Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Status of Claims
Applicant filed an amendment on June 29, 2026. Claims 1-27 were pending in the Application. Claims 1, 23-24, and 26 are amended. No new claims have been added. No new claims canceled, with claims 3, 8-9, 11-13, and 19 remaining canceled, and claims 7, 10, 14-18, and 20 remaining non-selected and withdrawn from consideration. Claim 1 is the independent claim, the remaining claims depend on claim 1. Thus, claims 1-2, 4-6, and 21-27 are currently pending. After careful and full consideration of Applicant arguments and amendments, the Examiner finds them to be moot and/or not persuasive.
Response to Arguments
In the context of 35 U.S.C. §101, Applicant respectfully traverses the rejection. Applicant is of the opinion that the claims are statutory and respectfully asserts the following:
The pending claims are not directed to a judicial exception and, even if they were, are integrated into a practical application and are significantly more than any such judicial exception.
Applicant has amended Claim 1 to further emphasize that the claims are directed to patent-eligible subject matter.
Claims 1-2, 4-6 and 21-27 are patent eligible under USPTO Step 2A because they do not recite a judicial exception and are integrated into a practical application.
Claims 1-2, 4-6 and 21-27 are patent eligible because they do not fall under enumerated groupings of abstract idea.
The Office Action improperly "oversimplifies the claims by looking at them generally and failing to account for the specific requirements of the claims".
The instant claims do not merely recite "methods of organizing human activities," but instead recite several detailed steps and features that point to specific improvements in computing device capabilities.
The bolded elements on pages 14-15 of the Applicant Arguments dated June 09, 2026, do not recite "certain methods of organizing human activity" as asserted by the Office Action, because they do not recite "fundamental economic principles or practices ... ; commercial or legal interactions (including ... advertising, marketing or sales activities or behaviors; business relations); [or] managing personal behavior or relationships or interactions between people".
Claims 1-2, 4-6 and 21-27 are patent eligible because they recite a practical application.
Even assuming arguendo that the instant claims do fall into one of the enumerated groupings of abstract ideas, which Applicant does not concede, the claims are patent eligible because they integrate any alleged judicial exception into a practical application.
The claims are patent-eligible because the claims integrate the alleged abstract idea by using a computing system that includes various components such as including at least one of "one or more processors" in a "meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception".
The claim features of "monitoring, in real-time, a data stream from a payment processing system to obtain transaction …”, “automatically generating … using one or more application programming interfaces (APIs), …”, “generating declination statement comprising ... a declination explanation associated with the virtual card number" and "modifying the GUI by providing a real-time notification to the user device indicating that the first virtual card number is invalid" provide for a technical improvement to transaction processing systems that provides a practical application of real-time notification of declinations that include automatically generated "declination explanations" that facilitate "rectifying declination issues with VCN s" in a manner that maintains and improves the customized security features provided by the VCN technology.
The Applicant's claimed technology provides an unconventional improvement in the computerized and dynamic presentation of declination statements.
These are clear advancements over prior technologies because such prior technologies "do not gather declination information from payment processing systems and provide it to the user in a dynamic GUI" such that "users may not realize when a virtual card number has been declined and/or why a virtual card number has been declined".
The claims "apply or use the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment.
By only considering the alleged "additional elements" of the claims, Applicant respectfully submits that Office Action fails to consider the claims "as a whole" when analyzing whether any alleged abstract idea is integrated into a practical application under Step 2A Prong Two, and therefore the rejection is defective.
The Office Action's rejection is improper and requests withdrawal of the rejection.
Similar to Example 37, amended independent Claim 1 recites “receiving, …, an indication of a selection of a feature”, “responsive to receiving one or more new declinations …”, “responsive to determining that a first new declination of the one or more new declinations …, modifying the GUI by providing a real-time notification …”, and “modifying the GUI to receive a request to generate a replacement virtual card number …”, which is analogous to the sample claims presented above because the present system similarly provides for the automatically repositioning of information presented by a GUI based on a selection of a criteria/feature and/or by making a determination that a declination comprises an indication that a first virtual card number is invalid.
Claim 1 also recites “monitoring, in real-time, a data stream …”, “determining, based on monitoring the data stream, that a virtual card number associated with the account has been declined," and "automatically generating, based on the determination that the virtual card number associated with the account has been declined and using one or more application programming interfaces (APIs), one or more declination explanations by converting the one or more declination codes into one or more written descriptions of a cause of a declination," which is similarly analogous to the sample claims presented above because the present system automatically modifies a GUI with the declination statement based on the monitoring of the data stream, making a determination regarding the account and automatically converting declination codes into declination explanations for display in the GUI.
Amended independent Claim 1 is at least as much of a practical application as the sample claim cited in Example 37.
Claims 1-2, 4-6 and 21-27 are patent eligible under USPTO Step 2A because they recite a combination of elements that is significantly more than an abstract idea.
Even if the claims are directed to an abstract idea, which Applicant does not concede, they are patent eligible because they recite an inventive concept that is significantly more than the alleged abstract idea.
The instant claims do involve more than performance of well-understood, routine, and conventional activities previously known to the industry.
The claims are significantly more than an abstract idea because the claims represent an inventive concept that addresses a technical problem in the art of the system being able to communicate real-time declinations of virtual card numbers along with the reason(s) for such declinations, as they occur, as well as providing for a real-time solution for rectifying such a declination associated with a merchant system via an API.
The claims are not directed to an abstract idea and are thus directed to patent eligible subject matter at step one of Alice.
Even if the claims are deemed to be directed to an abstract idea under step one of Alice, they recite an inventive concept such that the claims are directed to patent eligible subject matter under step two of Alice.
Claims 1-2, 4-6 and 21-27 are directed to patent eligible subject matter.
Initially, the Examiner would like to point out that the basis of the rejection is Alice, by applying the subject matter eligibility analysis and flowchart according to MPEP § 2106, which applies a two-step framework, earlier set out in Mayo Collaborative Services v. Prometheus Laboratories, Inc., 566 U.S. 66 (2012), "for distinguishing patents that claim laws of nature, natural phenomena, and abstract ideas from those that claim patent-eligible applications of those concepts." Alice, 573 U.S. at 217.
Under the two-step framework, it must first be determined if "the claims at issue are directed to a patent-ineligible concept." If the claims are determined to be directed to a patent-ineligible concept, e.g., an abstract idea, then the second step of the framework is applied to determine if "the elements of the claim ... contain an "inventive concept" sufficient to 'transform' the claimed abstract idea into a patent-eligible application." (citing Mayo, 566 U.S. at 72-73, 79).
With regard to step one of the Alice framework, we apply a "directed to" two-prong test: 1) evaluate whether the claim recites a judicial exception, and 2) if the claim recites a judicial exception, evaluate whether the claim "applies, relies on, or uses the judicial exception in a manner that imposes a meaningful limit on the judicial exception, such that the claim is more than a drafting effort designed to monopolize the judicial exception," i.e., whether the claim integrates the judicial exception into a practical application. (MPEP §2106.04 II.A.1. and II.B.2.).
The Specification, (PG Pub US 20240412209 A1, para 2), provides evidence as to what the claimed invention is directed. In this case, the specification, (‘209 A1, para 2), discloses that the invention relates to providing a declination statement, and is grouped under “Certain Methods of Organizing Human Activity, commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations)”, in prong one of step 2A. (MPEP §2106.04 II.A.1.).
Claim 1 provides additional evidence, and recites the limitations “receiving, from a user device, authentication data associated with an account; authenticating the user device by comparing the authentication data to account data; monitoring, in real-time, a data stream from a payment processing system to obtain transaction data comprising one or more declination codes; determining, based on the monitoring of the data stream, that a virtual card number associated with the account has been declined; automatically generating, based on the determination that the virtual card number associated with the account has been declined and using one or more application programming interfaces (APIs), one or more declination explanations by converting the one or more declination codes into one or more written descriptions of a cause of a declination; generating a declination statement comprising virtual card information and one or more declinations associated with the account, wherein the virtual card information comprises the virtual card number comprising a primary account number that has been tokenized and at least one of the one or more declinations comprises a declination explanation associated with the virtual card number; generating a graphical user interface (GUI) comprising the declination statement; receiving, from the user device, an indication of a selection of a feature; transmitting the GUI to the user device for display; receiving, from the payment processing system, one or more new declinations associated with the account; responsive to receiving one or more new declinations associated with the account, automatically modifying the GUI to further comprise the one or more new declinations and, as the one or more new declinations are received, dynamically reordering a list of declinations displayed by the GUI based on the feature, wherein the list of declinations comprises the one or more declinations associated with the account and the one or more new declinations associated with the account; responsive to determining that a first new declination of the one or more new declinations comprises an indication that a first virtual card number is invalid, modifying the GUI by providing a real-time notification to the user device indicating that the first virtual card number is invalid; modifying the GUI to receive a request to generate a replacement virtual card number to replace the first virtual card number; and responsive to receiving, the request to generate the replacement virtual card number from the user device, automatically; generating the replacement virtual card number to replace the first virtual card number; and interfacing, via an application programming interface (API), with a merchant system to upload the replacement virtual card number to the merchant system”, which represent the abstract idea of “providing statements with any declination explanation”. The abstract idea is in italics, and the additional elements are in bold. (MPEP §2106.04 II.A.1.).
This judicial exception is not integrated into a practical application because, when analyzed under prong two of step 2A (MPEP §2106.04 II.A.2.), the additional elements of the claim, such as “a system comprising: one or more processors; and memory in communication with the one or more processors and storing instructions that, when executed by the one or more processors, cause the one or more processors to perform the steps of: …”, “a user device”, “a payment processing system”, “using one or more application programming interfaces (APIs)”, “generating a graphical user interface (GUI) comprising the declination statement”, “transmitting the GUI to the user device for display”, “automatically modifying the GUI to further comprise …”, “displayed by the GUI”, “modifying the GUI”, and “an application programming interface (API), with a merchant system”, amount to merely “apply it”, as they represent the use of a computer as a tool to perform an abstract idea. Therefore, the additional elements do not integrate the abstract idea into a practical application as they do no more than represent a computer performing functions that correspond to implementing the acts of “providing statements with any declination explanation”.
Examiner notes the basis of the rejection was, and is not as any mental process covering performance in the mind, but classified as an abstract idea, “providing statements with any declination explanation”, grouped under “Certain Methods of Organizing Human Activity, commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations)”.
With respect to the additional elements operating in a non-conventional and non-generic way and reflecting an improvement to a particular technological environment, the cited additional elements represent the use of a computer as a tool to perform an abstract idea. Therefore, the additional elements do not integrate the abstract idea into a practical application as they do no more than represent a computer performing functions that correspond to implementing the acts of “providing statements with any declination explanation”. The claim is not directed to improving computer functionality nor improving another technology or technical field but improving the abstract idea “providing statements with any declination explanation”. For potential improvement in an abstract idea “providing statements with any declination explanation”, it is important to keep in mind that an improvement in the abstract idea itself (e.g. providing statements with any declination explanation concept) is not an improvement in technology. (MPEP § 2106.04(d)(1)). Therefore, claim 1 is non-statutory.
Finally, Examiner notes the basis of the rejection is Alice, by applying the subject matter eligibility analysis and flowchart according to MPEP § 2106. And, based on this standard, the claims are non-statutory, and correctly rejected under 35 U.S.C. § 101.
In the context of 35 U.S.C. § 112(b), Means-Plus-Function, in the Non-Final Rejection Office Action dated April 06, 2026, Applicant has adequately amended to overcome the rejection under 35 U.S.C. § 112(b), Means-Plus-Function. Applicant has amended claims 1 and 23-24 to eliminate the claim language “element configured to generate” in claim 1; to eliminate the claim language “elements configured to cancel” in claim 23; and to eliminate the claim language “elements configured to modify” in claim 24, to overcome the rejection under 35 U.S.C. § 112(b), Means-Plus-Function. Examiner hereby rescinds the rejections under 35 U.S.C. § 112(b), Means-Plus-Function, of the Non-Final Rejection Office Action dated April 06, 2026.
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 1-2, 4-6, and 21-27 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 1-2, 4-6, and 21-27 are directed to a “system”. Therefore, these claims are directed to one of the four statutory categories of invention.
Claim 1 recites “providing statements with any declination explanation”, which is a form of commercial or legal interactions (i.e., organizing human activity), and therefore, an abstract idea. Specifically, the claim recites “receiving, from a user device, authentication data associated with an account; authenticating the user device by comparing the authentication data to account data; monitoring, in real-time, a data stream from a payment processing system to obtain transaction data comprising one or more declination codes; determining, based on the monitoring of the data stream, that a virtual card number associated with the account has been declined; automatically generating, based on the determination that the virtual card number associated with the account has been declined and using one or more application programming interfaces (APIs), one or more declination explanations by converting the one or more declination codes into one or more written descriptions of a cause of a declination; generating a declination statement comprising virtual card information and one or more declinations associated with the account, wherein the virtual card information comprises the virtual card number comprising a primary account number that has been tokenized and at least one of the one or more declinations comprises a declination explanation associated with the virtual card number; generating a graphical user interface (GUI) comprising the declination statement; receiving, from the user device, an indication of a selection of a feature; transmitting the GUI to the user device for display; receiving, from the payment processing system, one or more new declinations associated with the account; responsive to receiving one or more new declinations associated with the account, automatically modifying the GUI to further comprise the one or more new declinations and, as the one or more new declinations are received, dynamically reordering a list of declinations displayed by the GUI based on the feature, wherein the list of declinations comprises the one or more declinations associated with the account and the one or more new declinations associated with the account; responsive to determining that a first new declination of the one or more new declinations comprises an indication that a first virtual card number is invalid, modifying the GUI by providing a real-time notification to the user device indicating that the first virtual card number is invalid; modifying the GUI to receive a request to generate a replacement virtual card number to replace the first virtual card number; and responsive to receiving, the request to generate the replacement virtual card number from the user device, automatically; generating the replacement virtual card number to replace the first virtual card number; and interfacing, via an application programming interface (API), with a merchant system to upload the replacement virtual card number to the merchant system”. The abstract idea is in italics, and the additional elements are in bold. (MPEP §2106.04 II.A.1.).
This judicial exception is not integrated into a practical application because, when analyzed under prong two of step 2A (MPEP §2106.04 II.A.2.), the additional elements of the claim, such as “a system comprising: one or more processors; and memory in communication with the one or more processors and storing instructions that, when executed by the one or more processors, cause the one or more processors to perform the steps of: …”, “a user device”, “a payment processing system”, “using one or more application programming interfaces (APIs)”, “generating a graphical user interface (GUI) comprising the declination statement”, “transmitting the GUI to the user device for display”, “automatically modifying the GUI to further comprise …”, “displayed by the GUI”, “modifying the GUI”, and “an application programming interface (API), with a merchant system”, amount to merely “apply it”, as they represent the use of a computer as a tool to perform an abstract idea. Therefore, the additional elements do not integrate the abstract idea into a practical application as they do no more than represent a computer performing functions that correspond to implementing the acts of “providing statements with any declination explanation”.
When analyzed under step 2B (MPEP 2106.05 I.A.), the claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception itself. Viewed as a whole, the combination of elements recited in the claim merely describes the concept of “providing statements with any declination explanation” using computer technology (e.g., “one or more processors” and “memory”). Therefore, these additional elements do no more than employ a computer as a tool to implement the abstract idea. And as the computer does no more than serve as a tool to implement the abstract idea, they do not improve computer functionality nor improve another technology or technical field. Therefore, claim 1 is non-statutory.
Dependent claims 2, 4-6, and 21-27 further describe the abstract idea of “providing statements with any declination explanation”, which is insufficient to overcome the rejection of claim 1.
Dependent claims 2, 5, 21, and 24-26 do not recite any new additional elements that integrate the abstract idea into a practical application, and that do no more than represent a computer performing functions that correspond to implementing the acts of “providing statements with any declination explanation”, when analyzed under Step 2A, Prong Two. And, as they do no more than employ a computer as a tool to implement the abstract idea, they do not improve computer functionality nor improve another technology or a technical field, when analyzed under Step 2B.
Dependent claim 4 recites a new additional element of “a database”, which does no more than employ a computer as a tool to implement the abstract idea. And, as it does no more than employ a computer as a tool to implement the abstract idea, it does not improve computer functionality nor improve another technology or a technical field.
Dependent claim 6 recites a new additional element of “a quick response code”, which does no more than employ a computer as a tool to implement the abstract idea. And, as it does no more than employ a computer as a tool to implement the abstract idea, it does not improve computer functionality nor improve another technology or a technical field.
Dependent claim 22 recites a new additional element of “a virtual card”, which does no more than employ a computer as a tool to implement the abstract idea. And, as it does no more than employ a computer as a tool to implement the abstract idea, it does not improve computer functionality nor improve another technology or a technical field.
Dependent claim 23 recites a new additional element of “one or more interactive elements”, which does no more than employ a computer as a tool to implement the abstract idea. And, as it does no more than employ a computer as a tool to implement the abstract idea, it does not improve computer functionality nor improve another technology or a technical field.
Dependent claim 27 recites a new additional element of “an unauthorized website”, which does no more than employ a computer as a tool to implement the abstract idea. And, as it does no more than employ a computer as a tool to implement the abstract idea, it does not improve computer functionality nor improve another technology or a technical field.
Hence, claims 1-2, 4-6, and 21-27 are not patent eligible.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure:
Ramanathan et al (U. S. Patent Application Publication No. 20240378590 A1) – Systems And Methods For Virtual Card Decline Notification
Ramanathan discloses a system for virtual card decline notifications. The system receives declination data regarding a first transaction using a prefunded virtual card. The system determines a reason the prefunded virtual card was declined using rules-based decisioning. The system categorizes the reason into one of one or more predetermined categories. Responsive to the reason being categorized in a select group of the one or more predetermined categories, the system generates a first interactive graphical user interface including an interactive list view showing one or more previous declined transactions using prefunded virtual cards, transmits the first interactive graphical user interface to an administrator device for display, receives a first request for first information regarding the first transaction by selecting the first transaction utilizing the first interactive graphical user interface from the administrator device, generates a second interactive graphical user interface including a detailed view of the first transaction.
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 extension fee 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 date of this final action.
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/STEVEN R CHISM/Examiner, Art Unit 3692
/RYAN D DONLON/Supervisory Patent Examiner, Art Unit 3692 October 1, 2026
