DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Claim Status
As of the Office Action dated January 5, 2026 claims 1, 3, 5-10, 12 and 14-19 were pending and claims 1, 3, 5-10, 12 and 14-19 stood rejected. Claims 1, 10 and 19 have been amended. Claims 5 and 14 have been cancelled. No claims have been added. Claims 1, 3, 6-10, 12 and 15-19 are therefore currently pending and are presented for examination on the merits.
Information Disclosure Statement
The information disclosure statement (IDS) was submitted on February 10, 2026. The submission is in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner.
Response to Arguments
Applicant’s argument with regard to the 35 U.S.C. § 101 rejection of claims 1, 3, 5-10, 12 and 14-19 has been fully considered but is not persuasive. As the certificate constitutes nothing more than a guarantee that the user has access to sufficient funds to satisfy a transaction amount no technological improvement is present and the forming of the certificate and the determination can be viewed as being part of the abstract idea itself which is an indication of ineligibility under MPEP § 2106.05(f). Similarly the TEE is being used only as part of the verification process for determining whether the user has sufficient funds for performing the transaction and not for any technical benefit and can also be viewed as being mere instructions to implement the abstract idea itself MPEP § 2106.05(f) while tying the abstract idea to a particular technological environment MPEP § 2106.05(h). Therefore under Prong Two of Step 2A the claim is ineligible. Similar reasoning applies in Step 2B when utilizing section 2106.05 which repeats all of the conclusions from Prong Two of Step 2A with the exception of any conclusion reached in MPEP § 2106(e) which only applies to the obtaining and sending operations which must be re-analyzed under MPEP § 2106(d) in Step 2B. However as noted in remarks and the written disclosure the obtaining and sending operations both make use of the Internet which is a covered rationale under MPEP § 2106(d) that has been held as insufficient to provide an inventive concept. Therefore as the MPEP is the guideline for establishing whether a claim is or is not directed towards ineligible subject matter the conclusion that the claim is ineligible has been reached using the guidelines and will be maintained.
Applicant’s argument with regard to the 35 U.S.C. § 112 (a) paragraph rejection of claims 1, 3, 5-10, 12 and 14-19 has been fully considered and is persuasive. Accordingly the rejection is being withdrawn.
Applicant’s argument with regard to the 35 U.S.C. § 112 (b) paragraph rejection of claims 1, 3, 5-10, 12 and 14-19 has been fully considered and is persuasive. Accordingly the rejection is being withdrawn.
Applicant’s argument with regard to the 35 U.S.C. § 112 (d) paragraph rejection of claims 5 and 14 has been fully considered and is persuasive. Accordingly the rejection is being withdrawn.
Applicant’s argument with regard to the 35 U.S.C. § 103 rejection of claims 1, 5, 8-10, 14 and 17-19 as being unpatentable over Jiang et al. (U.S. Patent Publication 2015/0278795, hereinafter referred to as Jian) in view of Beye (U.S. Patent 11,605,068) in view of Avetisov et al. (U.S. Patent Publication 2020/0351660, hereinafter referred to as Avetisov) has been fully considered and is persuasive. However Examiner wishes to point out that the argument is not always matching the construction of the claim and at least some of the argument cannot be viewed pertinent to the actual claim. For example on the page labeled “17 of 20” Applicant argues that “First, Jiang does not disclose or suggest ‘determining, by a server’ that the predetermined certificated delivery condition is satisfied, specifically ‘during a first time period before a user certificate of the target electronic wallet account expires, a terminal device associated with the target electronic wallet account is connected to the internet’”. Applicant’s argument appears to somehow conjoin the first and second limitations of the claim where the second limitation “during a first time period before a user certificate of the target electronic wallet account expires, a terminal device associated with the target electronic wallet account is connected to the internet” does not appear to have any connection to the operation of “…determining, by a server, that a current state of a target electronic wallet account satisfies a predetermined certificate delivery condition” as the claim suggests that the determination of the certificate delivery condition can take place at any time and that the connection of the terminal device can happen at any point in the future. The argument appears to be suggesting an interrelationship between the two operations that Examiner frankly does not see and is not consistent with a fair interpretation of the claim. Going on into the argument at the top of page 18 where Applicant states that “…This is a user-initiated request model, not a server-side proactive determination as recited in the amended claims” where this statement appears to be based on the preceding statements of the argument on page 17 and again when the actual claim language is taken into account appear to rely on an interpretation of the claims that is not reflected in the actual claim language. Therefore the first argument is not clear and as Examiner does not see how the argument is tied to the actual claim language is not persuasive and is not a reason for establishing that the claimed invention has overcome the previous prior art rejection.
With regard to the second point raised in Applicant’s argument on page 18 although the Applicant did not explain why Jiang does not teach “current credit information” it would appear that the claim is broad enough in scope to cover either a line of credit or a simple account balance. The Merriam-Webster Dictionary defines “credit” as “the balance in a person’s favor in an account” or alternatively “an amount or sum placed at a person’s disposal by a bank”. The claim recites that “…current credit information represents a compliance degree of the target electronic wallet and comprises at least one of a current credit value or a current available credit limit”. Therefore Examiner deems that the broadest reasonable interpretation of the claim can include either a “bank balance” and/or an available balance on a line of credit but does not specifically require there to be both a traditional bank balance in combination with a line of credit account. Therefore while it is possible that the offline payment limit could be a combination of a bank balance and the available credit on a line of credit in the event that any particular user only had a traditional bank balance and no line of credit that the “current account balance and the current credit information” used in determining an offline payment limit would be the same value. This interpretation would be consistent with the language in the first step because the credit information is recited as comprising “at least one of a current credit value or a current available credit limit”. Applicant did not go into great detail on this argument but notably Applicant conceded that Jiang discloses determining available funds which given the breadth and wording of the claim is sufficient to read on the claim. There Applicant’s second argument is also unpersuasive as it not commensurate with the scope of the claim.
Applicant’s third argument, also on page 18 of 20, recites that the Beye and Avetisov references do not remedy “these deficiencies”. However as Examiner has pointed out in response to the first and second arguments there is no deficiency in Jiang when the claim scope is properly interpreted and there is no requirement to remedy a deficiency that does not exist. Therefore the third argument must also be held as unpersuasive as it relies solely on the unpersuasive first and second arguments made by Applicant.
The only persuasive argument that Applicant has presented is the final argument as Examiner concurs that none of the cited references fairly teaches or discloses that “the offline payment is executed in the TEE, a current upper limit for the offline payment is determined based on the offline payment limit and a historical amount, and the user certificate is provided to a payment collection device when a current transaction amount is not greater than the current upper limit for the offline payment”. Furthermore Examiner was unable to find any prior art that fairly taught or suggested this limitation. Accordingly the prior art rejections of claims 1, 10 and 19 are being withdrawn.
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1, 3, 6-10, 12 and 15-19 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Claim 1 recites a method and is therefore directed towards one of the four categories of statutory subject matter (MPEP § 2106.03 (II)). The analysis then proceeds to step 2A, specifically Prong One, in which the claim is analyzed in order to determine whether the claim is directed towards a judicial exception (MPEP § 2106.04 (II)(A)(1) and MPEP § 2106.04(a)(1-2)). The claim recites obtaining wallet account information, a current account balance and current credit information in response to determining that a current state of the wallet satisfies a predetermined certificate delivery condition (where example conditions are listed in paragraph 0061 of the written disclosure and are stated in the claim), determining an offline payment limit, signing summary information using a server private key to form a signature, generating a user certificate based on the summary information and the signature and sending the certificate to make offline payments based on the certificate where the certificate can be viewed as a credit guarantee that can be applied when a network is not available and per the written disclosure removes the requirement that a user recharge a hardware wallet on a device such as a mobile phone when an online connection is present prior to engaging in an offline transaction (written disclosure at paragraphs 0003-0005 and 0058). Providing a signed credit guarantee that payment will be fulfilled is a fundamental economic practice (MPEP § 2106.04(a)(2)(II)(A)) and as the method only requires a review of the parameters including the wallet account information and the offline payment limit, adding an issuance time and a validity duration and placing a signature over the parameters to form a certificate in order to attest that an authorized entity issued the certificate the method can also be viewed as a mental process (MPEP § 2106.04(a)(2)(III)(C)(1)) and therefore under Prong One of Step 2A involves two categories of abstract ideas involving a fundamental economic practice and a mental process. Therefore under Prong One of Step 2A the claim must be held as being ineligible.
The analysis then moves to Prong Two of Step 2A in order to evaluate whether the claim recites additional elements sufficient to form a practical application of the abstract idea (MPEP § 2106.04(d)(I-III)). The claim recites “…in response to determining, by a server, that a current state of a target electronic wallet account satisfies a predetermined certificate delivery condition” where the actual determining operation is not positively claimed and can therefore be viewed under broadest reasonable interpretation as an operation involving insignificant extra-solution activity (MPEP § 2106.05(g)) because as recited the claimed server may simply be performing data gathering amounting to the receiving of a result of the determination from an entity separate from the server. The claim also recites signing summary information using a private key of a server and notably the written disclosure describes no particular algorithm for adding the signature other than suggesting that asymmetric cryptography is being used as the signature can be verified using a public key (paragraph 0026 of the written disclosure) however this must be viewed as being at a generally high level and therefore weighs against including the signing operation as an element which is described as taking place at a first signing module (paragraph 0138) which is not described in any detail and only ties the claim to a particular technological environment (MPEP § 2106.05(h)). No improvement to the functioning of a computer or to any other technology or technical field is present in the signing operation (MPEP § 2106.05 (a)) and as the signing operation only describes the idea of an outcome as the signing operation is nothing more than mere instructions to apply an exception (MPEP § 2106.05(f)(1)). The generation of the certificate is also not described in any particular detail as the function is described by written disclosure as being performed by a first generation module 540 (paragraph 0138) that provides no detail as to any structure of the first generation module and therefore as the only clear recitation of structure is the portion of the disclosure at paragraphs 0161-0166 which recite a memory and a processor the claim can be viewed as simply linking the abstract idea to a particular technological environment (MPEP § 2106.04(d)(I), MPEP § 2106.05 (h)) that provides no improvement to the computer itself or to any other technology or technical field. Therefore the generation of the certificate does not form a practical application as no improvement to the functioning of a computer or to any other technology or technical field is present in the certificate generation (MPEP § 2106.05 (a) and the certificate generation only describes the idea of an outcome as the generating operation is nothing more than mere instructions to apply an exception (MPEP § 2106.05(f)(1)). The claim also recites “…where the terminal device is provided with a trusted execution environment (TEE), and wherein sending the user certificate comprises delivering the user certificate to the TEE of the terminal device so that the terminal device stores the user certificate in the TEE”. While the TEE can be considered as being an element the claim only recites an operation of storing data in the TEE and there is nothing in the claim that suggests that any improvement to the storing operation is improving the functioning of the server or to any other technology or technical field (MPEP § 2106.05 (a)) and the recitation of the TEE merely serves to tie the abstract idea to a particular technological environment (MPEP § 2106.05(h)). As the claim also recites that the offline payment is executed in the TEE and that a current upper limit for the offline payment is determined based on the offline payment limit and a historical offline transaction amount this would amount to nothing more than mere instructions to apply the abstract idea (MPEP § 2106.05(f)). The operation of providing the user certificate to a payment collection device when a current transaction amount is not greater than the current upper limit for the offline payment is a data outputting operation and can be viewed as mere insignificant extra-solution activity (MPEP § 2016.05(g)). Therefore under Prong Two of Step 2A the claim is also held as being ineligible.
The analysis then proceeds to Step 2B (MPEP § 2106.05) in which the claim is analyzed in order to evaluate whether additional elements are present that amount to an inventive concept. The claim recites “…in response to determining, by a server, that a current state of a target electronic wallet account satisfies a predetermined certificate delivery condition” where the actual determining operation is not positively claimed and can therefore be viewed under broadest reasonable interpretation as an operation involving insignificant extra-solution activity (MPEP § 2106.05(g)) because as recited the claimed server may simply be performing data gathering amounting to the receiving of a result of the determination from an entity separate from the server. The claim also recites signing summary information using a private key of a server and notably the written disclosure describes no particular algorithm for adding the signature other than suggesting that asymmetric cryptography is being used as the signature can be verified using a public key (paragraph 0026 of the written disclosure) however this must be viewed as being at a generally high level and therefore weighs against including the signing operation as an element which is described as taking place at a first signing module (paragraph 0138) which is not described in any detail and only ties the claim to a particular technological environment (MPEP § 2106.05(h)). No improvement to the functioning of a computer or to any other technology or technical field is present in the signing operation (MPEP § 2106.05 (a)) and as the signing operation only describes the idea of an outcome as the signing operation is nothing more than mere instructions to apply an exception (MPEP § 2106.05(f)(1)). The generation of the certificate is also not described in any particular detail as the function is described by written disclosure as being performed by a first generation module 540 (paragraph 0138) that provides no detail as to any structure of the first generation module and therefore as the only clear recitation of structure is the portion of the disclosure at paragraphs 0161-0166 which recite a memory and a processor the claim can be viewed as simply linking the abstract idea to a particular technological environment (MPEP § 2106.04(d)(I), MPEP § 2106.05 (h)) that provides no improvement to the computer itself or to any other technology or technical field. Therefore the generation of the certificate does not form a practical application as no improvement to the functioning of a computer or to any other technology or technical field is present in the certificate generation (MPEP § 2106.05 (a) and the certificate generation only describes the idea of an outcome as the generating operation is nothing more than mere instructions to apply an exception (MPEP § 2106.05(f)(1)). The claim also recites “…where the terminal device is provided with a trusted execution environment (TEE), and wherein sending the user certificate comprises delivering the user certificate to the TEE of the terminal device so that the terminal device stores the user certificate in the TEE”. While the TEE can be considered as being an element the claim only recites an operation of storing data in the TEE and there is nothing in the claim that suggests that any improvement to the storing operation is improving the functioning of the server or to any other technology or technical field (MPEP § 2106.05 (a)) and the recitation of the TEE merely serves to tie the abstract idea to a particular technological environment (MPEP § 2106.05(h)). As the claim also recites that the offline payment is executed in the TEE and that a current upper limit for the offline payment is determined based on the offline payment limit and a historical offline transaction amount this would amount to nothing more than mere instructions to apply the abstract idea (MPEP § 2106.05(f)). The operation of providing the user certificate to a payment collection device when a current transaction amount is not greater than the current upper limit for the offline payment is a data outputting operation and can be viewed as mere insignificant extra-solution activity (MPEP § 2016.05(g)). The data inputting and outputting operations merely involve receiving and transmitting data over the internet which are operations that have been held by the courts to involve nothing more than well-understood, routine and conventional operations (MPEP § 2106.05(d)). Therefore under Step 2B claim 1 is also held as being ineligible.
Dependent claims 3 and 6-9 merely extend the abstract idea of claim 1 by reciting further description of the wallet account information in claim 3, further description of the manner in which the offline payment limit is determined including use of a scoring mechanism in claims 6 and 7, describing the obtaining of an offline bill which is used to deduct an amount from a wallet following an offline transaction, restoring the offline limit, and further describing that the amount is deducted from a wallet after verifying a merchant signature where again the high level of the written disclosure precludes considering any of the operations as elements and where the trusted execution environment is described in a manner that only links the abstract idea to a particular technological environment in claims 8 and 9. Therefore under both prongs of Step 2A and Step 2B claims 3 and 6-9 are also held as being directed towards an ineligible abstract idea without any practical application or inventive concept.
Claims 10, 12 and 15-18 are directed towards a server for performing the method of claims 1, 3 and 6-9. Claims 10, 12 and 15-18 are not appreciably different from claims 1, 3 and 6-9 and repeat the operations described in claims 1, 3 and 6-9 without adding any elements that would alter the conclusions for Prong Two of Step 2A and Step 2B that were reached for claims 1, 3 and 6-9 as the recitation regarding the server merely links the abstract idea to a particular technological environment (MPEP § 2106.05(h)) without providing any improvement to the functioning of either the server or to any other technology or technological field (MPEP § 2106.05 (a)). Therefore claims 10, 12 and 15-18 are also held as being directed towards an ineligible abstract idea without any practical application or inventive concept.
Claim 19 is directed towards the non-transitory computer-readable medium for instructing a computer to perform the method of claim 1. Claim 19 is not appreciably different from claim 1 and repeats the operations described in claim 1 without adding any elements that would alter the conclusions for Prong Two of Step 2A and Step 2B that was reached for claim 1 as the recitation regarding the medium merely links the abstract idea to a particular technological environment (MPEP § 2106.05(h)) without providing any improvement to the functioning of either the medium or to any other technology or technological field (MPEP § 2106.05 (a)). Therefore claim 19 is also held as being directed towards an ineligible abstract idea without any practical application or inventive concept.
Conclusion
THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to JAMES D NIGH whose telephone number is (571)270-5486. The examiner can normally be reached 6:00 to 9:45 and 10:30 to 2:45.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Neha Patel can be reached at (571) 270-1492. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/JAMES D NIGH/Senior Examiner, Art Unit 3699
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