para. 30). These alleged improvements in the specification are results of the business method and abstract idea itself, rather than a technological solution. These benefits are simply applying financial practices in a computer environment. In other words, the claims braodly cover an economic activity of enhancing account flexibility without tying it to a specific, concrete technological improvement or solution to a technical problem.
In Enfish, the court evaluated the patent eligibility of claims related to a self-referential database. Id. The court concluded the claims were not directed to an abstract idea, but rather an improvement to computer functionality. In contrast, the current claims are not directed to an improvement to computer functionality and instead merely recite the computer elements at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer component.
Similarly, in DDR Holdings LLC v. Hotels.com, LP, the claims were found eligible as they reflected improvements to the functioning of a computer, i.e. a modification of conventional Internet hyperlink protocol to dynamically produce a dual-source hybrid webpage. In contrast, the current claims do not contain limitations reflective of an improvement to computer functionality and instead merely recite the computer elements at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic computer component.
Further, the addition of the graphical user interface is a generic user interface for input/display, notification and real-time update that does not transform the abstract idea into a practical application. The automatic responses, such as GUI update, recalculation and notification, are just automating of business rules, and are not a specific technical improvement to a computer.
The currently amended claims and the presented GUI is different than Example 37, because in Example 37 automatically moved icons into a specific position on the GUI based on usage and improved the GUI by overcoming an inefficient manual icon organization on the display with icons, with an improvement is visual organization and accessibility, whereas the currently amended claims simply “automatically update the GUI,” and do not deal with positioning of icons, nor improve visual organization and accessibility.
The claims do not provide an inventive concept. As discussed above, the additional elements in the claim amount to no more than mere instructions to apply the exception using a generic computer. Even when viewed as whole, nothing in the claim adds significantly more (i.e. inventive concept) to the abstract idea. The currently recited claims solve recalculating a user global purchasing power for transactions, which is not a significant improvement to the functioning of a computer or to any other technology or technical field (MPEP 2106.05(a)).
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to BRANDON M DUCK whose telephone number is (469)295-9049. The examiner can normally be reached 8am - 5pm.
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/BRANDON M DUCK/Examiner, Art Unit 3693
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