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 .
The following is a Final Office Action in response to communications received December 29, 2025. Claim(s) 4 has been canceled. Claims 1, 8 and 15 have been amended. No new claims have been added. Therefore, claims 1-3 and 5-21 are pending and addressed below.
Priority
Application No. 18223476 filed 07/18/2023 is a Continuation of 16797992, filed 02/21/2020.
Applicant Name/Assignee: Mastercard International Incorporated
Inventor(s): Rohlfing, Patricia; Rohlfing, Joan Lee; Yog, Desh Deepak; Powell, Michael Scott
Response to Amendment/Arguments
Claim Interpretation
Applicant has affirmed the claim interpretation.
Claim Rejections - 35 USC § 101
Applicant's arguments filed 12/29/2025 have been fully considered but they are not persuasive.
In the remarks applicant points to MPEP 2106.04(II)(A) and MPEP 2016.04(a), with respect to the two step analysis for patent eligibility, arguing that under the step 2A prong 1, analysis the claimed subject matter is not abstract. Applicant argues the computing system claimed reduces processing resources required to process reversible (chargeback) electronic instructions by generating a single file substituted for a plurality of files. The single file is in a format that improves transmission of the single data file over a network and the readability of the single data file by computer resources in communication. Applicant argues the generating a single data file by aggregating and formatting data into standardized data format at least two types of reversible instructions non-concurrently identified and stored in at least one database where the single file substitutes a first data file including first type of reversible instructions, a second data file including second type of reversible instructions where the single data file includes first and second types of reversible instructions processed over a predetermined time. Although the claims do recite reversible (chargeback) instructions, the limitations do not recite chargeback transactions, instead they recite a computer process to expedite processing data and improving network bandwidth by generating a single computer data in standardize format. Applicant’s argument is not persuasive. The claim limitations recite “receive …data records associated with …data sets including identifiers…”, “identity …two types of reversible (chargeback) instructions …by matching …messages…for each data set …the first type corresponding to an invalid…message ”, “store…first type…reversible (chargeback) instructions…”, “identify, non-concurrently…second type of …reversible (chargeback) instructions…the second type of …reversible (chargeback) instructions include invalid identifier, invalid first message and flagged identifier”, “store…identified second type of …reversible (chargeback) instructions being in a second format”, “generate a single data file.. . the single data file includes…reversible (chargeback) instructions…the single data file substitutes a first data file including first type of …reversible (chargeback) instructions …and a second data file including the second type of …reversible (chargeback) instructions…”, “transmit …single data file …to …initiate reversal of at least first and second types of reversible (chargeback) instruction”. As a whole the claimed subject matter receives transaction related data, identifies and stores two types of chargeback instructions for instances which include invalid message (the specification ¶ 0051 describes an invalid authorization message or declined by issuer message, fraudulent, message without matching clearing message, processed transaction determined invalid) and second type of chargeback instructions (invalid identifier, invalid first message and flagged identifier). The identified messages are explicitly part of a transaction process that are stored and formatted for transmission to initiate chargeback instructions. Accordingly the claim limitations when considered as a whole are directed toward a transaction activity. The claimed system recites the claimed functions for the chargeback process at a high level of generality where the system claimed is merely applied as a tool to automate the chargeback transaction process. The rejection is maintained.
In the remarks applicant points to the USPTO Aug, 4, 2025 memo with respect to analysis for mental processes. Applicant is arguing a rejection not applied.
In the remarks applicant argues that as a whole the claimed subject matter under step 2A prong 2, integrate any alleged abstract idea into a practical application pointing to MPEP 2106.04(d)(I). Applicant argues the claimed system provides a solution to a problem rooted in technology (latency and inaccurate technical problems in computer systems for determining chargebacks). The limitations reduce processing resources request to process chargebacks by including an unconventional architecture to generate a single data file by aggregating and formatting into standardized format two types of chargeback instructions non-concurrently identified and stored. The single file to include data file including first and second type of chargeback instructions processed over time. The combining the hardware and performing steps provide technical improvement by determining eligible chargeback transaction, initiating chargeback transaction by combining all the chargeback instructions over a time period into one file such that the chargeback transactions can be sent in a single standardized file format reducing processing resources required and eliminating human interaction to determine and verify chargeback instructions. The examiner respectfully disagrees. Applicant did not invent the concept of collecting multiple chargeback messages/responses, and formatting the multiple messages/response into a batch of chargeback messages/response in a single communication to an electronic processing system (see US Pub No. 2021/0182866 A1 by Ajitraj et al- para 0107; US Pub No. 2020/0387902 A1 by Rohlfing et al-para 0002; US Pub No. 2018/0174147 A1 by Williams et al. (para 0050); US Pub No. 2014/0006264 A1 by Powell et al-para 0023. With respect to the argument that the claimed limitations “include an unconventional architecture to generate a single data file by aggregating and formatting into standardized format”, applicant’s argument is not supported by the claim limitations or the specification. The claim limitation recite basic computer components (system comprising a computer network to process data, at least one database comprising partitions to store records, at least one processor in communication with the at least one database the processor to perform the operations “store”, “identify …type of …reversible/chargeback instructions”, “generate a single file” and “transmit the …file”. The specification discloses the system and corresponding components as conventional…
[0023] The methods and systems directed to the AC computing device described herein may be implemented using computer programming or engineering techniques including computer software, firmware, hardware or any combination or subset thereof, wherein the technical effect may be achieved by performing at least one of the following steps: (i) receiving transaction data associated with a plurality of processed transactions, the transaction data including a plurality of account identifiers, a plurality of authorization messages, and a plurality of clearing messages associated with the plurality of processed transactions, (ii) matching the plurality of authorization messages with the respective plurality of clearing messages for each processed transaction of the plurality of processed transactions, (iii) identifying automatic chargeback-eligible transactions from the plurality of processed transactions by parsing the transaction data and by the matching of the authorization messages with the clearing messages, (iv) storing, in the at least one memory, the identified automatic chargeback-eligible transactions, (v) automatically initiating a chargeback transaction for each identified automatic chargeback-eligible transaction. “
[0027] As used herein, the term "database" may refer to either a body of data, a relational database management system (RDBMS), or to both. A database may include any collection of data including hierarchical databases, relational databases, flat file databases, object-relational databases, object oriented databases, and any other structured collection of records or data that is stored in a computer system The above examples are for example only, and thus, are not intended to limit in any way the definition and/or meaning of the term database…
[0028] The term processor, as used herein, may refer to central processing units, microprocessors, microcontrollers, reduced instruction set circuits (RISC), application specific integrated circuits (ASIC), logic circuits, and any other circuit or processor capable of executing the functions described herein.
Accordingly, the claim limitations and specification do not support applicant’s argument that the claimed limitations “include an unconventional architecture”
With respect to applicant’s argument that Applicant argues the claimed system provides a solution to a problem rooted in technology (latency and inaccurate technical problems in computer systems for determining chargebacks) by combining files into a single file is not supported in the specification. The specification is silent with respect to any problems found in latency as it relates to technology. Furthermore, the specification does not provide discussion errors in chargeback transactions is a problem within the technology itself rather that abstract issues such as invalid message (the specification ¶ 0051 describes an invalid authorization message or declined by issuer message, fraudulent, message without matching clearing message, processed transaction determined invalid) and second type of chargeback instructions (invalid identifier, invalid first message and flagged identifier). Applicant has not pointed out what problem is rooted within any of the underlying technology. The rejection is maintained.
In the remarks applicant argues that under step 2B, the claimed subject matter is patent eligible pointing to 2106.05(I)(A)(v), MPEP 2106.05(d) and MPEP 2106.05(d)(I)(3) when considering the additional elements which amount to significantly more that the alleged abstract idea. Applicant argues the aggregating and formatting of a two types of messages as a single file provides the additional element beyond the abstract idea. The examiner respectfully disagrees. As discussed above it is known in the art to aggregate transactions messages into a single batch file that is then transmitted. As evidence the examiner provides US Pub No. 2019/0236683 A1 by Anand et al –“The ability to handle large files allows the transformation and aggregation engine 110 process large incoming files, and to aggregate smaller messages and files for transmission to external systems operating in batch mode. For example, aggregation allows rule-based aggregation of messages to conform to external processor capacity. … The UPE 242a, 242b handles different file formats The transformation and aggregation engine 110 is configured to supports a variety of industry standard file formats (such as .XML, .EDI, .JSON, and .WFF, for example). The transformation and aggregation engine 110 maintains a consistent way of transforming the files irrespective of the data format.”; Us Pub No. 2006/0294148 A1 by Brunet -para 0010-0012; WO 2006/032045 A1 by Sellers et al-para 0121; WO 2006/026418 A2 by Krikorian et al-“the MS gateway 170a is the gateway through which authorization and settlement for purchasing card transactions are preferably processed. This processing is may be fulfilled in batch mode, wherein Level III transactions are accumulated and sent at periodic intervals to the MS gateway 170a in a standard data interchange format, for example, the 810 EDI format. The MS gateway 170a preferably splits the transactions based on a merchant identifier ("Merchant ID") in order to route the transactions to the appropriate locations. The MS gateway 170a preferably provides an authorization response back in a standard data interchange format, such as, for example, the 824 EDI format.”; US Pub No. 2019/0190857 A1 by Zhou et al- para 0027; FIG. 5; US Pub No. 2007/0234369 A1 by Parmisivam et al – para 0031; FIG. 2-3; Accordingly, the technical process of aggregating collected data/messages, converting the messages to a single format and then bundling to the messages into a batch file for a single transmission is well known and not significantly more the merely applying known technology to perform the abstract idea of transaction processing. The rejection is maintained.
Claim Interpretation
In light of the specification and prosecution history, the examiner is interpreting the following language of the claims to be:
receive data records [transaction data] associated with a plurality of data sets [transactions] processed over a predetermined time period by a computer network, the data records [transaction data] including a plurality of identifiers, a plurality of first electronic messages [authorization messages], and a plurality of second electronic messages [clearing messages] associated with the data sets [transactions];
The data records are analogous to transaction data as per the specification, the first electronic messages are analogous to authorization messages and the second messages are analogous to clearing messages.
identify a first type of at least two types of automatically-reversible electronic instructions [chargeback transactions] by matching, based on the plurality of identifiers, the plurality of first electronic [authorization] messages with the respective plurality of second [clearing] electronic messages for each data set [transaction] of the plurality of data sets [transactions], the first type corresponding to an invalid first electronic [authorization] message;
The language “automatically-reversible electronic instructions” is interpreted to be analogous to chargeback transactions, the term “identifiers” are identifiers relevant to the chargeback transactions.
This interpretation is maintained throughout the claim limitations and annotated in the rejection for clarification.
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 1-3 and 5-21 are rejected under 35 U.S.C. § 101 because the instant application is directed to non-patentable subject matter. Specifically, the claims are directed toward at least one judicial exception without reciting additional elements that amount to significantly more than the judicial exception. The rationale for this determination is in accordance with the guidelines of USPTO, applies to all statutory categories, and is explained in detail below.
In reference to claims 1-3, 5-7 and 21:
STEP 1. Per Step 1 of the two-step analysis, the claims are determined to include a system, as in independent Claim 1 and the dependent claims. Such systems fall under the statutory category of "machine." Therefore, the claims are directed to a statutory eligibility category.
STEP 2A Prong 1. The claimed invention is directed to an abstract idea without significantly more. System claim 1 recites functions to (1) receive data, (2) identify two types of charge-backs based on matching authorization and clearing messages for each transaction, (3) store data, (5) identify and parse charge-backs (6) store identified chargeback data, (7) generate a single file which includes aggregating data, formatting data and storing transaction data file, (8) transmit formatted data file. The claimed limitations which under its broadest reasonable interpretation, covers performance
when considered as a whole the claimed subject matter is directed toward a transaction process for risk mitigation. This is because the claimed limitations are directed toward a chargeback process for determining valid chargebacks. The specification discloses that the focus of invention is to provide a system for initiating chargeback transactions from a plurality of processed transaction based on satisfying rules/requirements in order to identify certain transaction as being automatic charge-back eligible transactions. (para 0005). The specification discloses identifying first and second types of messages (chargeback messages) where the first type of message is invalid and second type includes invalid identifier, that is stored and formatting the two types in a standard format as a single data file that is transmitted.(para 0006). Accordingly the specification makes clear that the focus of the invention is to parse chargeback messages for analysis in order to determine invalid message and identifiers message, where the determined invalid message and invalid identifier message are stored as a single file and transmitted for use in a chargeback transaction activity. Which when considered in light of abstract subject matter is directed toward commercial activity and risk mitigation.
Such concepts can be found in the abstract category of fundamental economic practices, commercial interactions and sales activity. These concepts are enumerated in Section I of the 2019 revised patent subject matter eligibility guidance published in the federal register (84 FR 50) on January 7, 2019) is directed toward abstract category of methods of organizing human activity.
STEP 2A Prong 2: The identified judicial exception is not integrated into a practical application because the claims recite an operations by a system to process reversible/chargeback instructions by generating a single file, the computer system comprising a computer network applied to process data for exchange between devices, a database comprising partitions having a plurality of fields for the intended use to store data, and a processor to perform the operations of the abstract idea. The processor is applied to perform at a high level the functions receive and transmit data lacking technical description and thus is directed toward insignificant extra solution activity. The processor claimed is applied to perform at a high level the functions “identify first type of two types of reversible/chargeback instructions by matching messages”, “identify non-concurrently with first type irreversible/chargeback instruction which include invalid identifier, invalid first message and/or flagged identifier”, “generate a single data file by aggregating and formatting two types of reversible/chargeback instructions” which is directed toward data analysis and manipulation. The processor claimed recites high level functions without technical details of “store…first type of reversible/chargeback instructions” and “store…second type of reversible/chargeback instructions”- which is a process directed toward a transaction record keeping process.
Taking the claim elements separately, the operation performed by the system at each step of the process is purely in terms of results desired and devoid of implementation of details. This is true with respect to the limitations “recited” as the claimed limitations do not provide any details on the technology or technical processes to perform the recited functions. For data, mere “manipulation” of basic mathematical constructs [i.e.,] the paradigmatic ‘abstract idea,’" has not been deemed a transformation. CyberSource v. Retail Decisions, 654 F.3d 1366, 1372 n.2, 99 USPQ2d 1690, 1695 n.2 (Fed. Cir. 2011) (quoting In re Warmerdam, 33 F.3d 1354, 1355, 1360 (Fed. Cir. 1994). Whether the transformation is extra-solution activity or a field-of-use (i.e., the extent to which (or how) the transformation imposes meaningful limits on the execution of the claimed method steps). A transformation that contributes only nominally or insignificantly to the execution of the claimed method (e.g., in a data gathering step or in a field-of-use limitation) would not provide significantly more (or integrate a judicial exception into a practical application). Mayo, 566 U.S. at 76, 101 USPQ2d at 1967. The Supreme Court disagreed, finding that this step was only a field-of-use limitation and did not provide significantly more than the judicial exception. Id. See MPEP § 2106.05(g) & (h).
When considered as a in part as a whole the combination of limitations 1-3 and 4-6 is to analyze and store received data which not directed toward indications of patent eligibility under step 2A prong 2, but rather a transaction process where a processor is applied as a tool to implement the abstract idea. The combination of limitations 1-6 and 7-8 is directed toward generating a file by combining the first and second types reversible/chargeback instructions and corresponding data of limitations 1-6 into a file that is then transmitted to initiate a transaction process. When considered as a whole the claimed limitations merely apply a processor to automate the reception of transaction data that is analyzed, stored and then the results of the analysis are combined/aggregated into a single files which contains the first and second types of reversible/chargeback instructions and corresponding data and then transmitted for use in initiating a transaction.
The functions are is recited at a high-level of generality such that it amounts to no more than applying the exception using generic computer components. Technology is not integral to the process as the claimed subject matter is so high level that any generic programming could be applied and the functions could be performed by any known means. Furthermore, the claimed functions do not provide an operation that could be considered as sufficient to provide a technological implementation or application of/or improvement to this concept (i.e. integrated into a practical application).
The combinations of parts is not directed toward any technical process or technological technique or technological solution to a problem rooted in technology. Although the abstract idea is dependent upon the ordered combination, the recited functions are independent and not a combination to enact a specific technical process. For example the match function is not dependent upon the receive function nor is the identify function dependent upon the match function such as found in BASCOM, where the filtering process was dependent upon the ordered combination. In addition, when the claims are taken as a whole, as an ordered combination, the claimed functions are directed toward a transaction process. The combination of steps does not add any indications of patent eligibility under step 2A prong 2, by virtue of considering the steps as a whole, as an ordered combination. This is because the claimed subject matter fails to provide additional elements or combination or elements to apply or use the judicial exception in a manner that imposes a meaningful limit on the judicial exception. The functions recited in the claims recite the concept of receive data, match authorization data, identify eligible transaction, aggregate, format and store eligible transaction data and transmitting organized data which is a process directed toward a business practice of data manipulation for use in a transaction process. The collection and manipulation of data by formatting the data into a standardized format function is high level lacking technical disclosure without any details as to technical implementation. The data manipulation fails to change the operation of the underlying technology in any way. The integration of elements do not improve upon technology or improve upon computer functionality or capability in how computers carry out one of their basic functions. The integration of elements do not provide a process that allows computers to perform functions that previously could not be performed. The integration of elements do not provide a process which applies a relationship to apply a new way of using an application. The instant application, therefore, still appears only to implement the abstract idea to the particular technological environments apply what generic computer functionality in the related arts. The steps are still a combination made to manipulate received data for a transaction process and does not provide any of the determined indications of patent eligibility set forth in the 2019 USPTO 101 guidance. The additional steps only add to those abstract ideas using generic functions, and the claims do not show improved ways of, for example, a particular technical function for performing the abstract idea that imposes meaningful limits upon the abstract idea. Moreover, Examiner was not able to identify any specific technological processes that goes beyond merely confining the abstract idea in a particular technological environment, which, when considered in the ordered combination with the other steps, could have transformed the nature of the abstract idea previously identified. Accordingly, this additional element does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. The claim is directed to an abstract idea.
STEP 2B; The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because as discussed above with respect to concepts of the abstract idea into a practical application. The additional elements recited in the claim beyond the abstract idea include a computing system applied at a high level to generate a file for communication in a transaction process comprising a computer network for use to process data sets for exchange between devices; at least one database having partitions of a plurality of fields for use in storing data records, and at least one processor in communication with at least one memory the processor performing a transaction and risk mitigation process by receive data, identify by matching, store, identify and parse data, store data, generate a single file by aggregating and formatting data, store single file data and transmit transaction data-–is purely functional and generic. Nearly every computer will include a system comprising a processor and memory capable of performing the functions of receive, match, identify, parse, store, generate single file by aggregating and formatting data and transmit transaction data. Taking the claim elements separately, the function performed by the computer at each step of the process is purely conventional. Using a computer system to perform the transaction process claimed ----are some of the most basic functions of a computer and therefore is not sufficient to provide significantly more than using technology to perform the abstract idea. All of these computer functions are generic, routine, conventional computer activities that are performed only for their conventional uses. See Elec. Power Grp. v. Alstom S.A., 830 F.3d 1350, 1353 (Fed. Cir. 2016). Also see In re Katz Interactive Call Processing Patent Litigation, 639 F.3d 1303, 1316 (Fed. Cir. 2011) Absent a possible narrower construction of the terms “receive”, “identify …by matching”, “store”, “generate single file”, “identify and parse data”, “format and store data” and “transmit” ... are functions can be achieved by any general purpose computer without special programming. None of the activities claimed in the claimed limitations of the application are used in some unconventional manner nor do any produce some unexpected result. In short, each step does no more than require a generic computer to perform generic computer functions. As to the data operated upon, "even if a process of collecting and analyzing information is 'limited to particular content' or a particular 'source,' that limitation does not make the collection and analysis other than abstract." SAP America, Inc. v. Invest Pic LLC, 898 F.3d 1161, 1168 (Fed. Cir. 2018). Considered as an ordered combination, the computer components of Applicant’s claimed functions add nothing that is not already present when the steps are considered separately. The sequence of data reception-analysis modification-transmission is equally generic and conventional. See Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709, 715 (Fed. Cir. 2014) (sequence of receiving, selecting, offering for exchange, display, allowing access, and receiving payment recited as an abstraction), Inventor Holdings, LLC v. Bed Bath & Beyond, Inc., 876 F.3d 1372, 1378 (Fed. Cir. 2017) (sequence of data retrieval, analysis, modification, generation, display, and transmission), Two-Way Media Ltd. v. Comcast Cable Communications, LLC, 874 F.3d 1329, 1339 (Fed. Cir. 2017) (sequence of processing, routing, controlling, and monitoring). The ordering of the steps is therefore ordinary and conventional. The analysis conclude that the claims do not provide an inventive concept because the additional elements recited in the claims do not provide significantly more than the recited judicial exception.
According to 2106.05 well-understood and routine processes to perform the abstract idea is not sufficient to transform the claim into patent eligibility. As evidence the examiner provides:
The specification discloses:
[0021]… Once transactions are determined to be automatic chargeback-eligible transactions, the AC computing device aggregates the chargeback-eligible transactions into a single data file. The AC computing device then formats the single data file into a standardized format such that the single file may be easily transmitted and read…
[0023] The methods and systems directed to the AC computing device described herein may be implemented using computer programming or engineering techniques including computer software, firmware, hardware or any combination or subset thereof, wherein the technical effect may be achieved by performing at least one of the following steps: (i) receiving transaction data associated with a plurality of processed transactions, the transaction data including a plurality of account identifiers, a plurality of authorization messages, and a plurality of clearing messages associated with the plurality of processed transactions, (ii) matching the plurality of authorization messages with the respective plurality of clearing messages for each processed transaction of the plurality of processed transactions, (iii) identifying automatic chargeback-eligible transactions from the plurality of processed transactions by parsing the transaction data and by the matching of the authorization messages with the clearing messages, (iv) storing, in the at least one memory, the identified automatic chargeback-eligible transactions, (v) automatically initiating a chargeback transaction for each identified automatic chargeback-eligible transaction. “
[0027] As used herein, the term "database" may refer to either a body of data, a relational database management system (RDBMS), or to both. A database may include any collection of data including hierarchical databases, relational databases, flat file databases, object-relational databases, object oriented databases, and any other structured collection of records or data that is stored in a computer system The above examples are for example only, and thus, are not intended to limit in any way the definition and/or meaning of the term database…
[0028] The term processor, as used herein, may refer to central processing units, microprocessors, microcontrollers, reduced instruction set circuits (RISC), application specific integrated circuits (ASIC), logic circuits, and any other circuit or processor capable of executing the functions described herein.
[0056] The processed transactions stored 309, 312, and 316 in separate databases are aggregated and formatted 318 by AC computing device 102 into a standardized, single file. The standardized, single file may include a standardized database file including each of the processed transactions. Once the processed transactions (the automatic chargeback-eligible transactions) are aggregated and formatted 318, AC computing device 102 initiates 310 chargeback transactions for the automatic chargeback-eligible transactions. In initiating 310 the chargeback transactions, AC computing device 102 transmits the aggregated and formatted 318 file to a dispute case manager (DCM) associated with processing network….
The specification discloses that the intended use of the formatting transaction single data file into a standardized format is so that the single file can be “easily transmitted and read” (para 0020). Although the specification states that the transaction single standardized file formatted reduces processing power to process transactions and eliminates the need for human interaction to determine and verify chargeback transaction for transactions that satisfy certain rules. The specification is silent as to how merely formatting a file in a standardized format to be sent has any impact upon reducing power required to process chargeback transactions or eliminate the need for human interaction beyond the conclusory statement. This “reducing the processing power required...” and “eliminating the need for human interaction...” appears to be a statement without support. (para 0022). The specification states that the account identifiers and transaction data may be retrieved from ...network in a standardized format and/or single message, but fails to provide any details as to the implementation of the formatting as it relates to a technical process beyond the mention of a common format used in transaction processes (ISO 8583) . Para 0055 of the specification states that the transactions stored are aggregated and formatted into a standardized single file where once the file is aggregated and standardized the computing device initiates chargeback transactions. The formatting therefore, appears to be nothing more than processing data for use of the computer for the chargeback process. See also para 0041, para 0047, para 0063-0064, para 0071-0072
Evidence that the concept of manipulating received data by aggregating and formatting the data into a common/standard format is well known in the art, the examiner provides. US Pub No. 2019/0034591 A1 by Mossin et al (para 0067); US Pub No. 2018/0167281 A1 by Meenal et al –(para 0006 -background); US Pub No. 2017/00856345 A1 by Guney et al- (para 0075); US Pub No. 2015/0295751 A1 by Caison et al-(para 0037); US Pub No. 2014/0130119 A1 by Goldschlg et al-(para 0147); US Pub No. 2011/0166883 A1 by Palmer et al –(para 0098) which provides evidence that such data manipulation has been known and applied in the art for some time.
The instant application, therefore, still appears to only implement the abstract ideas to the particular technological environments using what is generic components and functions in the related arts. The claim is not patent eligible.
The remaining dependent claims—which impose additional limitations—also fail to claim patent-eligible subject matter because the limitations cannot be considered statutory. In reference to claims 2-3, 5-7 and 21 and these dependent claim have also been reviewed with the same analysis as independent claim 1. Dependent claim 2 recites “store account identifier, parse account identifier, compare identifiers, determine identifier matches, store unmatched identifiers, and identify each transaction with a not-on-file account identifier as an eligible transaction- a business process and comparing and manipulating data see For data, mere “manipulation” of basic mathematical constructs [i.e.,] the paradigmatic ‘abstract idea,’" has not been deemed a transformation. CyberSource v. Retail Decisions, 654 F.3d 1366, 1372 n.2, 99 USPQ2d 1690, 1695 n.2 (Fed. Cir. 2011) (quoting In re Warmerdam, 33 F.3d 1354, 1355, 1360 (Fed. Cir. 1994). Whether the transformation is extra-solution activity or a field-of-use (i.e., the extent to which (or how) the transformation imposes meaningful limits on the execution of the claimed method steps). A transformation that contributes only nominally or insignificantly to the execution of the claimed method (e.g., in a data gathering step or in a field-of-use limitation) would not provide significantly more (or integrate a judicial exception into a practical application). Mayo, 566 U.S. at 76, 101 USPQ2d at 1967. The Supreme Court disagreed, finding that this step was only a field-of-use limitation and did not provide significantly more than the judicial exception. Id. See MPEP § 2106.05(g) & (h) . Dependent claim 3 is directed toward store identifiers, determine whether transactions valid authorization message, store identified transaction that do not include valid authorization and identify invalid authorization as eligible chargeback transactions- a business practice and sales activity. Dependent claim 5 is directed toward aggregating identified eligible chargeback separately in memory, - which is directed toward storing analyzed data- well known and understood and common business practice. Dependent claim 6 is directed toward determine account identifier and accounts standing status, store identifiers associated with bad standing accounts as bad identifiers, identify account bad standing account identifiers stored – a common business practice. Dependent claim 7 is directed toward receive transaction rules, identify eligible transaction and initiate transaction- a common business practice. Dependent claim 21 is directed toward reversing chargeback instructions of two types – sales activity
The dependent claim(s) have been examined individually and in combination with the preceding claims, however they do not cure the deficiencies of claim 1. Where all claims are directed to the same abstract idea, “addressing each claim of the asserted patents [is] unnecessary.” Content Extraction & Transmission LLC v. Wells Fargo Bank, Nat 7 Ass ’n, 776 F.3d 1343, 1348 (Fed. Cir. 2014). If applicant believes the dependent claims 2-3, 5-7 and 21 are directed towards patent eligible subject matter, they are invited to point out the specific limitations in the claim that are directed towards patent eligible subject matter.
In reference to claims 8-14:
STEP 1. Per Step 1 of the two-step analysis, the claims are determined to include a method, as in independent Claim 8 and the dependent claims. Such methods fall under the statutory category of "process." Therefore, the claims are directed to a statutory eligibility category.
STEP 2A Prong 1. Method claim 8 corresponds to system claim 1. Therefore, claim 8 has been analyzed and rejected as being directed toward an abstract idea of the categories of concepts directed toward mental processes and methods of organizing human activity previously discussed with respect to claim 1.
STEP 2A Prong 2: Method claim 8 corresponds to system claim 1. Therefore, claim 8 has been analyzed and rejected as failing to provide limitations that are indicative of integration into a practical application, as previously discussed with respect to claim 1.
STEP 2B; The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because as discussed above with respect to concepts of the abstract idea into a practical application. The additional elements beyond the abstract idea include a computing system including a processor in communication with a memory–is purely functional and generic. Nearly every computer system for implementing a method will include a “processor” capable of performing the basic computer functions -of “receive data, identify by matching, store, identify and parse data, store data, format and store data and transmit transaction data” steps - As a result, none of the hardware recited by the method claims offers a meaningful limitation beyond generally linking the use of the method to a particular technological environment, that is, implementation via computers.
Method claim 8 steps corresponds to system functions claim 1. Therefore, claim 8 has been analyzed and rejected as failing to provide additional elements that amount to an inventive concept –i.e. significantly more than the recited judicial exception. Furthermore, as previously discussed with respect to claim 1, the limitations when considered individually, as a combination of parts or as a whole fail to provide any indication that the elements recited are unconventional or otherwise more than what is well understood, conventional, routine activity in the field.
The remaining dependent claims—which impose additional limitations—also fail to claim patent-eligible subject matter because the limitations cannot be considered statutory. In reference to claims 9-14 these dependent claim have also been reviewed with the same analysis as independent claim 8. Dependent claim 9 recites “storing identifies, parsing identifier, comparing received identifier, determining matches set of identifiers, storing received identifiers, identifying data records with invalid identifiers- risk mitigation and sales activity. Dependent claim 10 is directed toward storing received identifiers, determining data set includes valid message, storing identified data set do not include valid message as invalid, identifying each invalid message as third type of two types of chargebacks. Dependent claim 11 is directed toward storing account identifiers, determining whether each data set includes valid message that was processed, storing data, identifying invalid messages as first type- a business practice and sales activity. Dependent claim 12 is directed toward aggregating each chargeback for each type of two types of chargeback – a sales activity business practice of data accumulation. Dependent claim 13 is directed toward determining whether identifier in good/bad standing, storing identifiers and identifying bad standing identifiers as one of chargebacks- sales activity and risk mitigation. Dependent claim 14 is directed toward receiving rules, identifying two types of chargeback instructions from rule- business process and sales activity. The dependent claim(s) have been examined individually and in combination with the preceding claims, however they do not cure the deficiencies of claim 8. Where all claims are directed to the same abstract idea, “addressing each claim of the asserted patents [is] unnecessary.” Content Extraction & Transmission LLC v. Wells Fargo Bank, Nat 7 Ass ’n, 776 F.3d 1343, 1348 (Fed. Cir. 2014). If applicant believes the dependent claims 9-14 are directed towards patent eligible subject matter, they are invited to point out the specific limitations in the claim that are directed towards patent eligible subject matter.
In reference to Claims 15-20:
STEP 1. Per Step 1 of the two-step analysis, the claims are determined to include a non-transitory computer-readable storage media as in independent Claim 15 and the dependent claims. Such medias fall under the statutory category of "manufacture." Therefore, the claims are directed to a statutory eligibility category.
STEP 2A Prong 1. Manufacture claim 16 corresponds to system claim 1. Therefore, claim 15 has been analyzed and rejected as being directed toward an abstract idea of the categories of concepts directed toward mental processes and market activity previously discussed with respect to claim 1.
STEP 2A Prong 2: Manufacture claim 15 corresponds to system claim 1. Therefore, claim 15 has been analyzed and rejected as failing to provide limitations that are indicative of integration into a practical application, as previously discussed with respect to claim 1.
STEP 2B; The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because as discussed above with respect to concepts of the abstract idea into a practical application. The additional elements beyond the abstract idea include a non-transitory computer-readable media including computer executable instructions to cause a processor to perform the instructions–is purely functional and generic. Nearly every non-transitory computer-readable media for implementing an instruction will include a “processor” capable of performing the basic computer functions -of “receive data, identify by matching, store, identify and parse data, store data, format and store data and transmit transaction data” steps - As a result, none of the hardware recited by the system claims offers a meaningful limitation beyond generally linking the use of the method to a particular technological environment, that is, implementation via computers.
The instructions of manufacture claim 15 corresponds to system functions claim 1. Therefore, claim 15 has been analyzed and rejected as failing to provide additional elements that amount to an inventive concept –i.e. significantly more than the recited judicial exception. Furthermore, as previously discussed with respect to claim 1, the limitations when considered individually, as a combination of parts or as a whole fail to provide any indication that the elements recited are unconventional or otherwise more than what is well understood, conventional, routine activity in the field.
The remaining dependent claims—which impose additional limitations—also fail to claim patent-eligible subject matter because the limitations cannot be considered statutory. In reference to claims 16-20 these dependent claim have also been reviewed with the same analysis as independent claim 15. Dependent claim 16 recites “store account identifiers, parse account identifiers, compare account identifiers to legitimate account identifiers, determine account identifiers match, store unmatched account identifiers and identify each transaction with invalid identifiers-risk mitigation and transaction activity. Dependent claim 17 is directed toward store matched account identifiers as on file, determine whether transaction valid authorization, store identified data, identify message as third type of two types of chargeback instructions- transaction activity. Dependent claim 18 is directed toward aggregate data- data accumulation business process. Dependent claim 19 is directed toward determine where identifier stored being in good/bad standing, store received identifiers, identify each data set associated with bad identifiers- risk mitigation. Dependent claim 20 is directed toward receiving rules, identifying two types of chargeback from plurality of transactions based on rules, initiate reversal of chargeback- sales activity.
The dependent claim(s) have been examined individually and in combination with the preceding claims, however they do not cure the deficiencies of claim 15. Where all claims are directed to the same abstract idea, “addressing each claim of the asserted patents [is] unnecessary.” Content Extraction & Transmission LLC v. Wells Fargo Bank, Nat 7 Ass ’n, 776 F.3d 1343, 1348 (Fed. Cir. 2014). If applicant believes the dependent claims 16-20 are directed towards patent eligible subject matter, they are invited to point out the specific limitations in the claim that are directed towards patent eligible subject matter.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. WO-2017132111-A1 by Phillips; CA 2944218 A1 by Wells et al; CA 2309052 by Johnson; CA 2350551 by Junger; CA 2437507 C by Falbert
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.
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/MARY M GREGG/Examiner, Art Unit 3695
/CHRISTINE M Tran/Supervisory Patent Examiner, Art Unit 3695