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 .
Status of Claims
This action is in reply to the response filed on March 11, 2026.
Claim(s) 1-14 are currently pending and have been examined.
This action is made Non-Final.
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.
Claim(s) 1-14 is/are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Claim(s) 1-8 are directed to a system, method, or product, which are/is one of the statutory categories of invention. (Step 1: YES).
The Examiner has identified independent system claim 1 as the claim that represents the claimed invention for analysis. Claim 1 recites the following limitations:
[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 claim data associated with a user registered to participate in an acceleration transaction program;
identify a plurality of attributes from the claim data and user account data associated with the user;
predict that a claim will be approved [by a claim payment provider] by applying a first set of the plurality of attributes [to a payment prediction model];
estimate an amount for a claim payment by applying a second set of the plurality of attributes [to an amount prediction model];
determine to accelerate a payment of the claim based at least in part on the estimated amount; and
initiate an accelerated claim transaction that credits a transaction account associated with the user with an accelerated transaction amount that is based at least in part on the estimated amount.
These limitations, under their broadest reasonable interpretation, cover performance of the limitation as certain methods of organizing human activity because the limitations recite a commercial or legal interaction. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation as a commercial or legal interaction, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea. The computing device comprising a processor and a memory, payment prediction model, and amount prediction model in Claim 1 are just applying generic computer components to the recited abstract limitations. The recitation of generic computer components in a claim does not necessarily preclude that claim from reciting an abstract idea. (Step 2A-Prong 1: YES. The claims recite an abstract idea)
This judicial exception is not integrated into a practical application. In particular, the claims recite the additional elements of a computing device comprising a processor and a memory, a payment prediction model, and an amount prediction model. The computer hardware/software is/are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function) such that it amounts to no more than mere instructions to apply the exception using a generic computer component. 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. Therefore, claim 1 is directed to an abstract idea without a practical application. (Step 2A-Prong 2: NO. The additional claimed elements are not integrated into a practical application)
The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when considered separately and as an ordered combination, they do not add significantly more (also known as an “inventive concept”) to the exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional element of using computer hardware amounts to no more than mere instructions to apply the exception using a generic computer component. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Accordingly, these additional elements do not change the outcome of the analysis when considered separately and as an ordered combination. Thus, claim 1 is not patent eligible. (Step 2B: NO. The claims do not provide significantly more)
Dependent claims 2-4, 6, and 7 further define the abstract idea that is present in independent claim 1 and thus correspond to certain methods of organizing human activity and hence are abstract for the reasons presented above. Dependent claims 2-4, 6, and 7 do not include any additional elements that integrate the abstract idea into a practical application or are sufficient to amount to significantly more than the judicial exception when considered both individually and as an ordered combination. Therefore, dependent claims 2-7 are directed to an abstract idea.
Claim 8 includes the additional limitations of a claim management computing device and a claim management entity. The additional limitations do not integrate the judicial exception into a practical application because the additional limitations are recited at a high level of generality and do not impose any meaningful limits on practicing the abstract idea. Therefore, dependent claim 8 is directed to an abstract idea.
Thus, claim(s) 1-8 are not patent-eligible.
Claim(s) 9-14 are directed to a system, method, or product, which are/is one of the statutory categories of invention. (Step 1: YES).
The Examiner has identified independent method claim 9 as the claim that represents the claimed invention for analysis. Claim 9 recites the following limitations:
generating a plurality of attributes based at least in part on an analysis of claim event data associated with a user registered to participate in an accelerated transaction program;
applying a first set of the plurality of attributes [to a payment prediction model];
predicting that an approved claim transaction will be initiated [by a claim payment provider] based at least in part on a comparison of a payment prediction score that is output from the payment prediction model with a predefined threshold;
applying a second set of the plurality of attributes [to a payment amount model], an output [of the payment amount model] comprising an estimated amount of the approved claim transaction;
and initiating a user with an accelerated transaction amount based at least in part on the estimated amount.
These limitations, under their broadest reasonable interpretation, cover performance of the limitation as certain methods of organizing human activity because the limitations recite commercial or legal interactions. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation as a commercial or legal interaction, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea. The payment prediction model, claim payment provider, and payment amount model in Claim 1 are just applying generic computer components to the recited abstract limitations. The recitation of generic computer components in a claim does not necessarily preclude that claim from reciting an abstract idea. (Step 2A-Prong 1: YES. The claims recite an abstract idea)
This judicial exception is not integrated into a practical application. In particular, the claims recite the additional elements of a payment prediction model, a claim payment provider, and a payment amount model. The computer hardware/software is/are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function) such that it amounts to no more than mere instructions to apply the exception using a generic computer component. 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. Therefore, claim 9 is directed to an abstract idea without a practical application. (Step 2A-Prong 2: NO. The additional claimed elements are not integrated into a practical application)
The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when considered separately and as an ordered combination, they do not add significantly more (also known as an “inventive concept”) to the exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional element of using computer hardware amounts to no more than mere instructions to apply the exception using a generic computer component. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Accordingly, these additional elements do not change the outcome of the analysis when considered separately and as an ordered combination. Thus, claim 9 is not patent eligible. (Step 2B: NO. The claims do not provide significantly more)
Dependent claims 12-14 further define the abstract idea that is present in independent claim 9 and thus correspond to certain methods of organizing human activity and hence are abstract for the reasons presented above. Dependent claims 12-14 do not include any additional elements that integrate the abstract idea into a practical application or are sufficient to amount to significantly more than the judicial exception when considered both individually and as an ordered combination. Therefore, dependent claims 12-14 are directed to an abstract idea.
Claim 10 includes the additional limitations of a claim management computing device and a claim management entity. The additional limitations do not integrate the judicial exception into a practical application because the additional limitations are recited at a high level of generality and do not impose any meaningful limits on practicing the abstract idea. Therefore, dependent claim 10 is directed to an abstract idea.
Claim 11 includes the additional limitations of a client device associated with the user, a claim management computing device, and a claim management entity. The additional limitations do not integrate the judicial exception into a practical application because the additional limitations are recited at a high level of generality and do not impose any meaningful limits on practicing the abstract idea. Therefore, dependent claim 11 is directed to an abstract idea.
Thus, claim(s) 9-14 are not patent-eligible.
Claim Rejections - 35 USC § 103
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.
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.
The factual inquiries set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied 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.
Claims 1, 2, 4, 5, and 8 are rejected under 35 U.S.C. 103 as being unpatentable over Rosanwo (US 2023/0075217) in view of Krishnan (US 20200104940) in view of Hayward (US 20210287297).
Regarding claim(s) 1:
Rosanwo teaches:
a computing device comprising a processor and a memory; and (Rosanwo: pgh 107, “As depicted, the illustrative computerized device may include a processor, memory, a bus or other internal communication system…”)
machine-readable instructions stored in the memory that, when executed by the processor, cause the computing device to at least: receive claim data associated with a user registered to participate in an acceleration transaction program; (Rosanwo: pgh 8, “The method may include retrieving datasets via a computer communications network…”)
determine to accelerate a payment of the claim based at least in part on the estimated amount; and (Rosanwo: pgh 11, “This may include substantially automatically executing the self-executing contract, substantially automatically disbursing funds for the payout defined by the smart contract to the user, and recording the disbursement…”)
initiate an accelerated claim transaction that credits a transaction account associated with the user with an accelerated transaction amount that is based at least in part on the estimated amount. (Rosanwo: pgh 89, “The smart contract or other self-executing contract may then be executed, which may initiate the payout process to fund the policyholder…”)
Rosanwo does not teach, however, Krishnan teaches:
predict that a claim will be approved by a claim payment provider by applying a first set of the plurality of attributes to a payment prediction model; (Krishnan: pgh 15, “Thus, based on previous data, the artificial intelligence (AI)-based model can help the insurer and the insured predict the category of insurance claim eligible for, repair time and costs for fixing the damage.”)
estimate an amount for a claim payment by applying a second set of the plurality of attributes to an amount prediction model; (Krishnan: pgh 16, “The system provides a structured methodology to collect the images of damaged cars from the car owner and to predict, using historical insurance claim data, the payout to be borne by the insurer.”)
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to have modified Rosanwo to include the teachings of Krishnan because it is beneficial to “help insurance companies process claims faster” (Krishnan: pgh 12). Rosanwo/Krishnan does not teach, however, Hayward teaches:
identify a plurality of attributes from the claim data and user account data associated with the user; (Hayward: pgh 195, “…the same attributes respective to the user claim may be provided as inputs to the neural network…by applying the user claim to the neural network…”)
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to have modified Rosanwo/Krishnan to include the teachings of Hayward to improve a system where “Accurate loss reserves prediction historically may be a manual process in which actuaries or other financial scientists manually review claims and make guesses as to the final loss amounts associated with those claims” (Hayward: pgh 22).
Regarding claim(s) 2:
The combination of Rosanwo/Krishnan/Hayward, as shown in the rejection above, discloses the limitations of claim 1. Hayward further teaches:
wherein the plurality of attributes comprise at least one of a user history, a payment history, a claim event type, diagnosis data, claim event data, an event length, user data, claim payment provider data, or a seasonality. (Hayward: pgh 195, “A plurality of attributes of claims (e.g., payments, type of loss, policy deductible etc.) may be used to train the neural network…”)
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to have modified Rosanwo/Krishnan to include the teachings of Hayward to improve a system where “Accurate loss reserves prediction historically may be a manual process in which actuaries or other financial scientists manually review claims and make guesses as to the final loss amounts associated with those claims” (Hayward: pgh 22).
Regarding claim(s) 4:
The combination of Rosanwo/Krishnan/Hayward, as shown in the rejection above, discloses the limitations of claim 1. Rosanwo further teaches:
wherein the accelerated claim transaction comprises a first accelerated claim transaction and, when executed, the machine-readable instructions further cause the computing device to at least: determine that the claim payment provider has approved the claim; and initiate a second accelerated claim transaction that debits the accelerated transaction amount from the transaction account. (Rosanwo: pgh 24, “The system may monitor for occurrence of the triggers defined by the self-executing contract and, upon detection of the occurrence of the triggers, disbursing a payout by performing the steps of substantially automatically executing the self-executing contract, substantially automatically disbursing funds for the payout defined by the self-executing contract to the user, and recording the disbursement to the data storage structure.”; pgh 31, “…the data storage structure may be or include a distributed ledger…”)
Regarding claim(s) 5:
The combination of Rosanwo/Krishnan/Hayward, as shown in the rejection above, discloses the limitations of claim 1. Anderson further teaches:
wherein the accelerated claim transaction comprises a first accelerated claim transaction and, when executed, the machine-readable instructions further cause the computing device to at least: determine that the claim has failed to be approved by the claim payment provider within a predefined period of time; and (Anderson: pgh 189, “Alternatively, the rules engine may indicate a claim is deficient or otherwise likely to be unpaid or rejected. Failed claims amay not be transmitted for payment…”)
initiate a second accelerated claim transaction that debits the accelerated transaction amount from the transaction account. (Anderson: pgh 189, “the claim scrubber system may allow for the claim to be manually, or in some instances, automatically fixed…to become a new claim to be re-analyzed and processed by the rules engine.”)
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to have modified Rosanwo/Krishnan/Hayward to include the teachings of Anderson to “…address numerous challenges, hurdles, inefficiencies, incompatibilities, and other ‘bottlenecks’ that are faced by patients, dental offices, and insurers” (Anderson: pgh 22).
Regarding claim(s) 8:
The combination of Rosanwo/Krishnan/Hayward, as shown in the rejection above, discloses the limitations of claim 1. Rosanwo further teaches:
wherein the claim data associated with the user is received from a claim management computing device associated with a claim management entity, the claim management entity being an intermediary between the user and the claim payment provider. (Rosanwo: pgh 56, “…external computer systems and data sources may use an application programming interface (API) to send and receive requests for information and return the information being requested.”)
Claim 6 is rejected under 35 U.S.C. 103 as being unpatentable over Rosanwo (US 2023/0075217) in view of Krishnan (US 20200104940) in view of Hayward (US 20210287297) in view of Nobuaki (US 2023/0260042).
Regarding claim(s) 6:
The combination of Rosanwo/Krishnan/Hayward, as shown in the rejection above, discloses the limitations of claim 1. Nobuaki (US 2023/0260042) further teaches:
wherein, when executed, the machine-readable instructions further cause the computing device to at least: generate a notification indicating the accelerated claim transaction has been completed in response to crediting the transaction account of the user; and transmit the notification to a client device associated with the user. (Nobuaki: pgh 55, “The benefit information of the insurance money includes at least one of…a notice that the insurance money has been paid.”)
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to have modified Rosanwo/Krishnan/Hayward to include the teachings of Nobuaki to “reduce the burden of taking procedures regarding medical insurance” (Nobuaki: pgh 12).
Claim 7 is rejected under 35 U.S.C. 103 as being unpatentable over Rosanwo (US 2023/0075217) in view of Krishnan (US 20200104940) in view of Hayward (US 20210287297) in view of Yang (US 2005/0033609).
Regarding claim(s) 7:
The combination of Rosanwo/Krishnan/Hayward, as shown in the rejection above, discloses the limitations of claim 1. Yang further teaches:
wherein, when executed, the machine-readable instructions further cause the computing device to at least: identify a credit limit associated with a registered participant account associated with the user; and (Yang: pgh 73, “The second, patient-accessible maximum credit limit is disclosed to the patient as his or her credit limit for the HTP account…”)
determine that the estimated amount exceeds the credit limit, the accelerated transaction amount that is credited to transaction account being based at least in part on the credit limit. (Yang: pgh 10, “…because the credit card company automatically denies the charge if it causes the account balance for the credit/debit cards to exceed the maximum credit limit…”)
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to have modified Rosanwo/Krishnan/Hayward to include the teachings of Yang to “…effectively guarantee payments for the patient-responsible portion of the healthcare expenses” (Yang: pgh 15).
Claims 9-11, 13, and 14 are rejected under 35 U.S.C. 103 as being unpatentable over Rosanwo (US 2023/0075217) in view of Krishnan (US 20200104940) in view of Anderson (US 2023/0140931).
Regarding claim(s) 9:
Rosanwo teaches:
generating a plurality of attributes based at least in part on an analysis of claim event data associated with a user registered to participate in an accelerated transaction program; (Rosanwo: pgh 8, “The method may include retrieving datasets via a computer communications network…”)
and initiating a user with an accelerated transaction amount based at least in part on the estimated amount. (Rosanwo: pgh 89, “The smart contract or other self-executing contract may then be executed, which may initiate the payout process to fund the policyholder…”)
Rosanwo does not teach, however, Krishnan teaches:
applying a first set of the plurality of attributes to a payment prediction model; (Krishnan: pgh 15, “Thus, based on previous data, the artificial intelligence (AI)-based model can help the insurer and the insured predict the category of insurance claim eligible for, repair time and costs for fixing the damage.”)
applying a second set of the plurality of attributes to a payment amount model, an output of the payment amount model comprising an estimated amount of the approved claim transaction; (Krishnan: pgh 16, “The system provides a structured methodology to collect the images of damaged cars from the car owner and to predict, using historical insurance claim data, the payout to be borne by the insurer.”)
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to have modified Rosanwo to include the teachings of Krishnan because it is beneficial to “help insurance companies process claims faster” (Krishnan: pgh 12). Rosanwo/Krishnan does not teach, however, Anderson teaches:
predicting that an approved claim transaction will be initiated by a claim payment provider based at least in part on a comparison of a payment prediction score that is output from the payment prediction model with a predefined threshold; (Anderson: pgh 201, “The outcome of the rules engine predicts the likelihood that the claim will be submitted. Claims that are determined to have a high likelihood of a poor outcome may be fixed…and reprocessed. Claims that pass the analysis by the rule engine and are associated with a positive outcome prediction are transmitted for payment…”)
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to have modified Rosanwo/Krishnan to include the teachings of Anderson to “…address numerous challenges, hurdles, inefficiencies, incompatibilities, and other ‘bottlenecks’ that are faced by patients, dental offices, and insurers” (Anderson: pgh 22).
Regarding claim(s) 10:
The combination of Rosanwo/Krishnan/Anderson, as shown in the rejection above, discloses the limitations of claim 9. Rosanwo further teaches:
receiving the claim event data from a claim management computing device associated with a claim management entity, the claim management entity being an intermediary between the user and the claim payment provider. (Rosanwo: pgh 56, “…external computer systems and data sources may use an application programming interface (API) to send and receive requests for information and return the information being requested.”)
Regarding claim(s) 11:
The combination of Rosanwo/Krishnan/Anderson, as shown in the rejection above, discloses the limitations of claim 10. Rosanwo further teaches:
receiving consent from a client device associated with the user; and transmitting the consent to the claim management computing device, the consent allowing the claim management entity to provide the claim event data associated with the user. (Rosanwo: pgh 77, “In some examples, consent may be requested and/or required before data may be retrieved from a connected data source.”)
Regarding claim(s) 13:
The combination of Rosanwo/Krishnan/Anderson, as shown in the rejection above, discloses the limitations of claim 9. Rosanwo further teaches:
wherein the accelerated claim transaction comprises a first accelerated claim transaction, and further comprising initiating a second accelerated claim transaction to debit the accelerated transaction amount from a transaction account associated with the user in response to determining that a predefined period of time has elapsed since crediting the transaction account. (Rosanwo: pgh 86, “If a trigger is detected that requires a payout, the smart contract or other self-executing contract associated with the policy may be substantially automatically executed and funds for the payout delivered to the policyholder as per the terms of the policy. A record of the payout may be kept by at least part of the server…”)
Regarding claim(s) 14:
The combination of Rosanwo/Krishnan/Anderson, as shown in the rejection above, discloses the limitations of claim 9. Rosanwo further teaches:
wherein the accelerated claim transaction comprises a first accelerated claim transaction, and further comprising initiating a second accelerated claim transaction to debit the accelerated transaction amount from a transaction account associated with the user in response to determining that the claim payment provider has initiated the approved claim transaction. (Rosanwo: pgh 86, “If a trigger is detected that requires a payout, the smart contract or other self-executing contract associated with the policy may be substantially automatically executed and funds for the payout delivered to the policyholder as per the terms of the policy. A record of the payout may be kept by at least part of the server…”)
Claims 3 and 12 are rejected under 35 U.S.C. 103 as being unpatentable over Rosanwo (US 2023/0075217) in view of Krishnan (US 20200104940) in view of Anderson (US 2023/0140931) in view of Hayward (US 20210287297).
Regarding claim(s) 3:
The combination of Rosanwo/Krishnan/Hayward, as shown in the rejection above, discloses the limitations of claim 1. Anderson further teaches:
wherein an output of the payment prediction model comprises a probability score and, when executed, the machine-readable instructions further cause the computing device to at least compare the probability score with a threshold value, the claim predicted to be approved when the probability score fails to meet or exceed the threshold value. (Anderson: pgh 210, “The system of claim 8, wherein the claim analyzer subsystem is further configured to: identify the input dental insurance claim as a deficient dental insurance claim in response to a predicted payment outcome score below a threshold value…”)
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to have modified Rosanwo/Krishnan/Hayward to include the teachings of Anderson to “…address numerous challenges, hurdles, inefficiencies, incompatibilities, and other ‘bottlenecks’ that are faced by patients, dental offices, and insurers” (Anderson: pgh 22).
Regarding claim(s) 12:
The combination of Rosanwo/Krishnan/Anderson, as shown in the rejection above, discloses the limitations of claim 9. Hayward further teaches:
wherein the plurality of attributes comprise at least one of a user history, a payment history, a claim event type, diagnosis data, claim event data, an event length, user data, claim payment provider data, or a seasonality. (Hayward: pgh 195, “A plurality of attributes of claims (e.g., payments, type of loss, policy deductible etc.) may be used to train the neural network…”)
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to have modified Rosanwo/Krishnan/Anderson to include the teachings of Hayward to improve a system where “Accurate loss reserves prediction historically may be a manual process in which actuaries or other financial scientists manually review claims and make guesses as to the final loss amounts associated with those claims” (Hayward: pgh 22).
Conclusion
Pertinent Art
The prior art made of record and not relied upon is considered pertinent to Applicant’s disclosure. Behrens (US 11,928,737) discloses methods and apparatus to process insurance claims using artificial intelligence.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to JOHN O PRESTON whose telephone number is (571)270-3918. The examiner can normally be reached 9:00 am - 5:00 pm.
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/JOHN O PRESTON/Examiner, Art Unit 3698
May 26, 2026
/BRUCE I EBERSMAN/Primary Examiner, Art Unit 3693
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