DETAILED ACTION
Status of Claims
1. This office action is in response to RCE filed 9/17/2025.
2. Claims 1, 2, 4-7, 9-13, 18 are pending.
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 .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 9/17/2025 has been entered.
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, 4-7, 9-13, 18
Claims 1, 2, 4-7, 9-13, 18 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.
Step 1: Claims 1-9 are directed to a method, 10-18 to system – each of which is one of the statutory categories of inventions.
Step 2A: A claim is eligible at revised Step 2A unless it recites a judicial exception and the exception is not integrated into a practical application of the application.
Prong 1: Prong One of Step 2A evaluates whether the claim recites a judicial exception (an abstract idea enumerated in the 2019 PEG, a law of nature, or a natural phenomenon).
Groupings of Abstract Ideas:
I. MATHEMATICAL CONCEPTS
A. Mathematical Relationships
B. Mathematical Formulas or Equations
C. Mathematical Calculations
II. CERTAIN METHODS OF ORGANIZING HUMAN ACTIVITY
A. Fundamental Economic Practices or Principles (including hedging, insurance, mitigating risk)
B. Commercial or Legal Interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations)
C. Managing Personal Behavior or Relationships or Interactions between People (including social activities, teaching, and following rules or instructions)
III. MENTAL PROCESSES.
Concepts performed in the human mind (including an observation, evaluation, judgment, opinion).
See MPEP 2106.04 (a) (2) Abstract Idea Groupings [R-10.2019]
Independent claims 1 and 10 are directed to – receiving, from a sending institution, a fund transfer request from first currency zone to a second currency zone; verifying the transfer request based on format of the transfer request; based on the transfer request being verified, confirming liquidity of the sending institution in second currency to cover the transfer request; in response to the confirmation, transforming the transfer request based on one or more rules specific to the second zone and defining request data, wherein transforming includes determining that the transfer request does not include required data; determining that the transfer request does not include required data, supplementing data in the transfer request in order to conform the transfer request to one or more rules; transmitting the transformed request to a recipient institution in the second zone – that constitutes Fundamental Economic Practices or Principles and/or Commercial/Legal Interactions and/or Managing Interactions between People all of which is subcategory under the abstract idea grouping of Certain Methods of Organizing Human Activity.
The dependent claims further limit the abstract idea to – submitting identifier to proxy and receiving account data specific to the proxy; receiving transfer instruction from sender and in connection with commitment to pre-fund the transfer to recipient user in second zone, requesting a currency conversion quote from a foreign exchange provider; receiving the currency conversion quote and submitting the transfer request including currency conversion quote to the payment system; transforming the transfer request includes separating the transfer request into multiple transfer requests based on the amount of the transfer; prior to receiving the transfer request, funding the liquidity of the sending institution in the second domestic currency with the custodian institution and/or replenishing the liquidity of the sending institution in the second domestic currency with the custodian at one or more intervals – that also constitute Certain Methods of Organizing Human Activity.
Hence under Prong One of Step 2A, the claims recite a judicial exception.
Prong 2: Prong Two of Step 2A evaluates whether the claim recites additional elements that integrate the judicial exception into a practical application of the exception.
Limitations that are indicative of integration into a practical application include:
Improvements to the functioning of a computer or to any other technology or technical field – see MPEP 2106.05(a)
Applying the judicial exception with, or by use of, a particular machine – see MPEP 2106.05(b)
Effecting a transformation or reduction of a particular article to a different state or thing – see MPEP 2106.05(c)
Applying or using the judicial exception in some other 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 – see MPEP 2106.05(e)
Limitations that are not indicative of integration into a practical application include:
Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP 2106.05(f)
Adding insignificant extra-solution activity to the judicial exception – see MPEP 2106.05(g)
Generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h)
Additional elements recited by the claims, beyond the abstract idea, include: computing device of sending institution, computing device of recipient institution, and computing device of payment system; a system comprising processor and memory. Examiner thus finds that any additional element(s), beyond the judicial exception, has been recited at a high level of generality such that the claim limitations amount to no more than mere instructions to apply the exception using generic components (see MPEP 2106.05(f)) or insignificant data gathering activities (see MPEP 2106.05(g)).
The combination of additional elements – receiving, confirming, transforming, transmitting – does not purport to improve the functioning of a computer or effect an improvement in any other technology or technical field. Instead, the additional elements do no more than use the computer as a tool and/or link the use of the judicial exception to a particular technological environment or field of use. The focus of the claims is not on improvement in computers, but on certain independently abstract ideas – receiving, from a sending institution, a fund transfer request from first currency zone to a second currency zone; confirming liquidity of the sending institution to cover the transfer request; transforming the transfer by including supplemental data in the transfer request based on rules; and providing the transformed transfer request to a recipient institution – that merely uses generic computers as tools. Steps that do no more than spell out what it means to “apply it on a computer” cannot confer patent eligibility. Indeed, nothing in claim 1 improves the functioning of the computer, makes it operate more efficiently, or solves any technological problem. See Trading Techs. Int’l, Inc. v. IBG LLC, 921 F.3d 1378, 1384-85 (Fed. Cir. 2019).
Hence, the additional elements, when considered individually or in combination, do not integrate the judicial exception into a practical application.
Hence, the claims are ineligible under Step 2A.
Step 2B: In Step 2B, the evaluation consists of whether the claim recites additional elements that amount to an inventive concept (aka “significantly more”) than the recited judicial exception.
As discussed in Prong Two, the additional elements in the claims amount to no more than mere instructions to apply the exception using generic components, which is insufficient to provide an inventive concept.
When considered individually or as an ordered combination, the additional elements fail to transform the abstract idea of – receiving, from a sending institution, a fund transfer request from first currency zone to a second currency zone; confirming liquidity of the sending institution to cover the transfer request; transforming the transfer by including supplemental data in the transfer request based on rules; and providing the transformed transfer request to a recipient institution – into significantly more.
See MPEP 2106.05(f) Mere Instructions To Apply An Exception [R-10.2019].
(2) Whether the claim invokes computers or other machinery merely as a tool to perform an existing process. Use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) or simply adding a general purpose computer or computer components after the fact to an abstract idea (e.g., a fundamental economic practice or mathematical equation) does not integrate a judicial exception into a practical application or provide significantly more.
Hence, the claims are ineligible under Step 2B.
Therefore, the claim(s) are rejected under 35 U.S.C. 101 as being directed to a judicial exception without significantly more.
Response to Arguments
Applicant's arguments filed 8/13/2025 have been fully considered but they are not persuasive.
101
Applicant argues, that the pending claims provide coordination for messaging between different countries through rules-based logic to provide enhanced, e.g., real-time transfers (citing para [0011], [0012] of the specification); provide technical solution for cross-border real time transfer (citing para [0060] of the specification).
Examiner respectfully disagrees because cross border payment has been a fundamental economic practice from time immemorial ever since merchant traders, travelers, and nation states have interacted with their counterparts across national boundaries for carrying out trade, commerce, travel, etc. Cross-border payments are important components of the global economy encompassing international trade, travel, remittances, investment, and charitable donations. See NPL Stripe. The fact that cross-border fund transfers are inefficient, time consuming and costly is due to various legal compliance and regulatory issues and nothing to do with technical problems. Therefore, for the applicant to assert – that the claims do not recite fundamental economic practices, or commercial/legal transaction, or managing interactions between people – is simply not persuasive.
With respect to Applicant’s argument regarding “real-time” cross-border transfers, Examiner notes that this is merely carrying out cross-border payments over the worldwide electronic payment systems and thus merely constitutes implementing an abstract idea on modern computing networks. See for example, MPEP 2106.04(a)(2) III.D.(“Examples of product claims reciting mental processes include: A wide-area real-time performance monitoring system for monitoring and assessing dynamic stability of an electric power grid – Electric Power Group, 830 F.3d at 1351 and n.1, 119 USPQ2d at 1740 and n.1”). Real time payments have become ubiquitous worldwide in the past two decades. Launched in 2008, UK’s Faster Payment System is often cited as one of the first major real-time payment systems. See NPL Real-time payments explained by Stripe. Therefore, for the applicant to assert – that the real-time aspect of the transfer is a technical improvement – is not persuasive especially, the applicant cannot credibly contend to have invented real-time payments or real-time fund transfers.
Furthermore, courts have consistently held that improved speed or efficiency inherent with applying an abstract idea on a computer are not sufficient to demonstrate an inventive concept. See OIP Techs v. Amazon.com (Fed. Cir. 2015) (“relying on a computer to perform routine tasks more quickly or more accurately is insufficient to render a claim patent eligible.”); Intellectual Ventures I LLC v. Capital One Bank (Fed. Cir. 2017), (“claiming the improved speed or efficiency inherent with applying the abstract idea on a computer does not provide a sufficient inventive concept.”); Intellectual Ventures I LLC v. Capital One Bank (USA) (Fed. Cir. 2015) (“[M]erely adding computer functionality to increase the speed or efficiency of the process does not confer patent eligibility on an otherwise abstract idea.”); Intellectual Ventures I LLC v. Erie Indemnity (Fed. Cir. 2017) (“Though the claims purport to accelerate the process of finding errant files and to reduce error, we have held that speed and accuracy increases stemming from the ordinary capabilities of a general-purpose computer do not materially alter the patent eligibility of the claimed subject matter.”).
Applicant argues that the claims recite an improvement to the functioning of a computer or an improvement to other technology or technical field.
Examiner disagrees.
MPEP 2106.05(a) Improvements to the Functioning of a Computer or To Any Other Technology or Technical Field
II. IMPROVEMENTS TO ANY OTHER TECHNOLOGY OR TECHNICAL FIELD
Consideration of improvements is relevant to the integration analysis regardless of the technology of the claimed invention. Notably, the court did not distinguish between the types of technology when determining that the invention improved technology. However, it is important to keep in mind that an improvement in the judicial exception itself (e.g., a recited fundamental economic concept) is not an improvement in technology. For example, in Trading Technologies Int’l v. IBG LLC, the court determined that the claim simply provided a trader with more information to facilitate market trades, which improved the trader but did not improve computers or technology.
Similarly here, confirming the liquidity of the sender and applying rules to the transfer request may facilitate fund transfer between sender and recipient in different domestic currency zones but it does not improve computers or technology. The improvement recited in the claim does not improve the computing devices. Instead, the alleged improvement recited in the claims is an abstract idea, i.e., facilitating cross-border currency conversion. Indeed, nothing in the claims improves the functioning of a computer, makes it operate more efficiently, or solves any technological problem. See Trading Techs. Int’l, Inc. v. IBG LLC, 921 F.3d 1084 (Fed. Cir. 2019) (“This invention makes the trader faster and more efficient, not the computer. This is not a technical solution to a technical problem.”) (“The claims of the ‘999 patent do not improve the functioning of the computer, make it operate more efficiently, or solve any technological problem. Instead, they recite a purportedly new arrangement of generic information that assists traders in processing information more quickly”); See Trading Techs. Int’l, Inc. v. IBG LLC, 921 F.3d 1378, 1384 (Fed. Cir. Apr 30, 2019) (“The claims are focused on providing information to traders in a way that helps them process information more quickly, ’556 patent at 2:26–39, not on improving computers or technology.”). Any purported improvement recited in the claim does not improve the computers. Instead, the alleged improvement recited in the claims is an abstract idea, i.e., cross-border transfers. See SAP Am., Inc. v. InvestPic, LLC, 898 F.3d 1161, 1170 (Fed. Cir. 2018) (“[P]atent law does not protect such claims[, i.e., claims to an asserted advance in the realm of abstract ideas], without more, no matter how groundbreaking the advance.”). But “[n]o matter how much of an advance in the … field the claims recite, the advance lies entirely in the realm of abstract ideas, with no plausibly alleged innovation in the non-abstract application realm.” SAP Am., Inc. v. Investpic, LLC 898 F.3d 1161, 1163 (Fed. Cir. 2018). Applying rules to cross-border fund transfer request may help achieve compliance with money laundering regulations but it does not achieve an improved technological result. Hence, contrary to Applicant’s assertions – the pending claims represent an improvement to the judicial exception rather than to the technology.
It is also not clear why the Applicant analogizes the present claims to McRO because, unlike McRO which involved improvement to animation phonemes, the present invention is directed to processing a payment transfer which is an abstract idea. Using business rules to supplement payment transfer request has absolutely nothing in common with rules for phonemes.
Applicant also analogizes the present claims to Finjan but this is again found unpersuasive. In Finjan, the Federal Circuit held that the claims directed to a behavior-based virus scan were a specific improvement in computer functionality similar to Enfish. However, no comparable technical improvement is present in the present claims. Implementing rules to facilitate cross border payment request from sender currency to recipient currency is not comparable to the improvement in computer functionality as in Finjan or Enfish.
The claim limitations do not purport to improve the functioning of the computer devices, do not recite (i) an improvement to the functionality of a computer or other technology or technical field; (ii) a “particular machine” to apply or use the judicial exception; (iii) a particular transformation of an article to a different thing or state; or (iv) any other meaningful limitation. See MPEP 2106.05(a)-(c), (e)-(h). Hence, the combination of additional elements, when considered individually or as an ordered combination, fail to integrate the abstract idea into a practical application or provide significantly more than an abstract idea. See MPEP 2106.05(f) (“Use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) or simply adding a general purpose computer or computer components after the fact to an abstract idea (e.g., a fundamental economic practice or mathematical equation) does not provide significantly more.”).
103
The obviousness rejection has been withdrawn because the prior art does not teach the combination of limitations filed 8/13/2025 and entered 9/17/2025.
Conclusion
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/ARUNAVA CHAKRAVARTI/Primary Examiner, Art Unit 3692