CTNF 18/208,740 CTNF 80634 DETAILED ACTION 1. Notice of Pre-AIA or AIA Status 07-03-aia AIA 15-10-aia The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA. 2. Continued Examination Under 37 CFR 1.114 07-42-04 AIA 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 4/20/2026 has been entered. 3. Status of Application and Claims Claims 1-3, 5-9, 12-14 and 16-22 are pending. Claims 1, 3, 5-9, 12, 14 and 16-22 were amended and/or newly added in the Applicant's filing on 4/20/2026. This office action is being issued in response to the Applicant's filing(s) on 4/20/2026. 07-30-03-h AIA 4. Claim Interpretation The subject matter of a properly construed claim is defined by the terms that limit its scope when given their broadest reasonable interpretation. see MPEP §2013(I)(C). Specifically, the “broadest reasonable construction ‘in light of the specification as it would be interpreted by one of ordinary skill in the art.’” See MPEP §2111, citing Phillips v. AWH Corp ., 75 USPQ2d 1321, 1329 (Fed. Cir. 2005). However, “[t]hough understanding the claim language may be aided by explanations contained in the written description, it is important not to import into claim limitations that are not part of the claim.” See MPEP §2111.01, citing Superguide Corp. v. DirecTV Enterprises, Inc ., 69 USPQ2d 1865, 1868 (Fed. Cir. 2004). Construing claims broadly during prosecution is not unfair to the applicant, because the applicant has the opportunity to amend the claims to obtain more precise claim coverage. See MPEP §2111, citing In re Yamamoto , 222 USPQ 934, 936 (Fed. Cir. 1984). As a general matter, grammar and the plain meaning of terms as understood by one having ordinary skill in the art used in a claim will dictate whether, and to what extent, the language limits the claim scope. See MPEP §2013(I)(C). Language that suggests or makes a feature or step optional but does not require that feature or step does not limit the scope of a claim under the broadest reasonable claim interpretation. See MPEP §2013(I)(C). As such, claim limitations that contain statement(s) such as “if,” “may,” “might,” “can,” and “could” are treated as containing optional language. See MPEP §2013(I)(C). As matter of linguistic precision, optional claim elements do not narrow claim limitations, since they can always be omitted. See MPEP §2013(I)(C). Similarly, a method step exercised or triggered upon the satisfaction of a condition, where there remains the possibility that the condition was not satisfied under the broadest reasonable interpretation, is an optional claim limitation. See MPEP §2111.04(II). As the Applicant does not address what happens should the optional claim limitations fail, Examiner assumes that nothing happens (i.e., the method stops). An alternate interpretation is that merely the claim limitations based upon the condition are not triggered or performed. In addition, when a claim requires selection of an element from a list of alternatives, the prior art teaches the element if one of the alternatives is taught by the prior art. See MPEP §2143.03, citing Fresenius USA, Inc. v. Baxter Int’l, Inc ., 582 F.3d 1288, 1298 (Fed. Cir. 2009); Language in a method or system claim that states only the intended use or intended result, but does not result in a manipulative difference in the steps of the method claim nor a structural difference between the system claim and the prior art, fails to distinguish the claims from the prior art. The following types of claim language may raise a question as to its limiting effect (this list is not exhaustive): Statements of intended use or field of use, including statements of purpose or intended use in the preamble. See MPEP §2111.02; Clauses such as “adapted to”, “adapted for”, “wherein”, and “whereby.” See MPEP §2111.04; Contingent limitations. See MPEP §2111.04(II); Printed matter. See MPEP §2111.05; and Functional language associated with a claim term. See MPEP §2181. As such, while all claim limitations have been considered and all words in the claims have been considered in judging the patentability of the claimed invention, the following italicized, underlined and/or boldened language is interpreted as not further limiting the scope of the claimed invention. Additionally, the following italicized, underlined and emboldened language is not necessarily an exhaustive list of claim language that is interpreted as not further limiting the scope of the claimed invention. Applicant should review all claims for additional claim interpretation issues. Claim 12 recites a method comprising: determining, by a processor based on a request to pledge at least part of an amount of cryptocurrency transferred, via an external cryptocurrency blockchain network operating independent of the processor, from an external cryptocurrency account to a gaming establishment controlled custodian account associated with an identified user as collateral for a gaming establishment line of credit is approved, an amount of available funds of the gaming establishment line of credit, Method claims are defined by the method steps being actively performed (i.e., transferring cryptocurrency), not method steps performed in the past (i.e., cryptocurrency transferred). Claiming method steps in the past tense can be interpreted as the method steps performed in the past are outside the scope of the claimed method. Alternatively stated, the scope of the claimed method are the active method steps which are building off a pre-existing state. The method steps performed for creation of the pre-existing state are outside the scope of the claimed invention. Claim 1 has similar claim interpretation issues, as Claim 1 does not recite that the system is transferring the cryptocurrency. Claim 12 recites a method comprising: releasing, by the processor, the placed lock and enabling, independent of the identified user, a transfer, via the external cryptocurrency blockchain network, of at least a portion of the amount of cryptocurrency from the gaming establishment controlled custodian account associated with the identified user to the external cryptocurrency account based on the conclusion of the limited duration associated with the gaming establishment line of credit being reached and the determination being that no portion of the amount of available funds is owed on the gaming establishment line of credit. Method claims are defined by the method steps being actively performed (i.e., transferring at cryptocurrency), not method steps possibly performed in the future (i.e., enabling a transfer of cryptocurrency). Claiming method steps in the future tense can be interpreted as the method steps possibly performed in the future are outside the scope of the claimed method. Enabling a transfer does not mean that a transfer actually performed. Just that a transfer is enabled (i.e., the means or opportunity is provided for a potential transfer). Claim 22 recites a method wherein the gaming establishment line of credit comprises a This Trip Only gaming establishment line of credit. Examiner notes that the specification does not define the claim element “This Trip Only” gaming establishment line of credit. Examiner assumes that the line of credit is being defined by a time duration of the trip (e.g., daily or weekly). Examiner notes that the line of credit is already defined by a time duration (i.e., a limited duration). See Claims 1 and 12. Claim 21 has similar claim interpretation issues. 5. Claim Rejections - 35 USC § 101 07-04-01 AIA 07-04 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 1-3, 5-9, 12-14 and 16-22 are rejected under 35 U.S.C. § 101 because the claimed invention is directed to an abstract idea without significantly more. STEP 1 The claimed invention falls within one of the four statutory categories of invention (i.e., process, machine, manufacture and composition of matter). See MPEP §2106.03. STEP 2A – PRONG ONE The claim(s) recite(s) a method and a system, executing instructions, causing the system to perform a method comprising: determining, … based on a request to pledge at least part of an amount of the [currency] transferred, …, from an external [currency] account to a gaming establishment controlled custodian account associated with an identified user as collateral for a gaming establishment line of credit is approved, an amount of available funds associated of the gaming establishment line of credit; placing, … and based on the identified user accessing at least a portion of the amount of available funds, a lock on any transfers of the amount of [currency] from the gaming establishment controlled custodian account associated with the identified user back to the external [currency] account, determining, …, if any portion of the amount of available funds is owed on the gaming establishment line of credit in association a conclusion of a limited duration associated with the gaming establishment line of credit being reached; releasing, …, the placed lock and enabling, independent of the identified user, a transfer, …, of at least a portion of the amount [currency] from the gaming establishment controlled custodian account associated with the identified use to the external [currency] account based on the conclusion of the limited duration associated with the gaming establishment line of credit being reached and the determination being that no portion of the amount of available funds is owed on the gaming establishment line of credit, and; maintaining, …, the placed lock based on the conclusion of the limited duration associated with the gaming establishment line of credit being reached and the determination being that at least part of the amount of available funds is owed on the gaming establishment line of credit. These limitations, as drafted, under its broadest reasonable interpretation, covers a series of steps instructing how to manage collateral used to secure a line of credit which is a fundamental economic practice, a sub-category of certain method(s) of organizing human activity, an enumerated grouping of abstract ideas. See MPEP §2106.04(a)(2)(II)(A). Examiner notes that locking up collateral used to secure a line of credit is mitigation of financial risk that there will be insufficient collateral to satisfy the debt and that the mitigation of financial risk is a court-provided example of a fundamental economic practice. See MPEP §2106.04(a)(2)(II)(A), citing Alice Corp. v. CLS Bank. (2014). Accordingly, the claimed invention recites an abstract idea. STEP 2A – PRONG TWO The claimed invention recites additional elements (i.e., computer elements) of a processor (Claim(s) 1 and 12) and a memory (Claim(s) 1), wherein the currency is cryptocurrency (Claim(s) 1 and 12); and wherein the cryptocurrency is transferred via a blockchain network (Claim(s) 1 and 12). The claimed invention does not include additional elements that integrate the judicial exception into a practical application of the exception because the claims do not provide improvements to another technology or technical field; improvements to the functioning of the computer itself; are not applying or using a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition; are not applying the judicial exception with or by use of a particular machine; are not effecting a transformation or reduction of a particular article to a different state or thing; and are not applying the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment. See MPEP §2106.04(d). The additional elements are recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using a generic computer component. See MPEP §2106.05(f). Alternately, the additional elements amount to no more than generally linking the exception to a particular technological environment or field of use. See MPEP §2106.05(h). Accordingly, these additional element(s), when considered separately and as an ordered combination, do not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Accordingly, the claimed invention is directed to an abstract idea without a practical application. STEP 2B Upon reconsideration of the indicia noted under Step 2A in concert with the Step 2B considerations, the additional claim element(s) amounts to adding the words “apply it” (or an equivalent) with the judicial exception. See MPEP §2106.07(a)(II). The same analysis applies in Step 2B, i.e., mere instructions to apply an exception using a generic computer component cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. The claim does not provide an inventive concept significantly more than the abstract idea. 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. DEPENDENT CLAIMS Dependent Claim(s) 2-3, 5-9, 13, 14 and 16-22 recite claim limitations that further define the abstract idea recited in respective independent Claim(s) 1 and 12. As such, the dependent claims are also grouped an abstract idea utilizing the same rationale as previously asserted against the independent claims. No additional computer components other than those found in the respective independent claims is recited, thus it is presumed that the claim is further utilizing the same generically recited computer. As such, the dependent claims do not include any additional elements that integrate the abstract idea into a practical application of the judicial exception or are sufficient to amount to significantly more than the judicial exception when considered both individually and as an ordered combination. Accordingly, the dependent claim(s) are also not patent eligible. Appropriate correction is requested. 6. Claim Rejections - 35 USC § 112(b) 07-30-02 AIA The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 3 and 14 are rejected based upon a reference to a claim element that is variable. “A claim may be rendered indefinite when a limitation of the claim is defined by reference to an object and the relationship between the limitation and the object is not sufficiently defined.” See MPEP §2173.05(b)(II). Claim 3 states “wherein the limited duration is less than a repayment duration associated with another gaming establishment line of credit not associated with any amounts of cryptocurrency pledged as collateral." Claim language fails to indicate what constitutes “a repayment duration associated with another gaming establishment line of credit." As said duration could be any duration, said claim limitation fails to establish any limitations upon the “the limited duration.” Claim 14, due to similar claim language, results in a similar claim rejection. Claims 21 and 22 are rejected based upon a reference to a claim element that is variable. “A claim may be rendered indefinite when a limitation of the claim is defined by reference to an object and the relationship between the limitation and the object is not sufficiently defined.” See MPEP §2173.05(b)(II). Claim 21 states “the gaming establishment line of credit comprises a This Trip Only gaming establishment line of credit." Examiner notes that the specification does not define the claim element “This Trip Only” gaming establishment line of credit. Examiner assumes that the line of credit is being defined by a time duration of the trip (e.g., daily or weekly). Claim language fails to indicate what constitutes the duration of one trip. As said duration could be any duration, said claim limitation fails to establish any limitations upon the “This Trip Only.” Claim 22 , due to similar claim language, results in a similar claim rejection. Appropriate correction is requested. 7. Claim Rejections - 35 USC § 103 07-20-aia AIA The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. 07-23-aia AIA The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. 07-21-aia AIA Claim s 1-3, 5-9, 12-14 and 16-22 is/are rejected under 35 U.S.C. 103 as being unpatentable over Nelson (US PG Pub. 2018/0365764) and Upadrasta (US PG Pub. 2024/0021046) . Regarding Claim 12 , Nelson discloses a method of operating a system, the method comprising: determining, by a processor based on a request to pledge at least a part of the amount of the cryptocurrency transferred, via an external cryptocurrency blockchain network operating independent of the processor, form an external cryptocurrency account to an establishment controlled custodian account associated with an identified user as collateral for an establishment line of credit is approved, an amount of available funds of the establishment line of credit (loan value or an amount equal to the USD value of the collateral). (see abstract; para. 42); placing, by the processor and based on the identified user accessing at least a portion of the amount of available funds, a lock on any transfers of the amount of cryptocurrency from the controlled custodian account associated with the identified user (participant) back to the external account. (see para. 60 and 113); determining, by the processor, if any portion of the amount of available funds is owed on the establishment line of credit in association with a conclusion of a limited duration (specified amount of time) associated with the establishment line of credit being reached. (see para. 62); releasing, by the processor, the placed lock (unlocking collateral) and enabling, independent of the identified user, a transfer, via the external cryptocurrency blockchain network, of at least a portion of the amount of cryptocurrency from the establishment controlled custodian account associated with the identified user to the external cryptocurrency account based on the conclusion of the limited duration (specified amount of time) associated with the establishment line of credit being reached and the determination being that no portion of the amount of available funds is owed on the establishment line of credit (loan is repaid in the amount equal to that which was originally withdrawn). (see fig. 3A; para. 19 and 42); and maintaining, by the processor, the placed lock based on the conclusion of the limited duration (specified amount of time) associated with the establishment line of credit being reached and the determination being that at least part of the amount of available funds is owed on the establishment line of credit (necessary assets or funds are not contributed in time). (see fig. 3A; para. 64). Nelson does not explicitly teach a method wherein the establishment is a gaming establishment. Upadrasta discloses a method wherein the establishment is a gaming establishment (casino). (see para. 60). It would have been obvious to one of ordinary skill in the art at the effective filing date of the invention to have modified Nelson to incorporate a gaming establishment-controlled custodian account, as disclosed by Upadrasta, thereby utilizing the collateral to secure credit at a gaming establishment, as disclosed by Upadrasta. Regarding Claim 13 , Nelson does not teach a method wherein the limited duration is associated with a period of time during which the identified user visits a gaming establishment. It would have been obvious to one having ordinary skill in the art at the effective filing date of the invention was made to allow for the limited duration (i.e. time period) that the inventor desired, such as a limited duration associated with a gaming visit, as disclosed by Upadrasta. In re Kuhle , 526 Regarding Claim 14, Nelson does not explicitly teach a method wherein the limited duration less than a repayment duration associated with another line of credit not associated with any amounts of cryptocurrency pledged as collateral, although Nelson discloses a method wherein the other amounts (other portfolios) not associated with any amounts of cryptocurrency pledged as collateral. (see para. 81). It would have been obvious to one having ordinary skill in the art at the effective filing date of the invention was made to allow for the limited duration (i.e. time period) that the inventor desired, such as a limited duration less than a repayment duration associated with another line of credit. In re Kuhle , 526 F.2d 553, 555, 188 USPQ 7, 9 (CCPA 1975). Regarding Claim 16, Nelson discloses a method wherein the placement of the lock is based on a current price (market value) of the amount of cryptocurrency. (see para. 94). Regarding Claim 17, Nelson discloses a method wherein the placement of the lock is based on an attribute (identity verification) of the identified user. (see para. 81). Regarding Claim 18, Nelson discloses a method wherein the placement of the lock is based on a volatility of price fluctuations of the cryptocurrency. (see para. 62). Regarding Claim 19 , such claim(s) recite substantially similar limitations as claimed in previously rejected claim(s) and, therefore, would have been obvious based upon previously rejected claim(s). Regarding Claim 20 , Nelson discloses a method comprising, responsive to the conclusion of the limited duration associated with the line of credit when at least part of the amount of available funds is owed on the line of credit, automatically liquidating at least part of the amount of cryptocurrency. (see para. 72). Regarding Claim 22 , Nelson discloses a system wherein the gaming establishment line of credit comprises a This Trip Only (specified amount of time) line of credit. (see para. 62). Regarding Claims 1-3, 5-9 and 21 , such claim(s) recite substantially similar limitations as claimed in previously rejected claim(s) and, therefore, would have been obvious based upon previously rejected claim(s) . 8. Response to Arguments 07-37 AIA Applicant's arguments filed 4/ 20/2026 ha ve been fully considered but they are not persuasive. §101 Rejection Applicant argues that the claimed invention recites a practical application and, as such, satisfies Step 2A Prong Two of the §101 Guidelines. See Arguments, pp. 8-10. Specifically, Applicant argues: Applicant respectfully submits that similar to how new capabilities through automation not possible with prior human operation evidenced patentable subject matter in McRO, representative Claim 1 offers new capabilities not possible with prior human operation due to the scope and breadth of transfers of cryptocurrency via an external cryptocurrency blockchain network. That is, given the technicality of employing an external cryptocurrency blockchain network operating independent of the processor to transfer cryptocurrency coupled with the unique aspects of a gaming establishment controlled custodian account (e.g., the account is associated with an identified user but transfers of cryptocurrency away from the account are determined independent of the identified user) provides that the claimed gaming establishment credit systems and methods employ capabilities in a way not otherwise possible through human operation. See Arguments, pp. 8-9 – emphasis added. The Examiner respectfully disagrees. The court in McRO stated: Claim 1 of the ′576 patent is focused on a specific asserted improvement in computer animation, i.e., the automatic use of rules of a particular type. We disagree with Defendants’ arguments that the claims simply use a computer as a tool to automate conventional activity. While the rules are embodied in computer software that is processed by general-purpose computers, Defendants provided no evidence that the process previously used by animators is the same as the process required by the claims. See Defs.’ Br. 10-15, 39-40. In support, Defendants point to the background section of the patents, but that information makes no suggestion that animators were previously employing the type of rules required by claim 1. Defendants concede an animator's process was driven by subjective determinations rather than specific, limited mathematical rules. The prior art “animator would decide what the animated face should look like at key points in time between the start and end times, and then ‘draw’ the face at those times.” Defs.’ Br. 10. The computer here is employed to perform a distinct process to automate a task previously performed by humans. McRO states that animators would initially set keyframes at the point a phoneme was pronounced to represent the corresponding morph target as a starting point for further fine tuning. J.A. 3573 at 8:53 ( McRO 's Claim Construction Presentation). This activity, even if automated by rules, would not be within the scope of the claims because it does not evaluate sub-sequences, generate transition parameters or apply transition parameters to create a final morph weight set. It is the incorporation of the claimed rules, not the use of the computer, that “improved [the] existing technological process” by allowing the automation of further tasks. Alice , 134 S. Ct. at 2358. This is unlike Flook, Bilski, and Alice, where the claimed computer-automated process and the prior method were carried out in the same way. Flook, 437 U.S. at 585-86; Bilski, 561 U.S. at 611; Alice , 134 S. Ct. at 2356. See McRO, Inc. v. Bandai Namco Games America Inc., 120 USPQ2d 1091, 1102 (Fed. Cir. 2016) - emphasis added. In McRO , the court determined that the claimed invention recited a computer system utilizing specific rules that “enabled the automation of specific animation tasks that previously could only be performed subjectively by humans, when determining that the claims were directed to improvements in computer animation instead of an abstract idea.” See MPEP §2106.05(a). That determination allowed the court to classify the claimed invention in McRO as an improvement in an existing technological process (i.e., computer animation), unlike Alice where a computer was merely used as a tool to perform an existing process. In the instant case, the claimed invention is not improving a technological process by reciting specific rules to automate a process that otherwise could not be automated. Rather the claimed invention in the instant case, like Alice , is using a computer and its existing capabilities as a tool to implement an abstract idea. Additionally, MPEP §2106.05(a) recites: If it is asserted that the invention improves upon conventional functioning of a computer, or upon conventional technology or technological processes, a technical explanation as to how to implement the invention should be present in the specification. That is, the disclosure must provide sufficient details such that one of ordinary skill in the art would recognize the claimed invention as providing an improvement. The specification need not explicitly set forth the improvement, but it must describe the invention such that the improvement would be apparent to one of ordinary skill in the art. Conversely, if the specification explicitly sets forth an improvement but in a conclusory manner (i.e., a bare assertion of an improvement without the detail necessary to be apparent to a person of ordinary skill in the art), the examiner should not determine the claim improves technology. – emphasis added. The specification does not provide any evidence that the claimed invention results in an improvement to the functioning of a computer, an improvement to conventional technology or technological processes, or is addressing a technology-based problem. Additionally, the specification does not provide any evidence that there is even a technical (i.e., technology-based) problem to be solved. For example, the specification does not provide any evidence that existing technology was incapable of performing the claimed functions but for the claimed technical solution as in McRo. Applicant further argues: Akin to Bascom 's finding of a non-conventional and non-generic arrangement of known conventional pieces, the non-conventional and non-generic arrangement of the processor of the gaming establishment credit system operating with the external cryptocurrency blockchain network enables the unconventional solution of utilizing a gaming establishment controlled custodian account while ensuring that the control of the cryptocurrency remains that of the gaming establishment credit system. Such an unconventional solution effectuates, amongst the previously described technical benefits, the reduced reliance on cash (and the multitude of operational and health problems associated therewith) which collectively rise to the level found in Bascom to be significantly more than an abstract idea. See Arguments, p. 9. The Examiner respectfully disagrees. The court in Bascom Global Internet Services v. AT&T Mobility, LLC (Fed. Cir. 2016) stated: However, we disagree with the district court's analysis of the ordered combination of limitations. In light of Mayo and Alice , it is of course now standard for a § 101 inquiry to consider whether various claim elements simply recite “well-understood, routine, conventional activit[ies].” Alice , 134 S. Ct. at 2359. The district court's analysis in this case, however, looks similar to an obviousness analysis under 35 U.S.C. §103, except lacking an explanation of a reason to combine the limitations as claimed. The inventive concept inquiry requires more than recognizing that each claim element, by itself, was known in the art. As is the case here, an inventive concept can be found in the non-conventional and non-generic arrangement of known, conventional pieces. See Bascom Global Internet Services v. AT&T Mobility, LLC , 119 USPQ2d 1236, 1242 (Fed. Cir. 2016). Alice established that a §101 analysis requires consideration whether the individual claim elements (i.e., the computerized activity) is more than "well-understood, routine, conventional" activities. Bascom stated that the §101 analysis requires more than just analyzing each claim element, by itself, in isolation, but should also consider the claim elements in combination, as the “inventive concept can be found in the non-conventional and non-generic arrangement of known, conventional pieces.” The claimed invention in the instant case recites performance of a series of well-understood, routine and conventional computerized activities, such as making determinations (i.e., performing computations) and locking funds (i.e., preventing transfers of funds). While the claimed invention employs these well-understood, routine and conventional computer functions to a particular end, such as making determinations pertaining to a specific type of data (e.g., cryptocurrency or custodian account balances), the underlying computer functions are still well-understood, routine and conventional computerized activities. Viewing the claim elements, as an ordered combination, does not reveal a "non-conventional and non-generic arrangement of known, conventional pieces” but rather a conventional and generic arrangement of well-understood, routine and conventional computerized functions. Additionally, DDR Holdings, LLC v. Hotels.com , the U.S. Court of Appeals stated: As an initial matter, it is true that the claims here are similar to the claims in the cases discussed above in the sense that the claims involve both a computer and the Internet. But these claims stand apart because they do not merely recite the performance of some business practice known from the pre-Internet world along with the requirement to perform it on the Internet. Instead, the claimed solution is necessarily rooted in computer technology in order to overcome a problem specifically arising in the realm of computer networks . See DDR Holdings, LLC v. Hotels.com , 113 USPQ2d 1097, 1106 (Fed. Cir. 2014) – emphasis added. In the instant case, the asserted problem that the claimed invention is designed to overcome, to reduce reliance on cash (and the multitude of operational and health problems associated therewith), is not a problem specifically arising from the realm of computers. This problem is a standard business problem that exists outside the realm of computers and existed before the age of computers. The court in Electric Power Group LLC v. Alstom SA (Fed. Cir. 2016) stated: The claims here are unlike the claims in Enfish . There, we relied on the distinction made in Alice between, on one hand, computer-functionality improvements and, on the other, uses of existing computers as tools in aid of processes focused on “abstract ideas” (in Alice , as in so many other § 101 cases, the abstract ideas being the creation and manipulation of legal obligations such as contracts involved in fundamental economic practices). Enfish , 822 F.3d at 1335-36; see Alice, 134 S. Ct. at 2358-59. That distinction, the Supreme Court recognized, has common-sense force even if it may present line-drawing challenges because of the programmable nature of ordinary existing computers. In Enfish, we applied the distinction to reject the § 101 challenge at stage one because the claims at issue focused not on asserted advances in uses to which existing computer capabilities could be put, but on a specific improvement—a particular database technique—in how computers could carry out one of their basic functions of storage and retrieval of data. Enfish, 822 F.3d at 1335-36; see Bascom, 2016 U.S. App. LEXIS 11687, 2016 WL 3514158, at *5; cf. Alice, 134 S. Ct. at 2360 (noting basic storage function of generic computer). The present case is different: 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. see Electric Power Group LLC v. Alstom SA , 119 USPQ2d 1739, 1742 (Fed. Cir. 2016) – emphasis added. The claimed invention is not an improvement to computer technology or computer functionality. Rather, the claimed invention is applying a computer’s existing capabilities to implement a particular abstract idea. As in Electric Power Group , the focus of the claimed invention is not on an improvement in computers as tools but on improving an abstract idea (i.e., preventing a user reclaiming the pledged collateral without paying back the line of credit) that uses computers as tools. MPEP §2106.04(d) recites: The courts have also identified limitations that did not integrate a judicial exception into a practical application: Merely reciting the words “apply it” (or an equivalent) with the judicial exception, or merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea, as discussed in MPEP § 2106.05(f); [and] Generally linking the use of a judicial exception to a particular technological environment or field of use, as discussed in MPEP § 2106.05(h). Examiner asserts that the additional elements amount to merely (1) including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea, or alternatively, (2) merely links the use of a judicial exception to a particular technological environment or field of use. §103 Rejection Applicant argues that the previously asserted prior art (Nelson and Upadrasta) fail to teach or suggest the claimed invention. See Arguments, pp. 10-12. Specifically, Applicant argues: Applicant respectfully disagrees and submits that while Nelson includes a processor locking an asset in a blockchain-based database by establishing a locked asset value for the asset and preventing exchange of the asset by an asset owner and further includes the processor generating a loan value for the asset less than the locked asset value (see Abstract) and while Nelson includes a liquidity protocol for a repayment of the loan within a specified amount of time (see paragraph [0062]), Nelson does not continue to maintain the locked asset in the blockchain-based database after the specified amount of time. Rather, Nelson specifies that "[i]f the value of the collateral drops further, and/or if the necessary assets or funds are not contributed in time, at 310, liquidity protocol 120 may sell all or a portion of the collateral and may assess a penalty incurred by the original owner" (see paragraph [0064]). As such, Nelson includes selling the asset pledged as collateral as part of a liquidity protocol and not continuing with the lock of that asset. See Arguments, p. 10. The Examiner respectfully disagrees. Nelson recites: At 306, liquidity protocol 120 may determine that repayment of the issued Bridgecoin(s) is due. For example, in some cases, users may be required repay the liquidity they received from the collateral vault within a specified amount of time. The amount repaid, the liability, may be slightly higher than the liquidity generated based on an associated interest agreed upon during the inception of the loan. This may ensure that the operation and maintenance of the system are economically well-supported. The additional liability may also incentivize responsible use of the system at a fraction of the cost of traditional interest rates. In other example cases, certain types of collateral such as cryptocurrencies or stocks may significantly fluctuate in value. Liquidity protocol 120 may monitor one or more network 100 sources of collateral value data (e.g., stock and/or currency market exchanges) to detect changes in collateral value. In such cases, when the value of the collateral in the vault drops below a certain threshold called the notice line, server device 102 may notify the user that they are approaching the point where their assets are at risk of being sold. To address this, the user may contribute additional collateral to the Asset Vault or pay down their liability with Bridgecoin to make up the difference. If repayment is received in a timely fashion, at 308, liquidity protocol 120 may burn (e.g., destroy) the issued Bridgecoin. Burning a coin may remove it from circulation and thus may reduce the number of Bridgecoins in the market, maintaining a balance between collateral and Bridgecoin and ensuring the stability of the asset-backed cryptocurrency. If the value of the collateral drops further, and/or if the necessary assets or funds are not contributed in time, at 310, liquidity protocol 120 may sell all or a portion of the collateral and may assess a penalty incurred by the original owner. The threshold below which the value of the collateral indicates a required sale, called the sell line, may be set differently for different collateral asset types depending on their risk and volatility parameters, as described in detail below. Users may be allowed to set their sell line at any value above a required minimum. This may prevent correlated large scale sell events that could otherwise introduce instability into the system. See para. 62-64 – emphasis added. Nelson discloses a method wherein a lock is maintained on the cryptocurrency (i.e., the cryptocurrency is not returned to the identified user) after the specified time, as the cryptocurrency is sold if an amount is owed on the line of credit (i.e., Bridgecoin) after the specified time. See para. 62-64. Applicant further argues: Applicant submits that since Nelson lacks any disclosure of any gaming establishment or any casinos (and, as acknowledged by the Office, lacks "a gaming establishment-controlled custodian account"), the loan of Nelson is not a gaming establishment line of credit made available by a gaming establishment credit system. Upadrasta does not cure these deficiencies of Nelson because, as mentioned above, Upadrasta is silent regarding any lines of credit being offered in exchange for an incoming cryptocurrency being pledged. Without any lines of credit (and thus without any gaming establishment lines of credit), Upadrasta fails to include a gaming establishment credit system that determines if any portion of the amount of available funds is owed on the absent gaming establishment line of credit when a conclusion of a limited duration associated with the gaming establishment line of credit is reached and then either releases or maintains a placed lock on the incoming cryptocurrency accordingly. See Arguments, pp. 10-11 – emphasis added. The Examiner respectfully disagrees. The title of the entity that offers or controls the line of credit, whether a gaming establishment, a credit card company or a bank, does not differentiate the claimed invention from the prior art. The entity, regardless of the categorization of its line of business, is an entity that is extending a line of credit to a user based upon cryptocurrency being used as collateral. Regardless, Upadrasta claims: 1. A method of operating a casino gaming system, the casino gaming system comprising one or more servers connected via a network, the one or more servers comprising an API service, a transfer wallet, a bridge service, a player's unified wallet and a casino main wallet, the method comprising : via the bridge service: detecting presence of cryptocurrency in the transfer wallet; withdrawing the cryptocurrency from the transfer wallet; depositing the cryptocurrency into the casino main wallet; computing a current cash value of the cryptocurrency; and depositing credits equivalent to the current cash value into the player's unified wallet. Upadrasta discloses a method comprising a gaming establishment (i.e., a casino) issuing credits in exchange for incoming cryptocurrency and the cryptocurrency being deposited in a gaming establishment controlled account (i.e., a casino main wallet). See Claim 1. Admittedly, Upadrasta does not teach a method wherein the credit is a credit from a line of credit (i.e., a loan) based upon the incoming cryptocurrency. However, "one cannot show non-obviousness by attacking references individually where, as here, the rejections are based on combinations of references." See MPEP §2145(IV), citing In re Keller, Terry, and Davies , 208 USPQ 871, 882 (CCPA 1981). In the instant case, applicant refutes each prior art reference individually, rather than viewing them in combination, in light of the totality of their combined teachings. 9. Conclusion 07-40 AIA 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 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 JASON M. BORLINGHAUS whose telephone number is (571)272-6924. The examiner can normally be reached M-F 9-5. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, RYAN D. DONLON can be reached at (571)270-3602. The fax phone number for the organization where this application or proceeding is assigned 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. /Jason M. Borlinghaus/Primary Examiner, Art Unit 3692 May 29, 2026 Application/Control Number: 18/208,740 Page 2 Art Unit: 3692 Application/Control Number: 18/208,740 Page 3 Art Unit: 3692 Application/Control Number: 18/208,740 Page 4 Art Unit: 3692 Application/Control Number: 18/208,740 Page 5 Art Unit: 3692 Application/Control Number: 18/208,740 Page 6 Art Unit: 3692 Application/Control Number: 18/208,740 Page 7 Art Unit: 3692 Application/Control Number: 18/208,740 Page 8 Art Unit: 3692 Application/Control Number: 18/208,740 Page 9 Art Unit: 3692 Application/Control Number: 18/208,740 Page 10 Art Unit: 3692 Application/Control Number: 18/208,740 Page 11 Art Unit: 3692 Application/Control Number: 18/208,740 Page 12 Art Unit: 3692 Application/Control Number: 18/208,740 Page 13 Art Unit: 3692 Application/Control Number: 18/208,740 Page 14 Art Unit: 3692 Application/Control Number: 18/208,740 Page 15 Art Unit: 3692
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