Prosecution Insights
Last updated: April 19, 2026
Application No. 18/239,214

Distributed, Privacy Preserving, Payments Fraud Detection System

Non-Final OA §101§103
Filed
Aug 29, 2023
Examiner
EKECHUKWU, CHINEDU U
Art Unit
3695
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
BANK OF AMERICA CORPORATION
OA Round
3 (Non-Final)
1%
Grant Probability
At Risk
3-4
OA Rounds
4y 10m
To Grant
3%
With Interview

Examiner Intelligence

Grants only 1% of cases
1%
Career Allow Rate
2 granted / 195 resolved
-51.0% vs TC avg
Minimal +2% lift
Without
With
+1.7%
Interview Lift
resolved cases with interview
Typical timeline
4y 10m
Avg Prosecution
62 currently pending
Career history
257
Total Applications
across all art units

Statute-Specific Performance

§101
37.9%
-2.1% vs TC avg
§103
36.6%
-3.4% vs TC avg
§102
11.3%
-28.7% vs TC avg
§112
13.5%
-26.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 195 resolved cases

Office Action

§101 §103
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 . This is a Non-Final Office Action in response to application 18/239,214 entitled "Distributed, Privacy Preserving, Payments Fraud Detection System" filed on June 13, 2025, with claims 1 to 20 pending. Continued Examination Under 37 CFR 1.114 A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Status of Claims Claims 1, 8, and 15 have been amended and are hereby entered. Claims 1-20 are pending and have been examined. Response to Amendment The amendment filed June 13, 2025, has been entered. Claims 1-20 remain pending in the application. Applicant’s amendments to the Specification, Drawings, and/or Claims have been noted in response to the Final Office Action mailed April 2, 2025. Information Disclosure Statement The information disclosure statement (IDS) submitted on August 29, 2023, is in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the Examiner. 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 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. Please see MPEP 2106 for additional information regarding Patent Subject Matter Eligibility Guidance. Claims 1-20 are directed to a system, method/process, machine/apparatus, or composition of matter, which are/is one of the statutory categories of invention. (Step 1: YES). The claimed invention is directed to an abstract idea without significantly more. Independent Claim 1 recites: “…model on a data set; communicate, …and to a local instance of a decentralized privacy preserving fraud detection system on each payment …system of a plurality of payments … systems, the …model; monitor, in real-time based on the …model and locally to each of the plurality of payments …systems by the local instance of the decentralized privacy preserving fraud detection system, each of the plurality of payments … systems for an indication of a fraudulent transaction, wherein data privacy is preserved because local data sets do not leave the …and data privacy is further enhanced by selective gradient clipping; perform, by the local instance of the decentralized privacy preserving fraud detection system utilizing the … model while monitoring real-time payments transactions being performed by each payments … system of the plurality of payments …systems, …on a local dataset; receive, … and by a centralized model …a gradient update to a first local model utilized by a first instance of a first decentralized privacy preserving fraud detection system associated with on a first-payments … system of the plurality of payments…systems, wherein a gradient comprises differences local to the first payments …system and the first instance of the decentralized privacy preserving fraud detection system processing the …. model and wherein the differences comprise a first fraudulent activity pattern; …by the centralized model …the model based on aggregated gradients received from each of the plurality of payments … systems and including the gradient update, wherein the…model comprises a capability to identify a pattern of fraudulent transactions in real-time while maintaining privacy, wherein the pattern of fraudulent transactions comprises the first fraudulent activity pattern identified on the first payment …system; communicate, … and to the plurality of payments …systems, the …model to each local instance of the decentralized privacy preserving fraud detection system on each payment … system of the plurality of payments … systems, wherein the plurality of payments …systems comprises a plurality of electronic transaction system types; and … in real-time and based on an identification of a fraudulent transaction by a second instance of a second decentralized privacy preserving fraud detection system associated with a second payments … system of the plurality of payments … systems based on use of the … model… identifying the fraudulent transaction.” These limitations clearly relate to managing payment transactions. These limitations, under their broadest reasonable interpretation, cover performance of the limitation as certain methods of organizing human activity. Specific instances include instructing to “communicate… to the plurality of payments … systems, the … model to each of the plurality of payments … systems” recite a fundamental economic principles or practice and/or commercial or legal interactions. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation as a fundamental economic, commercial, or financial action, principle, or practice then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites 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 platform comprising: a processor; and memory storing instructions that, when executed by the processor, cause the computing platform] [via a network] [computing] [corresponding local network]: merely applying computer processing, storage, and networking technology as tools to perform an abstract idea [to: train an artificial intelligence/machine learning (AI/ML)] [training] [trained] [Nc epochs of gradient descent ][retraining engine][re-train] [re-trained]: merely applying computer machine learning technology as a tool to perform an abstract idea [generate…an alert] insignificant post-solution activity are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function) such that it amounts no more than mere instructions to apply the exception using a generic computer components and/or electronic processes. For example, the Applicant’s Specification reads: [30] The application computing systems 108 may be one or more host devices (e.g., a workstation, a server, and the like) or mobile computing devices (e.g., smartphone, tablet). [32] The user device(s) 110 may be computing devices (e.g., desktop computers, laptop computers) or mobile computing device (e.g., smartphones, tablets) [17] "Computer machines" can include one or more: general-purpose ...computers... desktop computers... laptop or notebook computers” Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. The additional elements merely add instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea, see MPEP 2106.05(f). 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) Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. The additional elements merely add instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea, see MPEP 2106.05(f). Accordingly, these additional elements, do not change the outcome of the analysis, when considered separately and as an ordered combination. The [generate …an alert] is an additional element, that is merely insignificant extra post solution activity, specifically mere data gathering. Per Outputting data/notifications: MPEP2106.05(g), Ameranth, 842 F.3d at 1241-42, 120 USPQ2d at 1854-55. The claim further define the abstract idea that is present and hence are abstract for the reasons presented above. The independent claim does 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, the independent claim is directed to an abstract idea. Thus, the claim is not patent eligible. (Step 2B: NO. The claims do not provide significantly more) Dependent Claims recite additional elements. This judicial exception is not integrated into a practical application. In particular, the recited additional elements of Claim 2: “computing”: merely applying computer processing, networking, and display technologies as a tool to perform an abstract idea Claim 3: “computing”: merely applying computer processing, networking, and display technologies as a tool to perform an abstract idea “retrain”: generally linking to machine learning as a tool to perform an abstract idea Claim 4: “computing”, “computing network”: merely applying computer processing, networking, and display technologies as a tool to perform an abstract idea Claim 5: “computing”, “computing network”, “network”: merely applying computer processing, networking, and display technologies as a tool to perform an abstract idea Claim 6: “computing”: merely applying computer processing, networking, and display technologies as a tool to perform an abstract idea Claim 7: “computing”: merely applying computer processing, networking, and display technologies as a tool to perform an abstract idea. are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function) such that it amounts no more than mere instructions to apply the exception using a generic computer components and/or electronic processes. For example, the Applicant’s Specification reads: [30] The application computing systems 108 may be one or more host devices (e.g., a workstation, a server, and the like) or mobile computing devices (e.g., smartphone, tablet). [32] The user device(s) 110 may be computing devices (e.g., desktop computers, laptop computers) or mobile computing device (e.g., smartphones, tablets) [17] "Computer machines" can include one or more: general-purpose ...computers... desktop computers... laptop or notebook computers” Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. The additional elements merely add instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea, see MPEP 2106.05(f). 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, the claim 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) Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. The additional elements merely add instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea, see MPEP 2106.05(f). Accordingly, these additional elements, do not change the outcome of the analysis, when considered separately and as an ordered combination. Dependent claims further define the abstract idea that is present in their respective independent claims and hence are abstract for the reasons presented above. The dependent claims 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, the dependent claims are directed to an abstract idea. Thus, the claims are not patent eligible. (Step 2B: NO. The claims do not provide significantly more) Independent Claim 8 recites: “…cause a fraud detection system to: …an ….model on a data set; communicate, …and to a local instance of a decentralized privacy preserving fraud detection system on each payment …system of a plurality of payments … systems, the …model; monitor, in real-time based on the …model and locally to each of the plurality of payments …systems by the local instance of the decentralized privacy preserving fraud detection system, each of the plurality of payments … systems for an indication of a fraudulent transaction, wherein data privacy is preserved because local data sets do not leave the …and data privacy is further enhanced by selective gradient clipping; perform, by the local instance of the decentralized privacy preserving fraud detection system utilizing the … model while monitoring real-time payments transactions being performed by each payments … system of the plurality of payments …systems, …on a local dataset; receive, … and by a centralized model …a gradient update to a first local model utilized by a first instance of a first decentralized privacy preserving fraud detection system associated with on a first-payments … system of the plurality of payments…systems, wherein a gradient comprises differences local to the first payments …system and the first instance of the decentralized privacy preserving fraud detection system processing the …. model and wherein the differences comprise a first fraudulent activity pattern; …by the centralized model …the model based on aggregated gradients received from each of the plurality of payments … systems and including the gradient update, wherein the…model comprises a capability to identify a pattern of fraudulent transactions in real-time while maintaining privacy, wherein the pattern of fraudulent transactions comprises the first fraudulent activity pattern identified on the first payment …system; communicate, … and to the plurality of payments …systems, the …model to each local instance of the decentralized privacy preserving fraud detection system on each payment … system of the plurality of payments … systems, wherein the plurality of payments …systems comprises a plurality of electronic transaction system types; and … in real-time and based on an identification of a fraudulent transaction by a second instance of a second decentralized privacy preserving fraud detection system associated with a second payments … system of the plurality of payments … systems based on use of the … model… identifying the fraudulent transaction.” These limitations clearly relate to managing payment transactions. These limitations, under their broadest reasonable interpretation, cover performance of the limitation as certain methods of organizing human activity. Specific instances include instructing to “cause a fraud detection system to…communicate… to the plurality of payments … systems, the … model to each of the plurality of payments … systems” recite a fundamental economic principles or practice and/or commercial or legal interactions. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation as a fundamental economic, commercial, or financial action, principle, or practice then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites 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: [Non-transitory computer readable media storing instructions that, when executed by a processor], [computing] [comprising: a processor; and memory storing instructions that, when executed by the processor][via a network] [via the network]: merely applying computer processing, storage, and networking technology as tools to perform an abstract idea [to: train an artificial intelligence/machine learning (AI/ML)] [training] [trained] [Nc epochs of gradient descent ][retraining engine][re-train] [re-trained]: merely applying computer machine learning technology as a tool to perform an abstract idea [generate…an alert] insignificant post-solution activity are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function) such that it amounts no more than mere instructions to apply the exception using a generic computer components and/or electronic processes. For example, the Applicant’s Specification reads: [30] The application computing systems 108 may be one or more host devices (e.g., a workstation, a server, and the like) or mobile computing devices (e.g., smartphone, tablet). [32] The user device(s) 110 may be computing devices (e.g., desktop computers, laptop computers) or mobile computing device (e.g., smartphones, tablets) [17] "Computer machines" can include one or more: general-purpose ...computers... desktop computers... laptop or notebook computers” Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. The additional elements merely add instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea, see MPEP 2106.05(f). 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 8 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) Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. The additional elements merely add instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea, see MPEP 2106.05(f). Accordingly, these additional elements, do not change the outcome of the analysis, when considered separately and as an ordered combination. The [generate …an alert] is an additional element, that is merely insignificant extra post solution activity, specifically mere data gathering. Per Outputting data/notifications: MPEP2106.05(g), Ameranth, 842 F.3d at 1241-42, 120 USPQ2d at 1854-55. The claim further define the abstract idea that is present and hence are abstract for the reasons presented above. The independent claim does 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, the independent claim is directed to an abstract idea. Thus, the claim is not patent eligible. (Step 2B: NO. The claims do not provide significantly more) Dependent Claims recite additional elements. This judicial exception is not integrated into a practical application. In particular, the recited additional elements of Claim 9: “non-transitory computer readable media”, “computing”: merely applying computer processing, networking, and display technologies as a tool to perform an abstract idea Claim 10: “non-transitory computer readable media”, “computing”: merely applying computer processing, networking, and display technologies as a tool to perform an abstract idea “retrain”: generally linking to machine learning as a tool to perform an abstract idea Claim 11: “non-transitory computer readable media”, “computing”, “computing network”: merely applying computer processing, networking, and display technologies as a tool to perform an abstract idea Claim 12: “non-transitory computer readable media”, “computing”, “computing network”, “network”: merely applying computer processing, networking, and display technologies as a tool to perform an abstract idea Claim 13: “non-transitory computer readable media”, “computing”: merely applying computer processing, networking, and display technologies as a tool to perform an abstract idea Claim 14: “non-transitory computer readable media”, “computing”: merely applying computer processing, networking, and display technologies as a tool to perform an abstract idea. are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function) such that it amounts no more than mere instructions to apply the exception using a generic computer components and/or electronic processes. For example, the Applicant’s Specification reads: [30] The application computing systems 108 may be one or more host devices (e.g., a workstation, a server, and the like) or mobile computing devices (e.g., smartphone, tablet). [32] The user device(s) 110 may be computing devices (e.g., desktop computers, laptop computers) or mobile computing device (e.g., smartphones, tablets) [17] "Computer machines" can include one or more: general-purpose ...computers... desktop computers... laptop or notebook computers” Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. The additional elements merely add instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea, see MPEP 2106.05(f). 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, the claim 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) Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. The additional elements merely add instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea, see MPEP 2106.05(f). Accordingly, these additional elements, do not change the outcome of the analysis, when considered separately and as an ordered combination. Dependent claims further define the abstract idea that is present in their respective independent claims and hence are abstract for the reasons presented above. The dependent claims 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, the dependent claims are directed to an abstract idea. Thus, the claims are not patent eligible. (Step 2B: NO. The claims do not provide significantly more) Independent Claim 15 recites: “A method comprising …an ….an ….model on a data set; communicating, …and to a local instance of a decentralized privacy preserving fraud detection system on each payment …system of a plurality of payments … systems, the …model; monitoring, in real-time based on the …model and locally to each of the plurality of payments …systems by the local instance of the decentralized privacy preserving fraud detection system, each of the plurality of payments … systems for an indication of a fraudulent transaction, wherein data privacy is preserved because local data sets do not leave the …and data privacy is further enhanced by selective gradient clipping; performing, by the local instance of the decentralized privacy preserving fraud detection system utilizing the … model while monitoring real-time payments transactions being performed by each payments … system of the plurality of payments …systems, …on a local dataset; receiving, … and by a centralized model …a gradient update to a first local model utilized by a first instance of a first decentralized privacy preserving fraud detection system associated with on a first-payments … system of the plurality of payments…systems, wherein a gradient comprises differences local to the first payments …system and the first instance of the decentralized privacy preserving fraud detection system processing the …. model and wherein the differences comprise a first fraudulent activity pattern; …by the centralized model …the model based on aggregated gradients received from each of the plurality of payments … systems and including the gradient update, wherein the…model comprises a capability to identify a pattern of fraudulent transactions in real-time while maintaining privacy, wherein the pattern of fraudulent transactions comprises the first fraudulent activity pattern identified on the first payment …system; communicating, … and to the plurality of payments …systems, the …model to each local instance of the decentralized privacy preserving fraud detection system on each payment … system of the plurality of payments … systems, wherein the plurality of payments …systems comprises a plurality of electronic transaction system types; and … in real-time and based on an identification of a fraudulent transaction by a second instance of a second decentralized privacy preserving fraud detection system associated with a second payments … system of the plurality of payments … systems based on use of the … model… identifying the fraudulent transaction.” These limitations clearly relate to managing payment transactions. These limitations, under their broadest reasonable interpretation, cover performance of the limitation as certain methods of organizing human activity. Specific instances include instructing to “communicate… to the plurality of payments … systems, the … model to each of the plurality of payments … systems” recite a fundamental economic principles or practice and/or commercial or legal interactions. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation as a fundamental economic, commercial, or financial action, principle, or practice then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites 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: [computing] [comprising: a processor; and memory storing instructions that, when executed by the processor][via a network] [via the network]: merely applying computer processing, storage, and networking technology as tools to perform an abstract idea [training an artificial intelligence/machine learning (AI/ML)] [training] [trained] [Nc epochs of gradient descent ][retraining engine][re-train] [re-trained]: merely applying computer machine learning technology as a tool to perform an abstract idea [generating…an alert] insignificant post-solution activity are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function) such that it amounts no more than mere instructions to apply the exception using a generic computer components and/or electronic processes. For example, the Applicant’s Specification reads: [30] The application computing systems 108 may be one or more host devices (e.g., a workstation, a server, and the like) or mobile computing devices (e.g., smartphone, tablet). [32] The user device(s) 110 may be computing devices (e.g., desktop computers, laptop computers) or mobile computing device (e.g., smartphones, tablets) [17] "Computer machines" can include one or more: general-purpose ...computers... desktop computers... laptop or notebook computers” Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. The additional elements merely add instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea, see MPEP 2106.05(f). 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 15 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) Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. The additional elements merely add instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea, see MPEP 2106.05(f). Accordingly, these additional elements, do not change the outcome of the analysis, when considered separately and as an ordered combination. The [generating …an alert] is an additional element, that is merely insignificant extra post solution activity, specifically mere data gathering. Per Outputting data/notifications: MPEP2106.05(g), Ameranth, 842 F.3d at 1241-42, 120 USPQ2d at 1854-55. The claim further define the abstract idea that is present and hence are abstract for the reasons presented above. The independent claim does 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, the independent claim is directed to an abstract idea. Thus, the claim is not patent eligible. (Step 2B: NO. The claims do not provide significantly more) Dependent Claims recite additional elements. This judicial exception is not integrated into a practical application. In particular, the recited additional elements of Claim 16: “computing”: merely applying computer processing, networking, and display technologies as a tool to perform an abstract idea Claim 17: “computing”: merely applying computer processing, networking, and display technologies as a tool to perform an abstract idea “retraining”: generally linking to machine learning as a tool to perform an abstract idea Claim 18: “computing”, “computing network”: merely applying computer processing, networking, and display technologies as a tool to perform an abstract idea Claim 19: “computing”, “computing network”, “network”: merely applying computer processing, networking, and display technologies as a tool to perform an abstract idea Claim 20: “computing”: merely applying computer processing, networking, and display technologies as a tool to perform an abstract idea are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function) such that it amounts no more than mere instructions to apply the exception using a generic computer components and/or electronic processes. For example, the Applicant’s Specification reads: [30] The application computing systems 108 may be one or more host devices (e.g., a workstation, a server, and the like) or mobile computing devices (e.g., smartphone, tablet). [32] The user device(s) 110 may be computing devices (e.g., desktop computers, laptop computers) or mobile computing device (e.g., smartphones, tablets) [17] "Computer machines" can include one or more: general-purpose ...computers... desktop computers... laptop or notebook computers” Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. The additional elements merely add instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea, see MPEP 2106.05(f). 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, the claim 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) Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. The additional elements merely add instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea, see MPEP 2106.05(f). Accordingly, these additional elements, do not change the outcome of the analysis, when considered separately and as an ordered combination. Dependent claims further define the abstract idea that is present in their respective independent claims and hence are abstract for the reasons presented above. The dependent claims 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, the dependent claims are directed to an abstract idea. Thus, the claims are not patent eligible. (Step 2B: NO. The claims do not provide significantly more) Claim Rejections - 35 USC § 103 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. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. 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. 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 1-20 are rejected under 35 U.S.C. 103 as being unpatentable over Hassanzadeh ("PRIVACY-PRESERVING COLLABORATIVE MACHINE LEARNING TRAINING USING DISTRIBUTED EXECUTABLE FILE PACKAGES IN AN UNTRUSTED ENVIRONMENT", U.S. Publication Number: 20220414661 A1), in view of Perez (“PRESERVING PRIVACY AND TRAINING NEURAL NETWORK MODELS”, U.S. Publication Number: 20240311834 A1),in view of Marathe (“USER-LEVEL PRIVACY PRESERVATION FOR FEDERATED MACHINE LEARNING”, U.S. Publication Number: 20230047092 A1). Regarding Claim 1, Hassanzadeh teaches, A computing platform comprising: a processor; and memory storing instructions that, when executed by the processor, cause the computing platform to: train an artificial intelligence/machine learning (AI/ML) model on a training data set; (Hassanzadeh [Abstract] cooperative training of machine learning (ML) models Hassanzadeh [0007] machine learning models using distributed executable file packages includes executing, by one or more processors, an executable file package stored at a memory) communicate, via a network and to a local instance of a decentralized privacy preserving fraud detection system on each payment computing system of a plurality of payments computing systems, the trained model; (Hassanzadeh [0005] may cause the server and clients to perform cooperative learning, such as federated learning Hassanzadeh [0006] the client devices to implement and train a local ML model Hassanzadeh [0023] training of machine learning (ML) models that preserve privacy Hassanzadeh [Abstract] with multiple clients, particularly for a fraud prediction model for financial transactions. Hassanzadeh [0065] In federated learning, the server 340 initializes a global ML model (e.g., an initial ML model) and shares copies of the model with participating clients. Hassanzadeh [0035] to perform other types of predictions for other clients, such as in the health industry, network service providers, government agencies, or any other environment) monitor, … based on the trained model and locally to each of the plurality of payments computing systems by the local instance of the decentralized privacy preserving fraud detection system, each of the plurality of payments computing systems for an indication of a fraudulent transaction, (Hassanzadeh [0043] process of sharing output data and gradient data between the server 102 and the first client device 140 may continue until the first ML model and the first server ML model are trained Hassanzadeh [0001] training of a fraud detection machine learning model by multiple financial institutions using distributed executable file packages. Hassanzadeh [0006] training the local ML models may include providing output data Hassanzadeh [0002] to identify and predict anomalies) wherein data privacy is preserved because local data sets do not leave the corresponding local network and data privacy is further enhanced by [gradient data] (Hassanzadeh [0079] Each participating client trains a respective local partial ML model using its local dataset of financial transactions data, which may be private or confidential. The training includes providing output data to the server 540 for training of corresponding server-side partial ML models, and receipt of gradient data for training of the local partial ML models Hassanzadeh [0028] The client devices 140 and 142 may also store client-specific data, which may be private or confidential to the respective client Hassanzadeh [0031] clients may be competitors, or potential competitors, each client may desire to keep some or all client-specific data private, and thus the system 100 may represent an untrusted environment. ...To preserve privacy, the present disclosure provides techniques for cooperative training and use of ML models by the server 102, the first client device 140, the Nth client device 142, and the user device 150 that do not require client-specific data Hassanzadeh [0044] the Nth client device 142 may implement a second ML model ... may train the second ML model by providing the Nth client data 146 as training data to the second ML model... The Nth training output 172 may include ...second output data (e.g., second smash data) that includes gradient output) perform, by the local instance of the decentralized privacy preserving fraud detection system utilizing the trained model while monitoring … payments transactions being performed by each payments computing system of the plurality of payments computing systems, Nc epochs ….on a local dataset; receive, via the network and by a centralized model retraining engine, a gradient update to a first local model utilized by a first instance of a first decentralized privacy preserving fraud detection system associated with on a first-payments computing system of the plurality of payments computing systems, wherein a gradient comprises differences associated with a particular local to the first payments computing system and the first instance of the decentralized privacy preserving fraud detection system processing the trained model (Hassanzadeh [Abstract] particularly for a fraud prediction model for financial transactions Hassanzadeh [0050] the splitting, training, and aggregating are repeated for multiple iterations or epochs Hassanzadeh [0043] any output data and gradient data shared between the server and the first client device 140 may be encrypted. This process of sharing output data and gradient data between the server 102 and the first client device 140 may continue until the first ML model and the first server ML model are trained Hassanzadeh [0054] the first client device 140, and the Nth client device 142 while preserving privacy of client data used to train the ML models. Hassanzadeh [0040] the differences between client-side partial ML models of different clients may be similarly based on any desired characteristic or information associated with the clients. Performing individual splits on a client-by-client basis is more flexible and may improve the robustness of a resulting trained ML model as well as improve computing resource utilization across the server 102, the first client device 140, and the Nth client device 142 as compared to performing the same split for all clients, or not splitting the initial ML model) and wherein the differences …re-train, by the centralized model retraining engine, the model based on aggregated gradients received from each of the plurality of payments computing systems and including the gradient update, wherein the re-trained model comprises a capability to identify a pattern of fraudulent transactions in real-time while maintaining privacy, wherein the pattern of fraudulent transactions comprises … identified on the first payment computing system; (Hassanzadeh [0050] training, and aggregating are repeated for multiple iterations or epochs Hassanzadeh [0060] training the local ML models may include providing output data (e.g., smash data) to the server and receiving gradient data from the server Hassanzadeh [0001] to support collaborative training of a fraud detection machine learning model by multiple financial institutions Hassanzadeh [0054] privacy of sensitive client data is preserved while enabling computing resource-intensive training to be offloaded to the server 102 (or one or more cloud-based processing systems)) communicate, via the network and to the plurality of payments computing systems, the re-trained model to each local instance of the decentralized privacy preserving fraud detection system on each payment computing system of the plurality of payments computing systems, (Hassanzadeh [0065] In federated learning, the server 340 initializes a global ML model (e.g., an initial ML model) and shares copies of the model with participating clients.... trained local ML models are collected and aggregated by the server 340 to construct a new global ML model (e.g., an aggregated ML model) for deployment Hassanzadeh [0006] server may deploy the fraud prevention model, such as providing the fraud prevention model to the clients or implementing the fraud prevention model at an endpoint node for providing fraud prediction services) wherein the plurality of payments computing systems comprises a plurality of electronic transaction system types; (Hassanzadeh [0002] When facing distributed networks and highly sensitive datasets (e.g., finance, healthcare, etc.) Hassanzadeh [0035] ML model may be cooperatively trained to perform other types of predictions for other clients, such as in the health industry, network service providers, government agencies, or any other environment in which data privacy is important or required.) Hassanzadeh does not teach in real-time; selective gradient clipping; of gradient descent; a first fraudulent activity pattern; generate, in real-time and based on an identification of a fraudulent transaction by a second instance of a second decentralized privacy preserving fraud detection system associated with on a first a second payments computing system of the plurality of payments computing systems based on use of the re-trained model, an alert identifying the fraudulent transaction. Perez teaches, in real-time; (Perez [0005] any applied processing needs to take place at “real-time”, e.g. with millisecond latencies Perez [0035] a machine learning system is applied in real-time, high-volume transaction processing pipelines to provide an indication of) a first fraudulent activity pattern; (Perez [0070] the output of the machine learning system 160 may comprise a label, alert or other indication of fraud, or general malicious or anomalous activity. Perez [0035] observed and/or predicted patterns of activity or actions, e.g. an indication of whether a transaction or entity is “normal” or “anomalous”. The term “behavioural” is used herein to refer to this pattern of activity or actions) generate, in real-time and based on an identification of a fraudulent transaction by a second instance of a second decentralized privacy preserving fraud detection system associated with on a first a second payments computing system of the plurality of payments computing systems based on use of the re-trained model, an alert identifying the fraudulent transaction. (Perez [0070] the output of the machine learning system 160 may comprise a label, alert or other indication of fraud, or general malicious or anomalous activity. Perez [0005] any applied processing needs to take place at “real-time”, e.g. with millisecond latencies Perez [0035] a machine learning system is applied in real-time, high-volume transaction processing pipelines to provide an indication of whether a transaction...and/or predicted patterns of activity or actions, e.g. an indication of whether a transaction or entity is “normal” or “anomalous”. Perez [0073] a third party, such as the payment processor, one or more banks and/or one or more merchants. Perez [0046] A transaction comprises a series of communications between different electronic systems Perez [0224] bank may change its model or schema, subject to a partial retrain) It is prima facie obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the distributed edge machine learning model of Hassanzadeh to incorporate the real-time alerts of Perez where “the output of the machine learning system … may comprise a label, alert” (Perez [0070]). The modification would have been obvious, because it is merely applying a known technique (i.e. real-time alerts) to a known concept (i.e. distributed edge machine learning models) ready for improvement to yield predictable result (i.e. “a machine learning system is applied in real-time… to provide an indication of whether a transaction...and/or predicted patterns of activity or actions, e.g. an indication of whether a transaction or entity is “normal” or “anomalous”.” Perez [0035]) Perez does not teach selective gradient clipping; (Nc epochs) of gradient descent. Marathe teaches, selective gradient clipping; of gradient descent. (Marathe [0052] may train using … Stochastic Gradient Descent (SGD). … and then clip the gradients, …such as the global clipping threshold Marathe [0015] then repeat for a number of training rounds until the model converges or a fixed number of rounds is complete ) It is prima facie obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the distributed edge machine learning model of Hassanzadeh to incorporate the gradient descent/clippings of Marathe to “compute parameter gradients …, clip the gradients per a globally prescribed clipping threshold” (Marathe [0029]). The modification would have been obvious, because it is merely applying a known technique (i.e. gradient descent/clippings) to a known concept (i.e. distributed edge machine learning models) ready for improvement to yield predictable result (i.e. “While carefully calibrated noise may be injected in the parameter updates, this noise injection is a distinct operation that may be decoupled from parameter update computation. The resulting two steps in parameter updates may be modeled based on Stochastic Gradient Descent” Marathe [0022]) Regarding Claim 2, Hassanzadeh, Perez, and Marathe teach the distributed edge machin
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Prosecution Timeline

Aug 29, 2023
Application Filed
Nov 15, 2024
Non-Final Rejection — §101, §103
Feb 25, 2025
Response Filed
Mar 27, 2025
Final Rejection — §101, §103
Jun 13, 2025
Request for Continued Examination
Jun 18, 2025
Response after Non-Final Action
Nov 22, 2025
Non-Final Rejection — §101, §103 (current)

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Prosecution Projections

3-4
Expected OA Rounds
1%
Grant Probability
3%
With Interview (+1.7%)
4y 10m
Median Time to Grant
High
PTA Risk
Based on 195 resolved cases by this examiner. Grant probability derived from career allow rate.

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