Notice of Pre-AIA or AIA Status
The present application is being examined under the pre-AIA first to invent provisions.
DETAILED ACTION
Status of the Claims
Claims 1-20 are pending, with claims 1, 11 and 18 being independent.
Claims 1, 2, 10-12, and 17-18 have been amended.
The rejection under 35 USC 101 is maintained.
Response to Applicant Remarks
Applicant’s well-articulated remarks have been considered but are unpersuasive for the reasons below.
Regarding the rejection under 35 USC 101, Applicant argues that the claim as amended presents patent eligible additional elements beyond the abstract idea. (Applicant’s 4//28/26 remarks, p.9, “
Claim 1 recites additional
elements that include:
receiving an image of a receipt for a transaction, the receipt
being received by the user at a time of the transaction;
programmatically processing the image to determine
information about the transaction
generating a record of the transaction based on the information
determined from the image
supplementing the record with electronic purchase data
that corresponds to the transaction of the receipt of the
captured image
permanently storing a record of the transaction, the
record including (i) information determined from the
image data; (ii) electronic purchase data that corresponds to
the transaction determined from the image data, the electronic
purchase data being stored without alteration, (iii) identification
of a time when the electronic purchase data was obtained, (iv)
the third-party source from where electronic purchase data was
obtained, and (v) a link to the image
generating an electronic receipt for the transaction using the
stored record, the electronic receipt including (i) a link to the
record of the transaction, and (ii) a set of information that is
based on, but not the same as, the electronic purchase data,
the set of information including a verification identifier that is
unique to the electronic receipt
generating supplemental information, from the electronic
purchase data, to identify one or more items of the transaction
that qualify for a categorical designation, apart from one or
more items of the transaction that do not qualify for the
categorical designation
providing an interface to enable a third-party submitter
to submit verification codes; and
in response to receiving a verification code, (i)
determining that the verification code corresponds to the
verification identifier; and (ii) providing content that
includes the electronic receipt, including the
supplemental information.
The aforementioned features are additional elements because they represent
improvements, which cannot practically be performed in the human mind, or
through a human equivalent.”) The examiner respectfully disagrees.
The examiner notes that aggregating and disseminating receipt information is a well known and tedious manual process performed by humans. (Spero, para 0005, “[0005] In almost all organizations, the reimbursement process can be quite laborious and time consuming. Original receipts need to be photocopied several times in case the originals are lost. Copies are sent to various controllers and in some cases organization(s) that are sponsoring the services and expenses. Because receipts come in various sizes, photocopying receipts can be cumbersome and difficult. After the receipts are photocopied, individuals often need to fill out detailed expense reports matching each receipt to a specific expense line item. In a number of instances, receipts must be physically attached (taped or stapled) to a blank sheet of paper before the original receipts and expense reports are sent to the appropriate parties involved. Business professionals must also deal with digital receipts from airlines and in some cases hotels. This often requires opening an email, printing the receipts, and then attaching the receipt to a blank piece of paper. Controllers who review the expense report spend significant time ensuring that expense items claimed on the expense report can be verified by the actual receipt.”) That this process may be improved using computing capabilities, although it improves the execution, does not necessarily make the invention significantly more than the abstract idea. Data reception, transmission, storage, extraction etc, are generic computing functions. (MPEP 2106.05(D), “The courts have recognized the following computer functions as well‐understood, routine, and conventional functions when they are claimed in a merely generic manner (e.g., at a high level of generality) or as insignificant extra-solution activity.
i. Receiving or transmitting data over a network, e.g., using the Internet to gather data, Symantec, 838 F.3d at 1321, 120 USPQ2d at 1362 (utilizing an intermediary computer to forward information); TLI Communications LLC v. AV Auto. LLC, 823 F.3d 607, 610, 118 USPQ2d 1744, 1745 (Fed. Cir. 2016) (using a telephone for image transmission); OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1093 (Fed. Cir. 2015) (sending messages over a network); buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014) (computer receives and sends information over a network); but see DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d 1245, 1258, 113 USPQ2d 1097, 1106 (Fed. Cir. 2014) ("Unlike the claims in Ultramercial, the claims at issue here specify how interactions with the Internet are manipulated to yield a desired result‐‐a result that overrides the routine and conventional sequence of events ordinarily triggered by the click of a hyperlink." (emphasis added));
…
iii. Electronic recordkeeping, Alice Corp. Pty. Ltd. v. CLS Bank Int'l, 573 U.S. 208, 225, 110 USPQ2d 1984 (2014) (creating and maintaining "shadow accounts"); Ultramercial, 772 F.3d at 716, 112 USPQ2d at 1755 (updating an activity log);
iv. Storing and retrieving information in memory, Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015); OIP Techs., 788 F.3d at 1363, 115 USPQ2d at 1092-93;
v. Electronically scanning or extracting data from a physical document, Content Extraction and Transmission, LLC v. Wells Fargo Bank, 776 F.3d 1343, 1348, 113 USPQ2d 1354, 1358 (Fed. Cir. 2014) (optical character recognition); and…”) Performing manual human receipt management tasks in a generic technological environment is not believed to be patent eligible.
Applicant also argues that the claimed invention is transformative and is a practical application of an abstract idea. (Applicant’s 4/28/26 remarks, p.10, “Not only do the aforementioned features recite an improvement to an underlying technology, the features noted above are also transformative, in that they recite "providing content that includes the electronic receipt, including the supplemental information.
The aforementioned features are not extra-solution activity, and therefore integrate the alleged abstract concepts into a practical application.”) The examiner respectfully disagrees.
Although the claimed computerized system ingests data, stores it and can produce a result, the manipulation of data in this manner is not understood to be transformative. The examiner respectfully suggests that the courts have typically denied eligibility to claims simply related to the collection and analysis of data, which is an abstract idea. (See Versata Development Group v. SAP America, Inc., 793 F. 3d 1306 (Fed. Cir. 2015) , “Versata argues that its claims are tied to a machine and that this favors patent eligibility. As we previously noted, the machine-or-transformation test can be a useful clue in determining the eligibility of method claims. However, the claims at issue do not transform a general purpose computer into a specific machine. The steps in Versata's claims (e.g., arranging, storing, retrieving, sorting, eliminating, determining) are conventional, routine, and well-known. They involve the normal, basic functions of a computer. "In order for the addition of a machine to impose a meaningful limit on the scope of a claim, it must play a significant part in permitting the claimed method to be performed, rather than function solely as an obvious mechanism for permitting a solution to be achieved more quickly, i.e., through the utilization of a computer for performing calculations." SiRF Tech., Inc. v. Int'l Trade Comm'n, 601 F.3d 1319, 1333 (Fed. Cir.2010); see also Bancorp, 687 F.3d at 1277-78. Versata's claims do not meet this test, and instead function solely as a mechanism for permitting the price determination to be performed more quickly.”)
Regarding the rejection under 35 USC 103, Applicant argues:
“Spero captures an image of a paper receipt and uses optical character recognition to extract transaction information from that image, which is then used to populate an expense report. See Spero ||0023]-[0024], [0027]-[0029]. Spero does not disclose "obtaining, from a third-party source that maintains records for a financial account of a user, electronic purchase data," and does not disclose "supplementing the record with electronic purchase data that corresponds to the transaction of the receipt of the captured image."” (Applicant’s 4/28/26 remarks, p.12) The examiner respectfully disagrees.
Spero clearly discloses that a source of data could be a bank, which the examiner interprets to be a third party maintain user financial accounts. (“[0004] Unfortunately, in point-of-purchase situations paper receipts are still used. More specifically, all types of merchants, banks, retailers, and service providers issue paper receipts for the various types of financial transactions, services and/or purchases which they might provide at specific point-of-purchase locations. For example, a restaurant will issue a paper receipt for a user regardless of whether the user pays with cash and/or credit. Similarly, department stores, food stores and various retail outlets will also issue a paper receipt at the time of purchase, regardless of the form or method of payment.”).
Applicant also argues “Neither Lay nor Mastie discloses "receiving an image of a receipt for a transaction, the receipt being received by the user at a time of the transaction," "programmatically processing the image to determine information about the transaction," "generating a record of the transaction based on the information determined from the image," or
"supplementing the record with electronic purchase data that corresponds to the transaction of the receipt of the captured image."). Applicant’s 4/28/26 remarks, p.13-14). The examiner respectfully disagrees.
Lay discloses that the system may accept data in the form of upload of a scanned receipt. (Lay, para 0071). Spero is directed to an electronic expense report system. (Spero, abstract). Spero discloses that computer recognition of receipt image data is well known. (Spero, para 0034, “[0034] After the digital image is received by the computer, software on the computer converts the image data into alpha-numeric strings 106. Software routines such as optical recognition (OCR) and image character recognition (ICR) for handwriting recognition are well known in the industry and will not be further described herein. The invention is meant to incorporate all such methods of converting images to alpha-numeric data whether now known or hereinafter invented and the terms OCR and character recognition as used herein are meant to include ICR and any other such conversion methods.”) Lay further discloses that data could be supplemented. (Lay, para 0071, “ [0071] This feature allows a user to manually enter specific information in order to generate an electronic receipt for a purchase which might have been made at a merchant/retailer location not having a POS equipped with the software add-on described herein. More specifically, if a consumer obtains a paper receipt from a business/merchant that is not a member of a system and/or network described herein, the consumer is able to login to their account and manually input receipt data from the paper receipt they were given. Alternatively, if the consumer has a scanner, they can easily scan the receipt, upload the scanned receipt (for example in a .jpg or .gif format), and assign and input basic tracking parameters to the image receipt such as category, business name, business type, and amount.”)
Applicant also argues that the art does not teach "permanently storing a record of the transaction, the record including (i) information determined from the image data, (ii) electronic purchase data that corresponds to the transaction determined from the image data, the electronic purchase data being stored without alteration, and (v) a link to the image." (Applicant’s 4/28/26 remarks, p.13). The examiner respectfully disagrees.
Presumably, any data that is not deleted would be permanent and any data not modified would avoid alteration. These appear to be implicit states in any data storage system. The Spero reference also teaches explicit linking of receipt data to the original receipt image. (See e.g. Spero, fig. 4)
Applicant also argues “In addition, and independently, none of the references discloses "obtaining, from a third-party source that maintains records for a financial account of a user, electronic purchase data that identifies a transaction made using a financial account of the user."… Relatedly, none of the references discloses the recited "permanently storing a record of the transaction" with all of clauses (i)-(v) of amended Claim 1.” (Applicant’s 4/28/26 remarks, p.13). The examiner respectfully disagrees.
Spero clearly discloses that a source of data could be a bank, which the examiner interprets to be a third party maintain user financial accounts. (“[0004] Unfortunately, in point-of-purchase situations paper receipts are still used. More specifically, all types of merchants, banks, retailers, and service providers issue paper receipts for the various types of financial transactions, services and/or purchases which they might provide at specific point-of-purchase locations. For example, a restaurant will issue a paper receipt for a user regardless of whether the user pays with cash and/or credit. Similarly, department stores, food stores and various retail outlets will also issue a paper receipt at the time of purchase, regardless of the form or method of payment.”). Presumably, any data that is not deleted would be permanent and any data not modified would avoid alteration. These appear to be implicit states in any data storage system. It is believed that the previously cited references disclose Applicants elements (i)-(v). See the rejection below.
Applicant also argues: “Mastie's authentication identifier (Mastie ||0024]) is directed to anti-
tampering and authentication of the receipt itself, and does not disclose the recited third-party-submitter interface or the recited responsive provision of the electronic receipt and supplemental information.” (Applciant’s 4/28/26 remarks, pp.12-13) The examiner respectfully disagrees. Mastie clearly discloses that a receipt could entail supplemental information. (Mastie, para 0031, “[0031] Personal electronic receipts and returns based on those receipts are convenient for both the merchant and the customer, facilitating fraud detection, making it relatively easy to identify suspicious activity, e.g., where the original purchaser has reported a theft. Also, often enough, customers may mistakenly return the wrong item to the wrong store, e.g., due to a memory lapse or confusion. This is avoided by the robust receipt information in personal electronic receipts, e.g., the merchant and the serial number of purchased items. Thus, merchants may allow (line-item) returns of merchandise based on the personal electronic receipt rather than insisting on a paper receipt, while reducing lost income to the merchant from fraudulent returns, while customers have better experiences with the improved return and exchange process.”)
Applicant also argues “Mastie's "EC" and
"TDC" categorizations (Mastie [0023], [0025], [0028]) are destination-side routing
categories applied to receipts, and do not disclose generating, from the electronic
purchase data, supplemental information that identifies items "that qualify for a
categorical designation, apart from one or more items of the transaction that do not
qualify for the categorical designation." Spero's billable, reimbursable, and personal
indicators (Spero Figs. 4, 6; [[0044]-[0045]) are user-applied checkboxes on
individual line items in an expense-report user interface, and do not disclose
system-generated supplemental information derived from the electronic purchase
data. Lay's folder structures (Lay [0062]-[0063]) are storage-organization
mechanisms, and do not disclose the recited per-item supplemental information.”) The examiner respectfully disagrees.
Spero discloses that the system may analyze receipt information and group items for potential reimbursement. (Spero, para 0037, “[0037] The next step is parsing 107-110, which involves analyzing the alpha-numerical text to find meaningful terms and values. The parsing identifies certain text as the date and amount of the receipt, it will also look for the vendor name. If the receipt has multiple charges on it, in the preferred embodiment, the parsing software will recognize the various amounts on the receipt and identify the charges associated with those amounts. Thus, for example, on a hotel bill, the parsing software may be able to identify separately the charges for room, charges for meals, telephone calls and movies. While not a required part of invention, this separating of receipts is beneficial in that many receipts carry charges that must be sub-categorized. For example, movie charges may not be reimbursable or, on a restaurant bill, alcohol charges may not be tax deductible.”)
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. Regarding independent claims 1, 11, 18 the claimed invention recites an abstract idea without significantly more. The claims recite the abstract idea of storing receipt data which is a mental process. Other than reciting a computer, process receipt image to determine information nothing in the claims precludes the steps from being performed mentally. But for the computer the limitations on obtain purchase data, receive receipt image, generate record based on image, supplement record corresponding to image, store record of payment transaction, generate receipt, generating supplemental information to identify reimbursement or tax deduction, verify code and provide receipt and supplemental information responsive to code is a process that under its broadest reasonable interpretation could be performed by mentally but for the recitation of generic computer elements. If claim limitations, under the broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. Further the above limitations related to storing receipt data stripped of the identified additional and insignificant elements could also be considered a “Method of Organizing Human Activity” relating to the managing human behavior and interactions. (fundamental economic practice). Thus, the claims recite an abstract idea.
The judicial exception is not integrated into a practical application. The computers are recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using generic computer components. The additional element(s) does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Simply implementing the abstract idea on a generic computer environment is not a practical application of the abstract idea and does not take the claim out of the mental process or method of organizing human activity grouping.
The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above, with respect to integration of the abstract idea into a practical application, the additional element of a computer and image processing amounts to no more than mere instructions to apply the exception using a generic computer components. Mere instructions to apply an exception using generic computer components cannot provide an inventive concept. Collecting, analyzing and displaying information, and receiving and transmitting over a network are conventional in the computing arts. (MPEP 2106.05h; See also MPEP 2106.05, Alice v. CLS, “. Nearly every computer will include a ‘communications controller’ and ‘data storage unit’ capable of performing the basic calculation, storage, and transmission functions required by the method claims.”).; See also Content Extraction and Transmission. v. Wells Fargo Bank, 776 F.3d 1343 (Fed. Cir. 2014)) The claims are not patent eligible.
Regarding the dependent claims, these claims are directed to limitations which serve to limit the receipt storage steps. The subject matter of claims 2/12 (verify receipt), 3/13 (generate identifier after data is obtained), 4/5/9/14 (data format), 6 (card issuing financial institution device), 7/15/19 (code is a barcode or QR), 8/16/20 (code is with receipt), 10/17 (original record includes origination information)
appear to add additional steps to the abstract idea, implemented by generic computers. These claims neither introduce a new abstract idea nor additional limitations which are significantly more than an abstract idea. They provide descriptive details that offer helpful context, but have no impact on statutory subject matter eligibility.
Therefore the limitations on the invention, when viewed individually and in ordered combination are directed to in-eligible subject matter.
Claim Rejections - 35 USC § 103
The following is a quotation of 35 U.S.C. 103(a) which forms the basis for all obviousness rejections set forth in this Office action:
(a) A patent may not be obtained though the invention is not identically disclosed or described as set forth in section 102 of this title, if the differences between the subject matter sought to be patented and the prior art are such that the subject matter as a whole would have been obvious at the time the invention was made to a person having ordinary skill in the art to which said subject matter pertains. Patentability shall not be negatived by the manner in which the invention was made.
Claims 1-4,6-20 are rejected under 35 U.S.C. 103(a) as being unpatentable over Lay 20090271265 in view of Mastie 20070094088 in view of Spero 20040083134
Regarding Claim 1,
a memory, the memory storing a set of instructions; one or more processors that execute the set of instructions to perform operations that include:
obtaining, from a third-party source that maintains records for a financial account of a user, electronic purchase data that identifies transactions made using the financial account of the user;
Lay is directed to a system for capturing and generating electronic receipt information from service providers. (Lay, para 0007, “[0007] The present disclosure is directed to a system and method for auto capturing and auto generating an electronic receipt from virtually any type of public facing business having a live point-of-purchase, provided that business uses and accepts electronic payment systems, namely, point-of-sale (POS) systems such as a credit card terminal and/or electronic cash register (ECR) which may further include a cash drawer, barcode scanner, receipt printer, customer facing payment terminal, touch screen, and other similar devices known in the art.”; para 0004, “[0004] Unfortunately, in point-of-purchase situations paper receipts are still used. More specifically, all types of merchants, banks, retailers, and service providers issue paper receipts for the various types of financial transactions, services and/or purchases which they might provide at specific point-of-purchase locations. For example, a restaurant will issue a paper receipt for a user regardless of whether the user pays with cash and/or credit. Similarly, department stores, food stores and various retail outlets will also issue a paper receipt at the time of purchase, regardless of the form or method of payment.”)
receiving an image of a receipt for a transaction, the receipt being received by the user at a time of the transaction;
generating a record of the transaction based on the information determined from the image;
supplementing the record with electronic purchase data that corresponds to the transaction of the receipt of the captured image;
Lay discloses that the system may accept data in the form of upload of a scanned receipt. (Lay, para 0071, “ [0071] This feature allows a user to manually enter specific information in order to generate an electronic receipt for a purchase which might have been made at a merchant/retailer location not having a POS equipped with the software add-on described herein. More specifically, if a consumer obtains a paper receipt from a business/merchant that is not a member of a system and/or network described herein, the consumer is able to login to their account and manually input receipt data from the paper receipt they were given. Alternatively, if the consumer has a scanner, they can easily scan the receipt, upload the scanned receipt (for example in a .jpg or .gif format), and assign and input basic tracking parameters to the image receipt such as category, business name, business type, and amount.”)
generate an electronic receipt for the transaction using the stored record,
Lay fig.7
the set of information including a verification identifier that is unique to the electronicrreceipt;
(Lay, para 0013, “[0013] In specific implementations, the electronic receipts comprise one or more unique retailer-specific transaction numbers that are used by a retailer at the point-of-purchase to locate or identify purchase information associated with the one or more purchases made by the registered user at the point-of-purchase.”)
Lay does not explicitly disclose
providing an interface to enable a third-party submitter to submit verification codes; and in response to receiving a verification code, (i) determining that the a verification code that corresponds to the verification identifier; and (ii) providing content that includes the electronic receipt, including the supplemental information.
Mastie is directed to a paperless electronic receipt system. (Mastie, abstract) Mastie discloses that a transaction receipt may be uniquely identified, and the receipt information may be retrieved by scanning a bar code. (Mastie, para 0026, “[0026] Alternately, since not everyone is expected to have personal storage, in-store hard copy receipts may be generated and personal electronic receipts are indirectly passed to the customer 12. The merchant may have a shared kiosk located near an exit, for example, that is primarily for downloading personal electronic receipts in real-time to the customer's personal storage, including downloading images and detailed electronic receipt data. This kiosk may include a bar code reader, for example, that reads a unique barcode from printed receipts. Customers can present paper receipts and quickly receive a personal electronic receipt from the kiosk. This kiosk allows elimination of older point-of-sale terminal modifications/upgrades and may be compatible with all handheld devices.”) It would have been obvious to one of ordinary skill in the art before the date of the invention to combine Lay with the verification of Mastie with the motivation of providing receipt information. Id.
Lay does not explicitly disclose
programmatically processing the image to determine information about the transaction;
Spero is directed to an electronic expense report system. (Spero, abstract). Spero discloses that computer recognition of receipt image data is well known. (Spero, para 0034, “[0034] After the digital image is received by the computer, software on the computer converts the image data into alpha-numeric strings 106. Software routines such as optical recognition (OCR) and image character recognition (ICR) for handwriting recognition are well known in the industry and will not be further described herein. The invention is meant to incorporate all such methods of converting images to alpha-numeric data whether now known or hereinafter invented and the terms OCR and character recognition as used herein are meant to include ICR and any other such conversion methods.”)
permanently storing a record of the transaction, the record including (i) information determined from the image data, (ii) electronic purchase data that corresponds to the transaction determined from the image data, the electronic purchase data being stored without alteration, (iii) identification of a time when the electronic purchase data was obtained, and (iv) the third-party source from where electronic purchase data was obtained, and (v) a link to the image;
…the electronic receipt including (i) a link to the record of the transaction, and (ii) a set of information that is based on, but not the same as, the electronic purchase data,
Spero discloses storage of original receipt images and derived electronic information. (Spero, fig.3; fig.4; fig.5)
wherein generating the electronic receipt includes generating supplemental information, from the electronic purchase data, to identify one or more items of the transaction that qualify for a categorical designation, apart from one or more items of the payment transaction that do not qualify for the categorical designation;
Spero discloses that the system may analyze receipt information for potential reimbursement. (Spero, para 0037, “[0037] The next step is parsing 107-110, which involves analyzing the alpha-numerical text to find meaningful terms and values. The parsing identifies certain text as the date and amount of the receipt, it will also look for the vendor name. If the receipt has multiple charges on it, in the preferred embodiment, the parsing software will recognize the various amounts on the receipt and identify the charges associated with those amounts. Thus, for example, on a hotel bill, the parsing software may be able to identify separately the charges for room, charges for meals, telephone calls and movies. While not a required part of invention, this separating of receipts is beneficial in that many receipts carry charges that must be sub-categorized. For example, movie charges may not be reimbursable or, on a restaurant bill, alcohol charges may not be tax deductible.”) It would have been obvious to one of ordinary skill in the art before the date of the invention to combine Lay and Mastie with the reimbursement of Spero with the motivation of generating expenses. Id.
Regarding Claim 2, Lay, Mastie and Spero disclose the system of claim 1.
Lay does not explicitly disclose
wherein the one or more processors execute the set of instructions to verify that the electronic receipt corresponds to the transaction identified by the electronic purchase data.
Spero discloses that the electronic receipt system serves as verification of electronic receipt data. (Spero, para 0062-63, “The receipt account on the Internet (ASP) provides the individual user with a number of benefits. It serves as a verification source that the receipt has not been manipulated or altered in any way. This is important to the IRS and Employers. Users may access their account through the Internet and view and create receipt expense reports, as opposed to just being able to view or create receipt expense reports with their software enabled computer processor. [0063] Organizations also benefit from the system. If an entire organization uses the receipt system, then the organization can integrate their expense reports into the accounts payable program of an accounting system. Approvals can be granted, checks cut and mailed, and notifications provided to the expense submitter.”) It would have been obvious to one of ordinary skill in the art before the date of the invention to combine Lay and Mastie with the verification of Spero with the motivation of generating expenses. Id.
Regarding Claim 3, Lay, Mastie and Spero disclose the system of claim 1.
Lay does not explicitly disclose
wherein the verification identifier is generated after the electronic purchase data is obtained from the third-party source.
However, the limitation is obvious in view of Lay alone. The examiner notes that Lay discloses a verification identifier for identifying an electronic receipt, but is silent as to when it is generated. However, the examiner respectfully suggests that the identifying would necessarily be generated before, after or contemporaneously with the processing of transaction purchase data. One of ordinary skill in the art could have pursued the known potential options (generate an identifier after data is obtained) with a reasonable expectation of success. The claim would have been obvious because “a person of ordinary skill has good reason to pursue the known options within his or her technical grasp. If this leads to the anticipated success, it is likely the product not of innovation but of ordinary skill and common sense.”
Regarding Claim 4, Lay, Mastie and Spero disclose the system of claim 1.
wherein the electronic purchase data is represented using at least one of: i) the Open Financial Exchange (OFX) format; ii) the Quicken Financial Exchange (QFX) format; or iii) the Comma Separation Value (CSV) format, or iv) hypertext markup language (HTML).
(Lay, para 0082, “[0082] As described above in the various embodiments, after a consumer/user creates an account in the system, the consumer/user can receive and access all of their electronic receipts at a single website. Each purchase from a retailer/merchant that has also opted into the service can generate a digital/electronic receipt that is electronically sent into the user's online account directly from the checkout stand, otherwise known as the Point-of-Purchase (POP), located within the store.”) The examiner interprets web site receipt content to read on HTML.
Regarding Claim 6, Lay, Mastie and Spero disclose the system of claim 1.
wherein the computer system comprises a computing device that is connected to a card issuing financial institution over a communications network.
See prior art rejection of claim 1 regarding Lay.
Regarding Claim 7, Lay, Mastie and Spero disclose the system of claim 1.
wherein the verification code includes a barcode or QR code.
See prior art rejection of claim 1 regarding Mastie.
Regarding Claim 8, Lay, Mastie and Spero disclose the system of claim 1.
wherein the verification code is included with the electronic receipt.
See prior art rejection of claim 1 regarding Mastie
Regarding Claim 9, Lay, Mastie and Spero disclose the system of claim 1.
wherein the electronic receipt is at least partially formatted in HyperText Markup Language (HTML) or in Portable Document Format (PDF).
(Lay, para 0082, “[0082] As described above in the various embodiments, after a consumer/user creates an account in the system, the consumer/user can receive and access all of their electronic receipts at a single website. Each purchase from a retailer/merchant that has also opted into the service can generate a digital/electronic receipt that is electronically sent into the user's online account directly from the checkout stand, otherwise known as the Point-of-Purchase (POP), located within the store.”) The examiner interprets web site receipt content to read on HTML.
Regarding Claim 10, Lay, Mastie and Spero disclose the system of claim 1.
wherein the original record includes origination information corresponding to when the electronic purchase data was imported to create the record.
Spero is directed to an electronic expense report system. (Spero, abstract). Spero discloses storage of original receipt images and derived electronic information. (Spero, fig.3; fig.5) It would have been obvious to one of ordinary skill in the art before the date of the invention to combine Lay and Mastie with the origination of Spero with the motivation of generating expenses. Id.
Regarding Claims 11,12,13,14,15,16,17,18,19,20
See prior art rejections of claims 1,2,3,4,7,8,10,1,7,8
Claims 5 are rejected under 35 U.S.C. 103(a) as being unpatentable over Lay 20090271265 in view of Mastie 20070094088 in view of Spero 20040083134 in view of Farias 20080270514
Regarding Claim 5, Lay, Mastie and Spero disclose the system of claim 1.
Lay does not explicitly disclose
wherein the electronic purchase data is represented using the ISO 8583 Standard for Financial Transaction Card Originated Messages.
Farias is directed toa system for accessing POS terminals. (Farias, abstract). Farias discloses that it is known that transaction data may be formatted as ISO8583. (Farias, para 0036, “[0036] Further, electronic operations perform a simpler process that can be detailed with the following steps, as shown in FIG. 6:
1. POS user types the transaction data; 2. POS client system 15 connects to a Remote Access Server (RAS) 45 or attaches to a broadband network. 3. POS client system 15 receives network access. 4. POS client system builds an ISO8583 message. 5. POS client system sends the ISO8583 message to the transaction server 35. 6. Transaction server 35 responds to the POS client system with an ISO8583 message. 7. POS client system 15 process the received message. 8. POS client system 15 emits a transaction receipt.”) It would have been obvious to one of ordinary skill in the art before the date of the invention to combine Lay, Mastie and Spero with the ISO8583 of Farias with the motivation of processing transaction messages. Id.
Conclusion
THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
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/ALLEN C CHEIN/Primary Examiner, Art Unit 3627
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