DETAILED ACTION
Notice of 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
This action is in reply to the first amendment to non-final filed on October 1, 2025.
Claims 1, 2, 3, 5, and 17–20 have been amended and are hereby entered.
Claims 1–20 are currently pending and have been examined.
This action is made FINAL.
Response to Amendment
The amendment filed October 1, 2025 has been entered. Claims 1–20 remain pending in the application.
Claim Rejections - 35 USC § 101
The following is a quotation of 35 U.S.C. 101:
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 17 and 18 are rejected under 35 U.S.C. 101 because the claims are directed to non-statutory subject matter.
The United States Patent and Trademark Office (USPTO) is obliged to give claims their broadest reasonable interpretation consistent with the specification during proceedings before the USPTO. See In re Zletz, 893 F.2d 319 (Fed. Cir. 1989) (during patent examination the pending claims must be interpreted as broadly as their terms reasonably allow). The broadest reasonable interpretation of a claim drawn to a computer readable medium (also called machine readable medium and other such variations) typically covers forms of non-transitory tangible media and transitory propagating signals per se in view of the ordinary and customary meaning of computer readable media, particularly when the specification is silent. See MPEP 2111.01. When the broadest reasonable interpretation of a claim covers a signal per se, the claim must be rejected under 35 U.S.C. § 101 as covering non-statutory subject matter. See In re Nuijten, 500 F.3d 1346, 1356-57 (Fed. Cir. 2007) (transitory embodiments are not directed to statutory subject matter); Interim Examination Instructions for Evaluating Subject Matter Eligibility Under 35 U.S.C. §101, Aug. 24, 2009; p. 2.
The USPTO recognizes that applicants may have claims directed to computer readable media that cover signals per se, which the USPTO must reject under 35 U.S.C. § 101 as covering both non-statutory subject matter and statutory subject matter. In an effort to assist the patent community in overcoming a rejection or potential rejection under 35 U.S.C. § 101 in this situation, the USPTO suggests the following approach. A claim drawn to such a computer readable medium that covers both transitory and non-transitory embodiments may be amended to narrow the claim to cover only statutory embodiments to avoid a rejection under 35 U.S.C. § 101 by adding the limitation “non-transitory” to the claim. Cf. Animals - Patentability, 1077 Off. Gaz. Pat. Office 24 (April 21, 1987) (suggesting that applicants add the limitation “non-human” to a claim covering a multi-cellular organism to avoid a rejection under 35 U.S.C. § 101). Such an amendment would typically not raise the issue of new matter, even when the specification is silent because the broadest reasonable interpretation relies on the ordinary and customary meaning that includes signals per se. The limited situations in which such an amendment could raise issues of new matter occur, for example, when the specification does not support a non-transitory embodiment because a signal per se is the only viable embodiment such that the amended claim is impermissibly broadened beyond the supporting disclosure. See, e.g., Gentry Gallery, Inc. v. Berkline Corp., 134 F.3d 1473 (Fed. Cir. 1998).
Here the broadest reasonable interpretation of the phrase “machine-readable medium” in claim 17, line 1, when read in light of the specification is broad enough to encompass a signal. The specification also does not indicate that the machine-readable medium recited are tangible non-transitory media. Therefore, claim 17 and dependent claim 18 are rejected under 35 USC 101. Appropriate correction is required.
Claims 1–20 are further rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
First of all, claims must be directed to one or more of the following statutory categories: a process, a machine, a manufacture, or a composition of matter. Claims 1–18 are directed to a machine (“A system” and “A machine-readable medium”), and claims 19 and 20 are directed to a process (“A method”). Thus, claims 1–20 satisfy Step One because they are all within one of the four statutory categories of eligible subject matter.
Claims 1–20, however, are directed to an abstract idea without significantly more. For claim 1, the specific limitations that recite an abstract idea are:
receiving . . . a selection, by a first entity, of a product, to be provided by a second entity, wherein the first entity and the second entity are members of an entity network;
receiving . . . an indication of receipt of the product, transmitted . . . by the first entity;
computing . . . a first ranking metric for the second entity of the entity network based on feedback received from the first entity of the entity network, wherein the first ranking metric comprises a timely payment metric, a complete payment metric, or a combination thereof, for a good delivered by the first entity to the second entity;
computing . . . a second ranking metric for the second entity of the entity network based on one or more anonymized financial transactions received . . . from a third entity of the entity network, wherein the third entity comprises a trusted financial entity . . .;
determining, via a statistical analysis, whether the first ranking metric is valid based on the second ranking metric; and
providing . . . the first ranking metric to entities of the entity network based on the validity of the first ranking metric.
The claims, therefore, recite a product transfer, which is the abstract idea of certain methods of organizing human activity because they recite a commercial interaction. The claims also recite computing and validating ranking metrics, which is the abstract idea of mathematical concepts because they recite a mathematical relationship. Finally, the claims also recite comparing ranking metrics, which is the abstract idea of mental processes because they involve observations and evaluations that can be performed by the human mind.
The judicial exception recited above is not integrated into a practical application. The additional elements of the claims are various generic technologies and computer components to implement this abstract idea (“hardware processors”, “memory”, “application programming interface (API)”, “financial system server”, “computing device”, “online”, “machine-readable medium”, and “computer system”). These additional elements are not integrated into a practical application because the invention merely applies the abstract idea to generic computer technology, using the computer to facilitate the transfer and derive the entity ranking metrics. Because the invention is using the computer simply as a tool to perform the abstract idea on, the judicial exception is not integrated into a practical application.
Finally, the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, as discussed above, the additional elements in combination are at a high level of generality such that they amount to no more than mere instructions to apply the abstract idea using generic components. Because merely “applying” the exception using generic computer components cannot provide an inventive concept, the additional elements do not recite significantly more than the judicial exception. Thus, claim 1 is not patent eligible.
Independent claims 17 and 19 are rejected as ineligible subject matter under 35 U.S.C. 101 for substantially the same reasons as independent system claim 1. There are no additional elements recited in these claims other than the generic technology and computer parts discussed above (“machine-readable medium”, “computer system”, “application programming interface (API)”, “financial system server”, “computing device”, and “online”). The only differences are that the features of claim 1 are implemented by computer program instructions in claim 17 and implemented by a method in claim 19. Thus, because the same analysis should be used for all categories of claims, claims 17 and 19 are also not patent eligible. See Alice Corp. Pty. Ltd. v. CLS Bank Int'l, 134 S. Ct. 2347, 2354 (2014).
Dependent claims 2–16, 18, and 20 have been given the full two part analysis, analyzing the additional limitations both individually and in combination. The dependent claims, when analyzed individually and in combination, are also held to be patent ineligible under 35 U.S.C. 101.
For claims 2–5, 11–13, 18, and 20, the additional recited limitations of these claims merely further narrow the abstract idea discussed above. These dependent claims only narrow the product transfer recited in claims 1, 17, and 19 by further specifying the parties and details of the transaction—“financial entities”, “financial transactions detailing a payment for the product”, “a good, a service, or a combination”, “credit transaction”, “currency comprises one or more points”, “debit transaction”, “grouped entity”, “virtual company”, and “wholesale costing transaction”.
For claims 6–10, the additional recited limitations of these claims merely further narrow the abstract idea discussed above. These dependent claims only narrow the product transfer recited in claim 1 by further specifying how the ranking is determined—“calculate a difference value . . . inside a valid difference range”, “based on a social network”, “members . . . have submitted ranking values . . . compared to a median”, “ranking values are disposed in a statistical lower . . . or . . . upper quartile”, and “payment . . . goods . . . services . . . (ESG) . . . (DEI) metric, or a combination”.
For claims 14–16, the additional recited limitations of these claims are merely directed to an abstract idea. These dependent claims only recite creating an entity network with various features and connections, which is the abstract idea of mental processes because they involve observations and evaluations that can be performed by the human mind.
Claim Rejections - 35 USC § 103
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 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, 2, 6, 10–13, and 17–20 are rejected under 35 U.S.C. 103 as being unpatentable over Bond et al., U.S. Patent App. No. 2024/0193643 (“Bond”) in view of Pallaghy et al., U.S. Patent App. No. 2016/0027129 (“Pallaghy”) and Psota et al., U.S. Patent App. No. 2019/0362397 (“Psota”).
For claim 1, Bond teaches:
A system comprising (¶ 61: example system):
one or more hardware processors (¶ 62: processor); and
at least one memory storing instructions that cause the one or more hardware processors to perform operations comprising (¶ 62–63: memory storing machine readable instructions executed by processor):
receiving, via an application programming interface (API) at a financial system server, a selection, by a first entity, of a product, to be provided by a second entity (¶ 57: identification of product purchased by user; ¶ 45: communications with server through API), . . .;
receiving, via the API at the financial system server, an indication of receipt of the product, transmitted via a computing device communicatively coupled to the financial system server, by the first entity (¶ 57: server receives indication of product purchase receipt from electronic device of user);
Bond does not teach: wherein the first entity and the second entity are members of an entity network; computing, at the financial system server, a first ranking metric for the second entity of the entity network based on feedback received from the first entity of the entity network, wherein the first ranking metric comprises a timely payment metric, a complete payment metric, or a combination thereof, for a good delivered by the first entity to the second entity; computing, at the financial system server, a second ranking metric for the second entity of the entity network based on one or more anonymized financial transactions received via a financial network used by the financial system server from a third entity of the entity network, wherein the third entity comprises a trusted financial entity of the financial network; determining, via statistical analysis, whether the first ranking metric is valid based on the second ranking metric; and providing for online access, via the financial system server, the first ranking metric to entities of the entity network based on the validity of the first ranking metric.
Pallaghy, however, teaches:
wherein the first entity and the second entity are members of an entity network (¶ 59: peer-to-peer network of entities);
computing, at the financial system server, a first ranking metric for the second entity of the entity network based on feedback received from the first entity of the entity network (¶ 87–88: rating based on responses from rating entity regarding ratee);
determining . . . whether the first ranking metric is valid based on the second ranking metric (¶ 90: response scores provided by rating entities compared); and
providing for online access, via the financial system server, the first ranking metric to entities of the entity network based on the validity of the first ranking metric (¶ 94, 115–116: rating scores accumulated and presented).
It would have been obvious for one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the product purchase in Bond by adding the entity rating from Pallaghy. One of ordinary skill in the art would have been motivated to make this modification for the purpose of improving entity ratings within entity networks—a benefit explicitly disclosed by Pallaghy (¶ 12: need for more advanced and improved systems for providing entity ratings; ¶ 30: invention addresses need in part through comparing rating scores).
The combination of Bond and Pallaghy does not teach: wherein the first ranking metric comprises a timely payment metric, a complete payment metric, or a combination thereof, for a good delivered by the first entity to the second entity; computing, at the financial system server, a second ranking metric for the second entity of the entity network based on one or more anonymized financial transactions received via a financial network used by the financial system server from a third entity of the entity network, wherein the third entity comprises a trusted financial entity of the financial network; and via statistical analysis.
Psota, however, teaches:
wherein the first ranking metric comprises a timely payment metric, a complete payment metric, or a combination thereof, for a good delivered by the first entity to the second entity (¶ 391: factors include timely payment for shipments);
computing, at the financial system server, a second ranking metric for the second entity of the entity network based on one or more anonymized financial transactions received via a financial network used by the financial system server from a third entity of the entity network (¶ 297: transaction records received including bank records; ¶ 377: transaction records are anonymous), wherein the third entity comprises a trusted financial entity of the financial network (¶ 424: information received from trusted organizations); and
via a statistical analysis (¶ 189, 209: statistical measures applied to analyzes entity ratings).
It would have been obvious for one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the product purchase in Bond and the entity rating in Pallaghy by adding the transaction records from Psota. One of ordinary skill in the art would have been motivated to make this modification for the purpose of facilitating receiving information for selecting suppliers—a benefit explicitly disclosed by Psota (¶ 7–8: need for obtaining information on suppliers to more easily select them; ¶ 9–10: invention addresses need in part through rating system). Bond, Pallaghy, and Psota are all related in part to entity transactions, so one of ordinary skill in the art would have been motivated to make these transactions even more efficient by combining these references together.
For claim 2, Bond, Pallaghy, and Psota teach all the limitations of claim 1 above, and Bond further teaches:
The system of claim 1, wherein the third entity of the entity network comprises a financial entity and wherein the one or more anonymized financial transactions comprise one or more anonymized financial transactions detailing a payment for the product, to the second entity, wherein the product comprises a good, a service, or a combination thereof (¶ 25: entity can be any type of company, and purchase is for item, product, or service).
For claim 6, Bond, Pallaghy, and Psota teach all the limitations of claim 1 above, and Bond further teaches:
The system of claim 1, wherein determining whether the first ranking metric is valid based on the second ranking metric comprises comparing the first ranking metric to the second ranking metric to calculate a difference value, and if the difference value is inside a valid difference range, then determining that the first ranking metric is valid (¶ 107–108: different rating threshold values for comparisons).
For claim 10, Bond, Pallaghy, and Psota teach all the limitations of claim 1 above, and Pallaghy further teaches:
The system of claim 1, wherein the first ranking metric comprises a payment metric, a goods metric, a services metric, an environmental, social, and governance (ESG) metric, a diversity, equity, and inclusion (DEI) metric, or a combination thereof (¶ 25: entity can be any type of company, and purchase is for item, product, or service).
It would have been obvious for one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the product purchase in Bond and the transaction records in Psota by adding the entity rating from Pallaghy. One of ordinary skill in the art would have been motivated to make this modification for the purpose of improving entity ratings within entity networks—a benefit explicitly disclosed by Pallaghy (¶ 12: need for more advanced and improved systems for providing entity ratings; ¶ 30: invention addresses need in part through comparing rating scores). Bond, Pallaghy, and Psota are all related in part to entity transactions, so one of ordinary skill in the art would have been motivated to make these transactions even more efficient by combining these references together.
For claim 11, Bond, Pallaghy, and Psota teach all the limitations of claim 1 above, and Bond further teaches:
The system of claim 1, wherein the first entity comprises a grouped entity having a plurality of entity members (¶ 25: entity is set of retail stores).
For claim 12, Bond, Pallaghy, and Psota teach all the limitations of claim 11 above, and Bond further teaches:
The system of claim 11, wherein the grouped entity is organized into a virtual company (¶ 25: entity can also include ecommerce platform).
For claim 13, Bond, Pallaghy, and Psota teach all the limitations of claim 10 above, and Bond further teaches:
The system of claim 10, wherein the product is provided by the second entity via a wholesale costing transaction (¶ 25: entity to the product purchase includes wholesaler).
For claim 17, Bond teaches:
A machine-readable medium storing instructions that, when executed by a computer system, cause the computer system to perform operations comprising (¶ 62–63: memory storing machine readable instructions executed by processor):
receiving, via an application programming interface (API) at a financial system server, a selection, by a first entity, of a product, to be provided by a second entity (¶ 57: identification of product purchased by user; ¶ 45: communications with server through API), . . .;
receiving, via the API at the financial system server, an indication of receipt of the product, transmitted via a computing device communicatively coupled to the financial system server, by the first entity (¶ 57: server receives indication of product purchase receipt from electronic device of user);
Bond does not teach: wherein the first entity and the second entity are members of an entity network; computing, at the financial system server, a first ranking metric for the second entity of the entity network based on feedback received from the first entity of the entity network, wherein the first ranking metric comprises a timely payment metric, a complete payment metric, or a combination thereof, for a good delivered by the first entity to the second entity; computing, at the financial system server, a second ranking metric for the second entity of the entity network based on one or more anonymized financial transactions received via a financial network used by the financial system server from a third entity of the entity network, wherein the third entity comprises a trusted financial entity of the financial network; determining, via statistical analysis, whether the first ranking metric is valid based on the second ranking metric; and providing for online access, via the financial system server, the first ranking metric to entities of the entity network based on the validity of the first ranking metric.
Pallaghy, however, teaches:
wherein the first entity and the second entity are members of an entity network (¶ 59: peer-to-peer network of entities);
computing, at the financial system server, a first ranking metric for the second entity of the entity network based on feedback received from the first entity of the entity network (¶ 87–88: rating based on responses from rating entity regarding ratee);
determining . . . whether the first ranking metric is valid based on the second ranking metric (¶ 90: response scores provided by rating entities compared); and
providing for online access, via the financial system server, the first ranking metric to entities of the entity network based on the validity of the first ranking metric (¶ 94, 115–116: rating scores accumulated and presented).
It would have been obvious for one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the product purchase in Bond by adding the entity rating from Pallaghy. One of ordinary skill in the art would have been motivated to make this modification for the purpose of improving entity ratings within entity networks—a benefit explicitly disclosed by Pallaghy (¶ 12: need for more advanced and improved systems for providing entity ratings; ¶ 30: invention addresses need in part through comparing rating scores).
The combination of Bond and Pallaghy does not teach: wherein the first ranking metric comprises a timely payment metric, a complete payment metric, or a combination thereof, for a good delivered by the first entity to the second entity; computing, at the financial system server, a second ranking metric for the second entity of the entity network based on one or more anonymized financial transactions received via a financial network used by the financial system server from a third entity of the entity network, wherein the third entity comprises a trusted financial entity of the financial network; and via statistical analysis.
Psota, however, teaches:
wherein the first ranking metric comprises a timely payment metric, a complete payment metric, or a combination thereof, for a good delivered by the first entity to the second entity (¶ 391: factors include timely payment for shipments);
computing, at the financial system server, a second ranking metric for the second entity of the entity network based on one or more anonymized financial transactions received via a financial network used by the financial system server from a third entity of the entity network (¶ 297: transaction records received including bank records; ¶ 377: transaction records are anonymous), wherein the third entity comprises a trusted financial entity of the financial network (¶ 424: information received from trusted organizations); and
via a statistical analysis (¶ 189, 209: statistical measures applied to analyzes entity ratings).
It would have been obvious for one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the product purchase in Bond and the entity rating in Pallaghy by adding the transaction records from Psota. One of ordinary skill in the art would have been motivated to make this modification for the purpose of facilitating receiving information for selecting suppliers—a benefit explicitly disclosed by Psota (¶ 7–8: need for obtaining information on suppliers to more easily select them; ¶ 9–10: invention addresses need in part through rating system). Bond, Pallaghy, and Psota are all related in part to entity transactions, so one of ordinary skill in the art would have been motivated to make these transactions even more efficient by combining these references together.
For claim 18, Bond, Pallaghy, and Psota teach all the limitations of claim 17 above, and Bond further teaches:
The machine-readable medium of claim 17, wherein the third entity of the entity network comprises a financial entity and wherein the one or more anonymized financial transactions comprise one or more anonymized financial transactions detailing a payment for the product, to the second entity, wherein the product comprises a good, a service, or a combination thereof (¶ 25: entity can be any type of company, and purchase is for item, product, or service).
For claim 19, Bond teaches:
A method comprising (¶ 56: example method):
receiving, via an application programming interface (API) at a financial system server, a selection, by a first entity, of a product, to be provided by a second entity (¶ 57: identification of product purchased by user; ¶ 45: communications with server through API), . . .;
receiving, via the API at the financial system server, an indication of receipt of the product, transmitted via a computing device communicatively coupled to the financial system server (¶ 57: server receives indication of product purchase receipt from electronic device of user);
Bond does not teach: wherein the first entity and the second entity are members of an entity network; computing, at the financial system server, a first ranking metric for the second entity of the entity network based on feedback received from the first entity of the entity network, wherein the first ranking metric comprises a timely payment metric, a complete payment metric, or a combination thereof, for a good delivered by the first entity to the second entity; computing, at the financial system server, a second ranking metric for the second entity of the entity network based on one or more anonymized financial transactions received via a financial network used by the financial system server from a third entity of the entity network, wherein the third entity comprises a trusted financial entity of the financial network; determining, via statistical analysis, whether the first ranking metric is valid based on the second ranking metric; and providing for online access, via the financial system server, the first ranking metric to entities of the entity network based on the validity of the first ranking metric.
Pallaghy, however, teaches:
wherein the first entity and the second entity are members of an entity network (¶ 59: peer-to-peer network of entities);
computing, at the financial system server, a first ranking metric for the second entity of the entity network based on feedback received from the first entity of the entity network (¶ 87–88: rating based on responses from rating entity regarding ratee);
determining . . . whether the first ranking metric is valid based on the second ranking metric (¶ 90: response scores provided by rating entities compared); and
providing for online access, via the financial system server, the first ranking metric to entities of the entity network based on the validity of the first ranking metric (¶ 94, 115–116: rating scores accumulated and presented).
It would have been obvious for one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the product purchase in Bond by adding the entity rating from Pallaghy. One of ordinary skill in the art would have been motivated to make this modification for the purpose of improving entity ratings within entity networks—a benefit explicitly disclosed by Pallaghy (¶ 12: need for more advanced and improved systems for providing entity ratings; ¶ 30: invention addresses need in part through comparing rating scores).
The combination of Bond and Pallaghy does not teach: wherein the first ranking metric comprises a timely payment metric, a complete payment metric, or a combination thereof, for a good delivered by the first entity to the second entity; computing, at the financial system server, a second ranking metric for the second entity of the entity network based on one or more anonymized financial transactions received via a financial network used by the financial system server from a third entity of the entity network, wherein the third entity comprises a trusted financial entity of the financial network; and via statistical analysis.
Psota, however, teaches:
wherein the first ranking metric comprises a timely payment metric, a complete payment metric, or a combination thereof, for a good delivered by the first entity to the second entity (¶ 391: factors include timely payment for shipments);
computing, at the financial system server, a second ranking metric for the second entity of the entity network based on one or more anonymized financial transactions received via a financial network used by the financial system server from a third entity of the entity network (¶ 297: transaction records received including bank records; ¶ 377: transaction records are anonymous), wherein the third entity comprises a trusted financial entity of the financial network (¶ 424: information received from trusted organizations); and
via a statistical analysis (¶ 189, 209: statistical measures applied to analyzes entity ratings).
It would have been obvious for one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the product purchase in Bond and the entity rating in Pallaghy by adding the transaction records from Psota. One of ordinary skill in the art would have been motivated to make this modification for the purpose of facilitating receiving information for selecting suppliers—a benefit explicitly disclosed by Psota (¶ 7–8: need for obtaining information on suppliers to more easily select them; ¶ 9–10: invention addresses need in part through rating system). Bond, Pallaghy, and Psota are all related in part to entity transactions, so one of ordinary skill in the art would have been motivated to make these transactions even more efficient by combining these references together.
For claim 20, Bond, Pallaghy, and Psota teach all the limitations of claim 19 above, and Bond further teaches:
The method of claim 19, wherein the third entity of the entity network comprises a financial entity and wherein the one or more anonymized financial transactions comprise one or more financial transactions detailing a payment for the product, to the second entity, wherein the product comprises a good, a service, or a combination thereof (¶ 25: entity can be any type of company, and purchase is for item, product, or service).
Claims 3–5 are rejected under 35 U.S.C. 103 as being unpatentable over Bond et al., U.S. Patent App. No. 2024/0193643 (“Bond”) in view of Pallaghy et al., U.S. Patent App. No. 2016/0027129 (“Pallaghy”); Psota et al., U.S. Patent App. No. 2019/0362397 (“Psota”); and Lavian et al., U.S. Patent App. No. 2018/0130102 (“Lavian”).
For claim 3, Bond, Pallaghy, and Psota teach all the limitations of claim 2 above. The combination of Bond, Pallaghy, and Psota does not teach: wherein the one or more anonymized financial transactions comprises a credit transaction crediting a currency to an account of the second entity.
Lavian, however, teaches:
The system of claim 2, wherein the one or more anonymized financial transactions comprises a credit transaction crediting a currency to an account of the second entity (¶ 58: credit points to account for exchange).
It would have been obvious for one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the product purchase in Bond, the entity rating in Pallaghy, and the transaction records in Psota by adding the crediting from Lavian. One of ordinary skill in the art would have been motivated to make this modification for the purpose of facilitating the exchanging of products and services—a benefit explicitly disclosed by Lavian (¶ 7: need for resource sharing that is more efficient; ¶ 58: invention provides system of credit points for exchanging products). Bond, Pallaghy, Psota, and Lavian are all related in part to entity transactions, so one of ordinary skill in the art would have been motivated to make these transactions even more efficient by combining these references together.
For claim 4, Bond, Pallaghy, Psota, and Lavian teach all the limitations of claim 3 above, and Lavian further teaches:
The system of claim 3, wherein the currency comprises one or more points accrued based on receiving a favorable ranking metric (¶ 193: points credited dependent upon ratings or reviews).
It would have been obvious for one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the product purchase in Bond, the entity rating in Pallaghy, and the transaction records in Psota by adding the crediting from Lavian. One of ordinary skill in the art would have been motivated to make this modification for the purpose of facilitating the exchanging of products and services—a benefit explicitly disclosed by Lavian (¶ 7: need for resource sharing that is more efficient; ¶ 58: invention provides system of credit points for exchanging products). Bond, Pallaghy, Psota, and Lavian are all related in part to entity transactions, so one of ordinary skill in the art would have been motivated to make these transactions even more efficient by combining these references together.
For claim 5, Bond, Pallaghy, Psota, and Lavian teach all the limitations of claim 3 above, and Lavian further teaches:
The system of claim 3, wherein the one or more anonymized financial transactions comprise a debit transaction debiting the currency to a second account of the first entity (¶ 58: debit points from account for exchange).
It would have been obvious for one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the product purchase in Bond, the entity rating in Pallaghy, and the transaction records in Psota by adding the crediting from Lavian. One of ordinary skill in the art would have been motivated to make this modification for the purpose of facilitating the exchanging of products and services—a benefit explicitly disclosed by Lavian (¶ 7: need for resource sharing that is more efficient; ¶ 58: invention provides system of credit points for exchanging products). Bond, Pallaghy, Psota, and Lavian are all related in part to entity transactions, so one of ordinary skill in the art would have been motivated to make these transactions even more efficient by combining these references together.
Claims 7–9 are rejected under 35 U.S.C. 103 as being unpatentable over Bond et al., U.S. Patent App. No. 2024/0193643 (“Bond”) in view of Pallaghy et al., U.S. Patent App. No. 2016/0027129 (“Pallaghy”); Psota et al., U.S. Patent App. No. 2019/0362397 (“Psota”); and Fuller et al., U.S. Patent App. No. 2016/0117695 (“Fuller”).
For claim 7, Bond, Pallaghy, and Psota teach all the limitations of claim 1 above. The combination of Bond, Pallaghy, and Psota does not teach: wherein the operations comprise determining whether the first ranking metric is valid based on a social network.
Fuller, however, teaches:
The system of claim 1, wherein the operations comprise determining whether the first ranking metric is valid based on a social network (¶ 55: social networks used to confirm rating score).
It would have been obvious for one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the product purchase in Bond, the entity rating in Pallaghy, and the transaction records in Psota by adding the social network rating from Fuller. One of ordinary skill in the art would have been motivated to make this modification for the purpose of improving entity ratings—a benefit explicitly disclosed by Fuller (¶ 5–8: need for managing reputations and ratings for both parties; ¶ 18: invention provides reputations management system). Bond, Pallaghy, Psota, and Fuller are all related in part to entity transaction ratings, so one of ordinary skill in the art would have been motivated to make these ratings even more accurate by combining these references together.
For claim 8, Bond, Pallaghy, Psota, and Fuller teach all the limitations of claim 7 above, and Fuller further teaches:
The system of claim 7, wherein determining whether the first ranking metric is valid based on the social network comprises determining, via graph analysis, that members of the social network have submitted ranking values lower or higher when compared to a median ranking value (¶ 49: rating compared to median in social network).
It would have been obvious for one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the product purchase in Bond, the entity rating in Pallaghy, and the transaction records in Psota by adding the social network rating from Fuller. One of ordinary skill in the art would have been motivated to make this modification for the purpose of improving entity ratings—a benefit explicitly disclosed by Fuller (¶ 5–8: need for managing reputations and ratings for both parties; ¶ 18: invention provides reputations management system). Bond, Pallaghy, Psota, and Fuller are all related in part to entity transaction ratings, so one of ordinary skill in the art would have been motivated to make these ratings even more accurate by combining these references together.
For claim 9, Bond, Pallaghy, Psota, and Fuller teach all the limitations of claim 8 above, and Fuller further teaches:
The system of claim 8, wherein the submitted ranking values are lower or higher if the submitted ranking values are disposed in a statistical lower quartile or in a statistical upper quartile from the median ranking value (¶ 22: reliability of rating determined from statistical analysis of percentile quartiles).
It would have been obvious for one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the product purchase in Bond, the entity rating in Pallaghy, and the transaction records in Psota by adding the social network rating from Fuller. One of ordinary skill in the art would have been motivated to make this modification for the purpose of improving entity ratings—a benefit explicitly disclosed by Fuller (¶ 5–8: need for managing reputations and ratings for both parties; ¶ 18: invention provides reputations management system). Bond, Pallaghy, Psota, and Fuller are all related in part to entity transaction ratings, so one of ordinary skill in the art would have been motivated to make these ratings even more accurate by combining these references together.
Claims 14–16 are rejected under 35 U.S.C. 103 as being unpatentable over Bond et al., U.S. Patent App. No. 2024/0193643 (“Bond”) in view of Pallaghy et al., U.S. Patent App. No. 2016/0027129 (“Pallaghy”); Psota et al., U.S. Patent App. No. 2019/0362397 (“Psota”); and Sun et al., U.S. Patent App. No. 2013/0097056 (“Sun”).
For claim 14, Bond, Pallaghy, and Psota teach all the limitations of claim 1 above. The combination of Bond, Pallaghy, and Psota does not teach: wherein the operations comprise operations for creating the entity network and for populating the entity network with a plurality of entities.
Sun, however, teaches:
The system of claim 1, wherein the operations comprise operations for creating the entity network and for populating the entity network with a plurality of entities (¶ 65: network constructed with plurality of nodes representative of users).
It would have been obvious for one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the product purchase in Bond, the entity rating in Pallaghy, and the transaction records in Psota by adding the user node network from Sun. One of ordinary skill in the art would have been motivated to make this modification for the purpose of improving service recommendations through trust models—a benefit explicitly disclosed by Sun (¶ 6: need for improved approach for selecting and recommending service; ¶ 47: invention constructs user trust network). Bond, Pallaghy, Psota, and Sun are all related in part to entity transaction networks, so one of ordinary skill in the art would have been motivated to make these networks even more effective by combining these references together.
For claim 15, Bond, Pallaghy, and Psota teach all the limitations of claim 1 above. The combination of Bond, Pallaghy, and Psota does not teach: wherein the operations comprise operations for creating a virtual supply chain, a virtual marketplace, a virtual mentorship relationship, or a combination thereof.
Sun, however, teaches:
The system of claim 1, wherein the operations comprise operations for creating a virtual supply chain, a virtual marketplace, a virtual mentorship relationship, or a combination thereof (¶ 47, 66: service marketplace portal).
It would have been obvious for one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the product purchase in Bond, the entity rating in Pallaghy, and the transaction records in Psota by adding the user node network from Sun. One of ordinary skill in the art would have been motivated to make this modification for the purpose of improving service recommendations through trust models—a benefit explicitly disclosed by Sun (¶ 6: need for improved approach for selecting and recommending service; ¶ 47: invention constructs user trust network). Bond, Pallaghy, Psota, and Sun are all related in part to entity transaction networks, so one of ordinary skill in the art would have been motivated to make these networks even more effective by combining these references together.
For claim 16, Bond, Pallaghy, Psota, and Sun teach all the limitations of claim 15 above, and Sun further teaches:
The system of claim 15, wherein the virtual supply chain, the virtual marketplace, the virtual mentorship relationship, or the combination thereof, are created by connecting two or more entities of the entity network via a graph edge, wherein the graph edge comprises a supply chain type, a virtual marketplace type, a mentorship type, or a combination thereof (¶ 47, 51: nodes of users connected by edges, which represent type of trusted relationship, such as business contact).
It would have been obvious for one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the product purchase in Bond, the entity rating in Pallaghy, and the transaction records in Psota by adding the user node network from Sun. One of ordinary skill in the art would have been motivated to make this modification for the purpose of improving service recommendations through trust models—a benefit explicitly disclosed by Sun (¶ 6: need for improved approach for selecting and recommending service; ¶ 47: invention constructs user trust network). Bond, Pallaghy, Psota, and Sun are all related in part to entity transaction networks, so one of ordinary skill in the art would have been motivated to make these networks even more effective by combining these references together.
Response to Arguments
Claim Rejections Under 35 U.S.C. § 101
Applicant’s arguments filed on October 1, 2025 have been fully considered but they are not persuasive.
Applicant argues that the claims are patent eligible because they address the technological problem of validating entities in financial networks through cross-verification of trusted financial sources. Applicant explains that the claimed invention validates rankings in financial network systems, which is a specific solution rooted in computer technology. Finally, Applicant also points to USPTO Examples 40 and 42 to indicate that the claims here also apply statistical analysis to heterogenous data sources and convert anonymized financial data into ranking metrics for online access. These improvements indicated by Applicant, however, are merely improvements to the abstract ideas of a product transaction and computing ranking metrics. Although these improvements are applied within a financial network system, they are still improvements to the transaction itself. The claims merely apply the computing technology to these abstract ideas to make the calculations more accurate and make the transactions more secure. Rather than improving the technology itself in any way, the claims are instead merely using the technology as generic tools to implement the abstract ideas. Thus, claims 1–20 do not include additional elements sufficient to integrate the claims into a practical application or recite significantly more than the judicial exception.
Claim Rejections Under 35 U.S.C. § 103
Applicant’s arguments with respect to claims 1–20 have been considered but are moot because the arguments do not apply to the references being used in the current rejection.
Applicant has amended claims 1, 17, and 19 and argues that the combination of Bond (U.S. Patent App. No. 2024/0193643) and Pallaghy (U.S. Patent App. No. 2016/0027129) does not disclose these additional limitations. Claims 1, 17, and 19, however, are currently rejected under 35 U.S.C. 103 over Bond in view of Pallaghy and Psota (U.S. Patent App. No. 2019/0362397). Thus, Applicant’s arguments with respect to claims 1, 17, and 19 are moot.
Applicant argues that the dependent claims are allowable by virtue of their dependence on claims 1, 17, and 19, which were amended to overcome the rejection under 35 U.S.C. 103. As discussed above, however, claims 1, 17, and 19 are currently rejected under 35 U.S.C. 103 over Bond in view of Pallaghy and Psota. Thus, Applicant’s arguments with respect to claims 2–16, 18, and 20 are moot.
Prior Art Not Relied Upon
The prior art made of record and not relied upon is considered pertinent to Applicant’s disclosure. Those prior art references are as follows:
Wittsiepe et al., U.S. Patent App. No. 2016/0364774, discloses feedback rating after customer client interactions.
Ramirez, U.S. Patent App. No. 2017/0011411, discloses rating members of a computer-implemented network.
Conclusion
Applicant’s amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
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/DIVESH PATEL/Examiner, Art Unit 3696
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