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 .
Claim Objections
Claims 1-3, 6-11, 14-19, and 22-26 are objected to because of the following informalities.
Claims 1, 9 and 17 recite the acronyms "REST" and “ERP”. It is not clear what “REST” and “ERP” represent. The full meaning of the acronyms needs to be recited at the first instance. Appropriate correction is required. Neither the Specification nor the drawings define what these acronyms represent.
For examination purposes, Examiner assumes (not definitively) that these acronyms represent “REpresentational State Transfer” and “Enterprise Resource Planning” respectively.
Claims 2-3, 6-8, 10, 11, 14-16, 18, 19, and 22-26 are rejected by dependencies.
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, 6-11, 14-19, and 22-26 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (abstract idea) without significantly more.
Analysis
Claim 1: Ineligible.
The claim recites a series of acts for providing alerts. The claim is directed to a process, which is a statutory category of invention (Step 1: YES).
The claim is analyzed to determine whether it is directed to a judicial exception. The claim recites the steps of a method executed using a virtual compute instance executing one or more sequences of expense management instructions, the virtual compute instance communicatively coupled to a storage device comprising a database, the method comprising:
querying, using a REST application programming interface (API) call, an expense pre-approval application to obtain a set of expense documents from a first computer associated with a first account that is digitally linked to a credit line account, and receiving, in real-time in response to the REST API call, the set of expense documents, the expense pre-approval application being one of a plurality of federated applications hosted using a multi-tenant distributed computing system that comprises the virtual compute instance;
receiving, from the first computer communicatively coupled to the virtual compute instance, a request for creating expense payment objects;
determining, for each document in the set of expense documents, expense data comprising a type of expense document, time of spend, kind of expense, and a plurality of expense charges; determining whether the credit line account of the first account is specified with a threshold percentage and a threshold amount of credit spend amount;
determining the type of the credit line account corresponding to the first account;
based on the type of document of each expense document in the set of expense documents, identifying a payment gateway among a plurality of payment gateways, each payment gateway executing a plurality of programmatic payment rails that the first account can access; automatically populating a user interface of the expense pre-approval application with one or more payment type fields based on the type of credit line account and the threshold credit spend amount;
using the payment gateway, evaluating preapproved expense charges based on the expense data; creating and storing in the database, a plurality of expense payment objects associated with the preapproved expense charges when a first account database table associated with the credit line account of the first account matches with a second account database table of the payment gateway, and automatically applying the plurality of expense payment objects to reduce account balances of one or more preapproved spending amounts, wherein each expense payment object is associated with a virtual card account;
automatically generating a plurality of expense reports for the preapproved expense charges; receiving an incoming charge having an incoming charge amount;
exporting charge data to an ERP system, wherein the charge data comprises corresponding and offsetting credit and debit entries based on the incoming charge amount;
applying, in parallel to the generation of the plurality of expense reports, the incoming charge with the charge amount to the plurality of expense payment objects by forwarding the incoming charge amount to an associated virtual card account to create reconciliation line items indicating the charge amount against the preapproved expense charges;
transmitting reconciliation records to update the ERP system, wherein the reconciliation records comprise an amount of pre-approval used by the incoming charge and associated data for a first account to be credited and a second account to be charged based on expense lines of the plurality of expense reports.
These limitations, as drafted, are processes that, under its broadest reasonable interpretation, cover performance of the limitations under fundamental economic principles, but for the recitation of generic computer components such as the processors, payment gateway and database. That is, other than reciting this generic device, nothing in the claim precludes the limitations from practically being performed by organizing human activity. These limitations fall under the “certain method of organizing human activity” grouping (Step 2A1-Yes).
Next, the claim is analyzed to determine if it is integrated into a practical application. The claim recites additional elements a computer system, database and payment gateway (processors). These components (processors) in the steps are recited at a high level of generality, i.e., as generic processors performing generic computer functions. These generic processor limitations are no more than mere instructions to apply the exception using generic computer components. The network limitations (including the use of ERP systems and REST API call) are simply field of use that is an attempt to limit the abstract idea to a particular technological environment (see MPEP 2106.05(h)). Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. The claim is directed to the abstract idea (Step 2A2-No).
Next, the claim is analyzed to determine if there are additional claim limitations that individually, or as an ordered combination, ensure that the claim amounts to significantly more than the abstract ideas (whether claim provides inventive concept). As discussed with respect to Step 2A2 above, the additional elements in the claim amount to no more than mere instructions to apply the exception using a generic computer component. The same analysis applies here in Step 2B, i.e., mere instructions to apply an exception using a generic computer component cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B.
Viewing the limitations as an ordered combination does not add anything further than looking at the limitations individually. When viewed either individually, or as an ordered combination, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea itself. Therefore, the claim does not amount to significantly more than the recited abstract idea (Step 2B: NO). The claim is not patent eligible.
Claims 9 and 17 recite corresponding system and non-transitory computer-readable medium equivalents of claim 1. This claim is similarly rejected under the same rationale as claim 1, supra.
Claims 2, 10 and 18 recite presenting a report link for each expense report, wherein the plurality of expense reports are automatically generated for each category of the approved expense charges.
This limitation further narrows the abstract idea, but is nonetheless part of the abstract idea identified in claim 1. The additional elements, as similarly analyzed in claim 1 above, do not integrate the abstract idea into a practical application. The claimed invention as a whole also does not amount to significantly more than the abstract idea. The claim is similarly rejected under the same rationale as claim 1, supra.
Claims 3, 11 and 19 recite reducing the preapproved expense charges with the charge amount.
These limitations further narrow the abstract idea, but are nonetheless part of the abstract idea identified in claim 1. The additional elements are similarly as discussed in the claim 1 analysis, above. Finally, when viewed either individually, or as an ordered combination, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea itself. The claims are similarly rejected under the same rationale as claim 1, supra.
Claims 6, 14 and 22 recite determining the expense data from each of a plurality of document line items, document line strings, document texts, and document descriptions corresponding to expense documents in the set of expense documents.
This limitation further narrows the abstract idea, but is nonetheless part of the abstract idea identified in claim 1. The additional elements, as similarly analyzed in claim 1 above, do not integrate the abstract idea into a practical application. The claimed invention as a whole also does not amount to significantly more than the abstract idea. The claim is similarly rejected under the same rationale as claim 1, supra.
Claims 7, 15 and 23 recite associating each expense payment object with preapproved data that comprises a particular validity period, a particular tolerance limit, a spend amount, and currency of spend linking to the preapproved expense charges; causing to display, a digital view of the expense payment object of a virtual card account with the preapproved data; notifying the first computer with the digital view of the expense payment object for viewing and using to charge against preapproved items accredited to the credit line account.
These limitations further narrow the abstract idea, but are nonetheless part of the abstract idea identified in claim 1. The additional elements are similarly as discussed in the claim 1 analysis, above. Finally, when viewed either individually, or as an ordered combination, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea itself. The claims are similarly rejected under the same rationale as claim 1, supra.
Claims 8 and 16 recite identifying expense corporate card account data when an expense payment object is of corporate card type.
This limitation further narrows the abstract idea, but is nonetheless part of the abstract idea identified in claim 1. The additional elements, as similarly analyzed in claim 1 above, do not integrate the abstract idea into a practical application. The claimed invention as a whole also does not amount to significantly more than the abstract idea. The claim is similarly rejected under the same rationale as claim 1, supra.
Claims 24-26 recite wherein automatically populating the user interface of the expense pre-approval application based on the type of credit line account and the threshold amount of credit spend amount comprises: populating the user interface with a plurality of radio buttons that provide options for the generation of virtual cards as expense payment objects and the generation of different payment methods for pre-approval expenses; validating radio button selections to prevent adding more than one payment type to a single expense pre-approval form.
These limitations further narrow the abstract idea, but is nonetheless part of the abstract idea identified in claim 1. The additional elements, as similarly analyzed in claim 1 above, do not integrate the abstract idea into a practical application. The claimed invention as a whole also does not amount to significantly more than the abstract idea. The claim is similarly rejected under the same rationale as claim 1, supra.
Response to Arguments
Applicant's arguments filed 3/31/2026 have been fully considered but they are not persuasive.
Applicant argues that REST API call is a specific computer networking protocol mechanism for inter-system communication, and that the use of the ERP system recites specific machine-to-machine data exchange between distinct computing systems.
Examiner respectfully disagrees. These limitations are considerations under the Step 2A2 and not Step 2A1. They are considered as additional elements that are generic, and thus do not integrate the abstract idea into a practical application.
These elements are used in a generic manner that is consistence with that they are known to be capable of doing. The claimed invention does not seek to improve the REST API and the ERP system by themselves, they are simply deployed to perform tasks that they are traditionally known for, in carrying out abstract ideas with their inherent advantages including at least “greater speed, efficiency and accuracy”.
Applicant’s citation of Claim 1, Example 42 of the 2019 Revised Patent Subject Matter Eligibility Guidance (2019 PEG) is acknowledged. However, Example respectfully disagrees with the comparison. The claimed invention falls under “certain methods of organizing human activity” grouping of the abstract idea as analyzed above. Referring to Example 42, as an initial matter, the examples are hypothetical and only intended to be illustrative of claim analysis under the 2019 PEG. The examples are to be interpreted based on the fact pattern set forth therein as other facts patterns may have different eligibility outcomes (see the opening statement in the Examples). The outcome is specific to the fact pattern of the application (that is, the findings are not to be applied in a different context, but instead are only applicable to the facts of the Examples). The problem in Example 42 that was overcome was patient data that was located in disparate databases (physician computers) where the data was stored in different formats was inaccessible to other physicians who were treating the same patient. To solve this problem all the data was stored in a central database, the data from the different physician databases was formatted into a standard format. It is the combination of additional elements that makes the hypothetical claim patent eligible. Also, the timing (effective filing date) of a claimed invention is also a factor when analyzing claims. An invention deemed eligible in an era, may be considered routine and ineligible in another. So, those examples are purely hypothetical without any consideration of the timing of the hypothetical claim invention. The facts of the instant claimed invention are different, and not analogous to Example 42. These claims are patent ineligible.
Applicant further argues that new claims 24-26 recite eligible subject matter. In particular, Applicant asserts that the concept improves user navigation of a graphical user interface by providing specific elements such as the radio buttons with validation feature.
In particular, Applicant asserts that radio buttons guide the user through expense pre-approval and prevent input errors (citing to Claim 1 of Example 37 of the 2019 PEG).
Applicant argues that the claimed invention is similar to Example 37 (claim 1) of the issued 2019 PEG, titled “Relocation of Icons on a Graphical User Interface” (“Example 37”). Examiner respectfully disagrees. The Example 37 has to do with relocation of icons on an interface such that frequently used icons are placed closest to the start icon for easy access. The interface as described in the instant claimed invention simply affords a user to be presented with pre-populated radio buttons with validation of a selected button. This has nothing to do with the “structure” of the UI similar to relocation of icons on a UI of Example 37 for navigational purposes. Example 37 does not apply here
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Singh et al. (USPAP 2022/0012817) discusses intelligent expense report determination system.
Joseph et al. (USPAP 2010/0017316) discusses an automated expense report.
Cornelius et al. (USPN 6629081) discusses account settlement and financing in an e-commerce environment.
Leong et al. (USPN 7167844) discusses electronic menu document creator in a virtual financial environment.
Rouseau et al. (USPAP 2019/0236552) teaches customized authentication and disbursement system.
Boulger (USPAP 2002/0184147) teaches system for paying invoices.
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.
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/OLABODE AKINTOLA/Primary Examiner, Art Unit 3691