Prosecution Insights
Last updated: April 19, 2026
Application No. 18/260,763

RECEIPTS OF A DISTRIBUTED LEDGER

Final Rejection §101
Filed
Jul 07, 2023
Examiner
NILFOROUSH, MOHAMMAD A
Art Unit
3697
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Microsoft Technology Licensing, LLC
OA Round
2 (Final)
29%
Grant Probability
At Risk
3-4
OA Rounds
4y 10m
To Grant
64%
With Interview

Examiner Intelligence

Grants only 29% of cases
29%
Career Allow Rate
116 granted / 397 resolved
-22.8% vs TC avg
Strong +35% interview lift
Without
With
+34.8%
Interview Lift
resolved cases with interview
Typical timeline
4y 10m
Avg Prosecution
30 currently pending
Career history
427
Total Applications
across all art units

Statute-Specific Performance

§101
26.0%
-14.0% vs TC avg
§103
33.8%
-6.2% vs TC avg
§102
9.8%
-30.2% vs TC avg
§112
28.4%
-11.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 397 resolved cases

Office Action

§101
DETAILED ACTION Acknowledgements The claims filed 11/13/2025 are acknowledged. Claims 1-20 are pending. Claims 1-20 have been examined. 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 . Response to Amendment/Arguments Regarding the rejection of the claims under 35 USC 101, applicant states that the claims as a whole relate to technology that improves the functioning of a computer itself, and is not simply using a computer to implement an abstract idea. Applicant states that the transaction receipt generated by the claimed invention significantly reduces the amount of memory and network bandwidth required to receive and store receipts. Applicant states that the claimed invention reduces the burden of processing and storing receipts by condensing multiple receipts into a single receipt that requires significantly less data than individual receipts. Applicant states that similar to Enfish, the claims are directed to a data format for a combined distributed ledger receipt that is constructed according to a specific format. Applicant further states that claim 16 provides a detailed computer-implement algorithm that cannot be performed in the human mind or with pen and paper, and provides a specific technical solution to a technical problem of reducing memory and bandwidth requirements for cryptographic proofs in a distributed ledger system. Examiner notes, however, that the claims do not require any technical functionality to be performed. The independent claims only involve the functions of: “receive from a client a request for a receipt of a first transaction of said executed transactions and a request for a receipt of a second transaction of said executed transactions, the first and second transactions being of different leaves of the hash tree,” “determine compressed path information comprising a minimum set of values required to generate the hash root from either the first transaction or the second transaction given the first transaction and the second transaction,” “generate a combined receipt for the first and second transactions, the combined receipt comprising: i) the determined compressed path information; and ii) signatures of one or more of the replicas which signed the hash root,” and “provide the combined receipt to the client.” These steps only involve analyzing information in response to a request to make a determination about information to include in a minimum set of values, and outputting the result. While the result of the analysis and determinations may be to determine a reduced set of data, and a byproduct of this reduced set of data is that less storage is needed to store the set of data, the recited claims do not detail any technical functionality involved in improving the technological aspects of computer storage. Reducing storage space needed to store a reduced set of digital information on a computer is a byproduct of reducing the amount of information, in the same way that reducing the amount of paper needed to write a reduced set of written data is a byproduct of reducing the amount of information. Similarly, the detailed steps for determining the reduced amount of information in claim 16 are also abstract, as they describe further analysis of the data without requiring any technical functionality. Therefore, the claims are directed to an abstract idea, and do not provide a practical application or significantly more than the abstract idea. 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. In the instant case, claims 1-12 and 16 are directed to a method, claims 13, 15, and 17-18 are directed to a non-transitory machine-readable storage medium, and claims 14 and 19-20 are directed to a replica comprising a processor and a memory. Therefore, these claims fall within the four statutory categories of invention. The claims recite determining a set of values to use to generate a receipt for two transactions, and generating a signed receipt using the values in response to a user request for a receipt, which is an abstract idea. Specifically, the claims recite “receive from a client a request for a receipt of a first transaction of said executed transactions and a request for a receipt of a second transaction of said executed transactions, the first and second transactions being of different leaves of the hash tree,” “determine compressed path information comprising a minimum set of values required to generate the hash root from either the first transaction or the second transaction given the first transaction and the second transaction,” “generate a combined receipt for the first and second transactions, the combined receipt comprising: i) the determined compressed path information; and ii) signatures of one or more of the replicas which signed the hash root,” and “provide the combined receipt to the client,” which is grouped within the “certain methods of organizing human activity” grouping of abstract ideas in prong one of step 2A of the Alice/Mayo test (MPEP 2106.04 & 2106.04(a)) because it describes a process for creating a receipt for transactions based on transaction information, which is a commercial or legal interaction. Additionally, the claims are also grouped within the “mental processes” grouping of abstract ideas because they describe a process of receiving a request for a receipt, analyzing information regarding a minimum set of values needed to generate a hash root, and providing the determined information as a receipt, which can be practically performed by a human using a pen and paper. Accordingly, the claims recite an abstract idea (See MPEP 2106.04(a)). This judicial exception is not integrated into a practical application because, when analyzed under prong two of step 2A of the Alice/Mayo test (See MPEP 2106.04(d)), the additional elements of the claims such as the use of a distributed ledger maintained by a network of replicas configured to implement a distributed ledger system, a non-transitory machine-readable medium, and a replica comprising a processor and memory in a network of replicas, merely use a computer as a tool to perform an abstract idea. Specifically, these additional elements perform the steps or functions of “receive from a client a request for a receipt of a first transaction of said executed transactions and a request for a receipt of a second transaction of said executed transactions, the first and second transactions being of different leaves of the hash tree,” “determine compressed path information comprising a minimum set of values required to generate the hash root from either the first transaction or the second transaction given the first transaction and the second transaction,” “generate a combined receipt for the first and second transactions, the combined receipt comprising: i) the determined compressed path information; and ii) signatures of one or more of the replicas which signed the hash root,” and “provide the combined receipt to the client.” Viewed as a whole, the use of a processor/computer as a tool to implement the abstract idea does not integrate the abstract idea into a practical application because it requires no more than a computer performing functions that correspond to acts required to carry out the abstract idea. The additional elements do not involve improvements to the functioning of a computer, or to any other technology or technical field (MPEP 2106.05(a)), and the claims do not apply or use the abstract idea in some other meaningful way beyond generally linking the use of the abstract idea to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception (MPEP 2106.05(e) and Vanda Memo). Therefore, the claims do not, for example, purport to improve the functioning of a computer. Nor do they effect an improvement in any other technology or technical field. Accordingly, the additional elements do not impose any meaningful limits on practicing the abstract idea, and the claims are directed to an abstract idea. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when analyzed under step 2B of the Alice/Mayo test (See MPEP 2106.05), the additional elements of using a distributed ledger maintained by a network of replicas configured to implement a distributed ledger system, a non-transitory machine-readable medium, and a replica comprising a processor and memory in a network of replicas to perform the steps amounts to no more than using a computer or processor to automate and/or implement the abstract idea of determining a set of values to use to generate a receipt for two transactions, and generating a signed receipt using the values in response to a user request for a receipt. As discussed above, taking the claim elements separately, these additional elements perform the steps or functions of “receive from a client a request for a receipt of a first transaction of said executed transactions and a request for a receipt of a second transaction of said executed transactions, the first and second transactions being of different leaves of the hash tree,” “determine compressed path information comprising a minimum set of values required to generate the hash root from either the first transaction or the second transaction given the first transaction and the second transaction,” “generate a combined receipt for the first and second transactions, the combined receipt comprising: i) the determined compressed path information; and ii) signatures of one or more of the replicas which signed the hash root,” and “provide the combined receipt to the client.” These functions correspond to the actions required to perform the abstract idea. Viewed as a whole, the combination of elements recited in the claims merely recite the concept of determining a set of values to use to generate a receipt for two transactions, and generating a signed receipt using the values in response to a user request for a receipt. Therefore, the use of these additional elements does no more than employ the computer as a tool to automate and/or implement the abstract idea. The use of a computer or processor to merely automate and/or implement the abstract idea cannot provide significantly more than the abstract idea itself (MPEP 2106.05 (f) & (h)). Therefore, the claim is not patent eligible. Dependent claims 2-12 and 15 further describe the abstract idea of determining a set of values to use to generate a receipt for two transactions, and generating a signed receipt using the values in response to a user request for a receipt. Specifically, claim 2 describes the acts as being performed by a “replica”, claim 7 describes the acts as being performed by a client device, and claims 3-6, and 17-20 recite receiving a request for the receipt and performing the functions in response to the request, which is part of the abstract idea. The use of a replica or client device to perform the claimed functions does not provide a practical application or significantly more than the abstract idea because it only involves using a computer as a tool to automate and/or implement the abstract idea. Claims 8-12 and 15 describe obtaining separate receipts for each transaction, and using them to generate the combined receipt. This recites further detail regarding the creation of the receipt, which is part of the abstract idea. Claim 16 describes evaluating data in a hash tree to identify necessary hash value and omit redundant ones, which is also abstract as it only involves analyzing information to make a decision about whether or not to include it in the final set of values. The dependent claims do not include additional elements that integrate the abstract idea into a practical application or that provide significantly more than the abstract idea. Therefore, the dependent claims are also not patent eligible. Statement Regarding Prior Art Vaughan, et al., “Chainpoint – A Scalable Protocol for Recording Data in the Blockchain and Generating Blockchain Receipts”, July 22, 2015 (“Vaughan”) discloses a blockchain receipt for a first transaction that includes path information in the form of a Merkle Proof comprising values required to generate a hash root (Vaughan p. 2, Section Titled “Creating Blockchain Receipts”). Additionally, McDonald, Jim “Understanding Sparse Merkle Multiproofs” March 1, 2019, (“McDonald”) discloses multiproofs, which are a group of proofs against the same Merkle tree wrapped up together and “sparse multiproofs” which are Merkle multiproofs with intermediate hashes removed if those intermediate hashes can be calculated by a verified (McDonald p. 2-5, Sections Titled “Multiproofs” and “Sparse Multiproofs”). The use of a multiproof in the blockchain receipt of Vaughan would results in a combined receipt. Additionally, Sivathanu, et al. (US 2021/0014042) (“Sivathanu”) discloses a Merkle root being signed by multiple nodes or “replicas” (Sivathanu ¶ 76). Further, Rambaja, et al. “Compact Merkle Multiproofs” arXiv, 2/24/2020, available at: https://arxiv.org/pdf/2002.07648. (“Rambaja”) discloses compact Merkle multiproofs with less elements than a sparse multiproof (Rambaja Section III “The Compact Merkle Multiproof”). However, McDonald and Rambaja do not specifically disclose that the proofs are for two different transactions, and prior art references do not disclose, neither singly nor in combination, determining compressed path information that can generate the hash root from either the first transaction or second transaction given the first transaction and second the second transaction, and generating the combined receipt for both transactions having this compressed path information and a signature of one or more of the replicas which signed the hash root, as required by the claims. Conclusion THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to Mohammad A. Nilforoush whose telephone number is (571)270-5298. The examiner can normally be reached Monday-Friday 12pm-7pm. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, John W. Hayes can be reached at 571-272-6708. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /Mohammad A. Nilforoush/Primary Examiner, Art Unit 3697
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Prosecution Timeline

Jul 07, 2023
Application Filed
Aug 09, 2025
Non-Final Rejection — §101
Oct 28, 2025
Applicant Interview (Telephonic)
Oct 29, 2025
Examiner Interview Summary
Nov 13, 2025
Response Filed
Mar 11, 2026
Final Rejection — §101
Mar 20, 2026
Interview Requested

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

3-4
Expected OA Rounds
29%
Grant Probability
64%
With Interview (+34.8%)
4y 10m
Median Time to Grant
Moderate
PTA Risk
Based on 397 resolved cases by this examiner. Grant probability derived from career allow rate.

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