DETAILED ACTION
Status of Claims
1. This office action is in response to amendment filed 7/19/2026.
2. Claims 1-20 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 .
Claim Rejections - 35 USC § 112
The following is a quotation of the first paragraph of 35 U.S.C. 112(a):
(a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention.
The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112:
The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention.
Claims 1-20
Claims 1-20 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention.
The following newly amended limitations 1, 8 and 15 are not adequately supported by the original disclosure and are hence rejected as new matter:
applying temporal correlation processing between blockchain transaction timestamps and the date-time value;
applying transaction-value correlation processing between blockchain transaction amounts and the amount value;
…
reconstruct a blockchain transaction linkage association between the on-ramp transaction and a cryptocurrency wallet by:
identifying blockchain transaction outputs associated with the selected one or more blockchain transactions, and
determining the cryptocurrency wallet from the identified blockchain transaction outputs, wherein the cryptocurrency wallet is determined using the publicly available blockchain transaction data without receiving a wallet identifier from either the VASP or the on-ramp metadata;
Applicant is requested to provide support for the above limitations or else cancel the new matter.
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
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.
Step 1: Claims 1-7 are directed to a system; claims 8-14 are directed to method; claims 15-20 are directed to a computer readable storage medium – 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 claim 1, 8 and 15 recite the limitations –
receive on-ramp metadata associated with an on-ramp transaction between a fiat currency account and a virtual asset service provider (VASP), the on-ramp metadata comprising an amount value, a date-time value, and a transaction key;
retrieve, from a blockchain data source, publicly available blockchain transaction data, corresponding to blockchain transactions occurring within a defined temporal window relative to the date-time value, and within a defined transaction-value range relative to the amount value;
generate a candidate transaction dataset comprising blockchain transactions selected from the publicly available blockchain transaction data;
filter the candidate transaction dataset by excluding blockchain transactions satisfying predefined VASP batching criteria and predefined processing-fee deviation criteria to generate a filtered candidate transaction dataset;
for each blockchain transaction remaining in the filtered candidate transaction dataset, generate a link-score representing a likelihood that the blockchain transaction corresponds to the on-ramp transaction, wherein generating the link-score comprises:
applying temporal correlation processing between blockchain transaction timestamps and the date-time value; and
applying transaction-value correlation processing between blockchain transaction amounts and the amount value;
select, one or more blockchain transactions from the filtered candidate transaction dataset using the generated link scores;
reconstruct a blockchain transaction linkage association between the on-ramp transaction and a cryptocurrency wallet by:
identifying blockchain transaction outputs associated with the selected one or more blockchain transactions, and
determining the cryptocurrency wallet from the identified blockchain transaction outputs, wherein the cryptocurrency wallet is determined using the publicly available blockchain transaction data without receiving a wallet identifier from either the VASP or the on-ramp metadata;
determine high-risk blockchain behavior associated with the fiat currency account using the blockchain transaction linkage association and a blockchain risk model; and
use the transaction key to identify the fiat currency account and update a transaction-control setting of a transaction processing system associated with the identified fiat currency account to prevent completion of one or more payment network processes associated with a subsequent on-ramp transaction of the fiat currency account
– that fall under the abstract idea groupings of Mental Process and/or Certain Methods of Organizing Human Activity.
The dependent claims –
(Claims 2, 9, 16)
generate the transaction dataset by:
retrieving an initial group of blockchain transactions from a blockchain data source based on the defined temporal window relative to the date- time value and the defined transaction-value range relative to the amount value;
generating initial link scores for respective blockchain transactions of the initial group of blockchain transactions;
adjusting the initial link scores for one or more of the initial group of blockchain transactions by applying the temporal correlation processing and the transaction-value correlation processing to the respective blockchain transactions; and
selecting blockchain transactions from the initial group of blockchain transactions for inclusion in the filtered candidate transaction dataset based on the adjusted initial link scores
(Claim 3, 10, 17)
reconstruct the blockchain transaction linkage association by:
retrieving blockchain transaction output data associated with the selected one or more blockchain transactions;
identifying one or more destination cryptocurrency wallet addresses from the blockchain transaction output data; and
generating the association between: the fiat currency account, the on-ramp transaction, and the one or more destination cryptocurrency wallet addresses.
(Claim 4, 11, 18)
wherein the reconstructed blockchain further comprises:
a blockchain transaction identifier associated with the selected one or more blockchain transactions;
a blockchain transaction timestamp corresponding to the selected one or more blockchain transactions;
a blockchain transaction amount corresponding to the selected one or more blockchain transactions; and
the transaction key associated with the on-ramp transaction.
(Claim 5, 12, 19)
obtain historical blockchain transaction linkage associations generated for previous on- ramp transactions; and
update one or more transaction-selection parameters used for constructing subsequent blockchain transaction linkage associations, the transaction-selection parameters including one or more of:
the temporal correlation processing,
the transaction-value correlation processing,
the predefined VASP batching patter, or
the predefined processing-fee deviations,
based on the historical blockchain transaction linkage associations.
(Claim 6, 13, 20)
update the blockchain transaction linkage association between the fiat currency account and the cryptocurrency wallet in response to additional blockchain transaction data associated with the cryptocurrency wallet; and
update the transaction-control setting of the transaction processing system based on the updated association
(Claims 7, 14)
generate a graphical user interface (GUI) configured to display:
the association between the fiat currency account and the cryptocurrency wallet;
one or more blockchain transaction identifiers associated with the selected one or more blockchain transactions; and
corresponding blockchain transaction timestamps and transaction amounts,
wherein the GUI is configured to display blockchain-linked transaction activity associated with the fiat currency account
– that also fall under the abstract idea categories Mental Process and/or Certain Methods of Human Activity.
Hence under Prong One of Step 2A, claims 1-20 recite a combination of judicial exceptions.
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: a system comprising processor and memory; a computer storage medium; cryptocurrency wallet; metadata; a graphical user interface (GUI). Examiner 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 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 – receive on-ramp metadata associated with an on-ramp transaction between a fiat currency account and a virtual asset service provider (VASP), the on-ramp metadata comprising an amount value, a date-time value, and a transaction key; retrieve, from a blockchain data source, publicly available blockchain transaction data, corresponding to blockchain transactions occurring within a defined temporal window relative to the date-time value, and within a defined transaction-value range relative to the amount value; generate a candidate transaction dataset comprising blockchain transactions selected from the publicly available blockchain transaction data; filter the candidate transaction dataset by excluding blockchain transactions satisfying predefined VASP batching criteria and predefined processing-fee deviation criteria to generate a filtered candidate transaction dataset; for each of the identified plurality of blockchain transaction remaining in the filtered candidate transaction dataset, generate a link-score representing a likelihood that the blockchain transaction corresponds to the on-ramp transaction, wherein generating the link-score comprises: applying temporal correlation processing between blockchain transaction timestamps and the date-time value; and applying transaction-value correlation processing between blockchain transaction amounts and the amount value; one or more blockchain transactions from the filtered candidate transaction dataset using the generated link scores; reconstruct a blockchain transaction linkage association between the on-ramp transaction and a cryptocurrency wallet by: identifying blockchain transaction outputs associated with the selected one or more blockchain transactions, and determining the cryptocurrency wallet from the identified blockchain transaction outputs, wherein the cryptocurrency wallet is determined using the publicly available blockchain transaction data without receiving a wallet identifier from either the VASP or the on-ramp metadata; determine high-risk blockchain behavior associated with the fiat currency account using the blockchain transaction linkage association and a blockchain risk model; and use the transaction key to identify the fiat currency account and update a transaction-control setting of a transaction processing system associated with the identified fiat currency account to prevent completion of one or more payment network processes associated with a subsequent on-ramp transaction of the fiat currency account – 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).
Therefore, the additional elements, 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. When considered individually or as an ordered combination, the additional elements fail to transform the abstract idea of – receive on-ramp metadata associated with an on-ramp transaction between a fiat currency account and a virtual asset service provider (VASP), the on-ramp metadata comprising an amount value, a date-time value, and a transaction key; retrieve, from a blockchain data source, publicly available blockchain transaction data, corresponding to blockchain transactions occurring within a defined temporal window relative to the date-time value, and within a defined transaction-value range relative to the amount value; generate a candidate transaction dataset comprising blockchain transactions selected from the publicly available blockchain transaction data; filter the candidate transaction dataset by excluding blockchain transactions satisfying predefined VASP batching criteria and predefined processing-fee deviation criteria to generate a filtered candidate transaction dataset; for each of the identified plurality of blockchain transaction remaining in the filtered candidate transaction dataset, generate a link-score representing a likelihood that the blockchain transaction corresponds to the on-ramp transaction, wherein generating the link-score comprises: applying temporal correlation processing between blockchain transaction timestamps and the date-time value; and applying transaction-value correlation processing between blockchain transaction amounts and the amount value; one or more blockchain transactions from the filtered candidate transaction dataset using the generated link scores; reconstruct a blockchain transaction linkage association between the on-ramp transaction and a cryptocurrency wallet by: identifying blockchain transaction outputs associated with the selected one or more blockchain transactions, and determining the cryptocurrency wallet from the identified blockchain transaction outputs, wherein the cryptocurrency wallet is determined using the publicly available blockchain transaction data without receiving a wallet identifier from either the VASP or the on-ramp metadata; determine high-risk blockchain behavior associated with the fiat currency account using the blockchain transaction linkage association and a blockchain risk model; and use the transaction key to identify the fiat currency account and update a transaction-control setting of a transaction processing system associated with the identified fiat currency account to prevent completion of one or more payment network processes associated with a subsequent on-ramp transaction of the fiat currency account – 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.
Prior Art
Relevant Prior Art not relied upon but made of record:
Improving Decision-Making in Blockchain-Based Systems Using Fuzzy Logic by Abdullaeh et al., 16th International Conference on Applications of Fuzzy Systems, Soft Computing and Artificial Intelligence Tools – ICAFS-2023, pages 228-236
Review of Advances in Fuzzy Logic Models for Fraud Detection, Usman et al., Bima Journal of Science and Technology, Vol. 8(3) Sept, 2024 ISSN: 2536-6041
Data division using Fuzzy Logic and Blockchain for data security in cyber space, Sreenivasan et al., 4th International Conference on Innovative Data Communication Technology in cyber space.
Fuzzy Neural Network for Detecting Anomalies in Blockchain Transactions, Apiecionek et al., Published: 25 November 2024, Electronics 2024, 13, 4646. https://doi.org/10.3390/electronics13234646
Secure Intelligent Fuzzy Blockchain Framework: Effective Threat Detection in IoT Networks, Yazdinejad et al., ACM Digital Library, Computers in Industry, Vol. 144, No. C.
A Lightweight Scalable and Secure Blockchain Based IoT Using Fuzzy Logic, Anita et al., Wireless Personal Communications (2022) 125:2129–2146, Published online: 19 March 2022
Blockchain-Based and Fuzzy Logic-Enabled False Data Discovery for the Intelligent Autonomous Vehicular System, Rahman et al., ASSS ’23, July 10–14, 2023, Melbourne, VIC, Australia
Crypto Crime Has Hit Main Street. Here’s How Local Law Enforcement Can Tak Action, December 13, 2022 by Gurvias Grigg, Chainalysis.
US20160342976 Method and system for linkage of blockchain-based assets to fiat currency accounts
US20160342989 Method and system for processing blockchain-based transactions on existing payment networks
US20200082365 Cryptocurrency payment network
US20200151682 Digital fiat currency
US20210035110 Blockchain transaction fuzzy validation
Response to Arguments
Applicant's arguments filed 7/19/2026 have been fully considered but they are not persuasive.
101
Applicant argues (Remarks 7/19/2026) that the claims, as amended, are directed to a specific machine- implemented blockchain transaction reconstruction architecture that addresses a technological problem arising from the independent operation of blockchain transaction systems and fiat transaction processing systems. As described in the Specification (e.g., paragraphs [0012] - [0017] and [0032] - [0038]), blockchain transaction systems intentionally expose only publicly available blockchain transaction records, transaction outputs, timestamps, and values while omitting any native identifier linking those records to corresponding fiat-side on-ramp transactions. Conversely, fiat transaction systems maintain account and transaction information but do not expose corresponding blockchain wallet identifiers or blockchain transaction identifiers. Consequently, neither system independently maintains an blockchain transaction linkage association between fiat transaction events and blockchain transaction outputs. The amended claims address this technological problem through a specific sequence of machine-implemented blockchain transaction reconstruction operations. In particular, the amended claims recite retrieving publicly available blockchain transaction data, generating and filtering candidate blockchain transaction datasets using blockchain-specific criteria, reconstructing a blockchain transaction linkage association between fiat-side on-ramp transactions and blockchain-side cryptocurrency wallets from publicly available blockchain transaction outputs without receiving wallet identifiers from the VASP or the on-ramp metadata, and thereafter employ the reconstructed association in different technological ways. For example, Claim 1 uses the reconstructed association to automatically update transaction-control settings of a transaction processing system, Claim 8 uses the reconstructed association to identify subsequent on-ramp transactions for automated transaction control, and Claim 15 generates and transmits the reconstructed association and causes a transaction processing system to modify a transaction- control setting associated with the fiat currency account. Accordingly, the amended claims improve computerized reconstruction of blockchain transaction associations by enabling reconstruction of cross-system transaction associations that neither blockchain transaction systems nor fiat transaction systems natively maintain. The reconstructed associations are not merely informational, rather they enable machine-implemented transaction monitoring and automated transaction-processing operations without requiring disclosure of wallet identifiers by a virtual asset service provider.
Examiner respectfully disagrees.
Examiner notes that the amended claim limitations do not demonstrate any technical improvement but instead recite a series of abstract ideas. For example, retrieving publicly available blockchain transaction data within a temporal window and transaction value range; generating a candidate transaction dataset; generating a filtered transaction dataset by filtering the candidate transaction dataset by excluding transactions that satisfy VASP batching criteria and processing fee deviation criteria – involves observation, evaluation, judgment or opinion and hence falls under the Mental Process category of abstract ideas.
With regard to the limitation of generating a link score for the transactions remaining in the filtered candidate dataset by applying temporal correlation and transaction value correlation, between blockchain transaction and date-time value and amount value respectively, Examiner first notes that these limitations are not supported by the original disclosure and hence constitute inadmissible new matter; secondly, to the extent correlation represents association between transaction dataset and date-time value and transaction amount, this also involves observation, evaluation, judgment or opinion and hence falls under the Mental Process category of abstract ideas.
Next, with regard to the limitations – reconstructing a blockchain transaction linkage association between the fiat currency account and a cryptocurrency wallet using publicly available blockchain transaction data, wherein the cryptocurrency wallet is determined without receiving a wallet identifier from either the VASP or the on-ramp metadata; receiving a subsequent on-ramp transaction associated with the fiat currency account: and using a transaction key associated with the subsequent on-ramp transaction to identify the fiat currency account and update a transaction-control setting of a transaction processing system associated with the identified fiat currency account to prevent completion of one or more payment network processes associated with the subsequent on-ramp transaction – Examiner points out that (1) the limitations such as “reconstructing a blockchain transaction linkage” and “update a transaction-control setting” … “without receiving a wallet identifier from either the VASP or the on-ramp metadata” are not supported by the original disclosure and hence constitute inadmissible metadata; (2) reconstructing linkage between fiat currency account and a cryptocurrency wallet using publicly available blockchain transaction data, wherein the cryptocurrency wallet is determined without receiving a wallet identifier – requires involves observation, evaluation, judgment or opinion and hence falls under the Mental Process category of abstract ideas; (3) using a transaction key associated with the subsequent on-ramp transaction to identify the fiat currency account and update a transaction-control setting of a transaction processing system associated with the identified fiat currency account to prevent completion of one or more payment network processes associated with the subsequent on-ramp transaction – is a risk management measure in business and commerce that constitutes Fundamental Economic Practice and/or Commercial or Legal Interaction and hence fall under Certain Methods of Organizing Human Activity.
Applicant’s invocation of Enfish, McRO, DDR, SRI, etc. are not persuasive because each of these cases involved technical improvement in the form of a new data structure that improve the functioning of the computer (Enfish); improved rules to achieve accurate and realistic lip synchronization and facial expressions in animated characters (McRO); hybrid web page to merge third party content with host website (DDR); or solve a specific problem of suspicious network activity in the realm of computer networks (SRI). The pending claims, on the other hand are directed to analyzing blockchain transaction data based on batching criteria, processing fee deviation criteria, generating link score representing a likelihood that the blockchain transaction corresponds to on-ramp transaction, reconstructing blockchain transaction linkage between on-ramp transaction and a cryptocurrency wallet, determining high risk behavior associated with the fiat currency account, and preventing the completion of on-ramp transaction – that does nothing to improve a computer or any technology. The claims may help determining high-risk behavior in blockchain transaction but does not improve any blockchain technology. The focus of the claims is not on improvement in computers, but in the implementation of certain independently abstract ideas – determining high risk behavior associated with on ramp transactions – that merely uses generic computers as tools. Using transaction linkage and blockchain risk model may help identify high risk behavior in blockchain transactions but it does not achieve an improved technological result. Steps that do no more than spell out what it means to “apply it on a blockchain” 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).
The ordered combination of steps recited in claims 1-20 does 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 additional elements, when considered individually or as an ordered combination, do not integrate the abstract idea into a practical application or provide significantly more. 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.”).
For the above reasons, the Applicant’s arguments are not persuasive.
Previously Addressed
Applicant asserts (Remarks 1/8/2026) that previously, there was no practical or reliable way to link a fiat on-ramp transaction to the specific blockchain transaction that actually embodied the cryptocurrency transfer, and therefore no way to determine the true destination wallet of that on-ramp event. This was due to multiple technical barriers: (1) blockchain ledgers are pseudonymous and contain no fiat-side identifiers; (2) VASPs generally do not disclose withdrawal transaction IDs or receiving addresses; and (3) blockchain posting times, transaction fees, batching behaviors, and network delays break any straightforward correlation between fiat records and blockchain records. Applicant argues that 1 overcomes these technical barriers by determining which blockchain transaction corresponds to a given on-ramp transaction. As described in [0013], [0017], [0032] – [0038], the system evaluates publicly visible blockchain transactions using approximate temporal and value-range similarity rules, iteratively adjusts continuous link-scores for each candidate blockchain transaction, eliminates transactions whose values fall into common batching or fee-inconsistent patterns, and ranks the remaining candidates. Through this scoring and elimination process, the system identifies the specific blockchain transaction (or transactions) most likely to correspond to the fiat on-ramp transaction-a technical capability that did not exist previously. This ability to resolve a fiat on-ramp event into its actual blockchain transaction counterpart, and only thereafter infer the correct destination wallet, is itself the technological improvement. It enables attribution and traceability that were previously impossible for blockchain or banking systems, even when performed by experts. Applicant argues that claim 1 expressly recites that the identified cryptocurrency wallet is inferred and reconstructed even though a wallet identifier is neither explicitly provided by the virtual asset service provider nor included in the on-ramp metadata. This clarification makes clear that the claim is not directed to a financial or business practice, nor to a mental process, but instead to a technical solution to a blockchain-specific attribution problem caused by intentional anonymity, batching, and fee-induced non-determinism in distributed ledger systems. Applicant argues that claim 1 recites a particular way of resolving missing technical identifiers using probabilistic link-scoring and public blockchain data, which cannot practically be performed in the human mind and which meaningfully limits any alleged abstract idea.
Examiner respectfully disagrees.
Examiner finds the above arguments unpersuasive because none of the limitations recited in the independent (or dependent) claims involve technical improvement; rather each of the limitations recites either an abstract ide or a combination of abstract ideas. For example, in claim 1, the steps of generating, assigning, adjusting base link-score requires observation, evaluation, judgment and opinion and hence constitutes Mental Process. Similarly, the determination of how the amount of the blockchain transaction falls within an amount value range relative to the amount of value of the on-ramp transaction, when an amount of blockchain is or is not within common VASP batch patterns and is or is not inconsistent with defined standard processing fee deviation, and selecting a blockchain transaction with a highest generated link-score – also requires observation, evaluation, judgment and opinion and hence constitutes Mental Process. Generating, and adjusting link score involves Mathematical Concepts. Finally, the limitation of inferring a wallet identifier that is not explicitly provided by the VSAP and not included in the on-ramp metadata appears to be almost guesswork and is thus also a Mental Process. Hence, independent claim 1 recites a combination of Mental Process and/or Mathematical Concepts.
As regarding the dependent claims, Examiner notes that determining and identifying high-risk behavior in claims 3-7 falls under Fundamental Economic Practice which is a subcategory of Certain Methods of Organizing Human Activity. Examiner also notes that limitation of generating fiat currency account risk rating from the blockchain risk model (claim 3) and adjusting the blockchain risk model using machine learning and based on the obtained feedback data, whereby accuracy of the blockchain risk model is improved for future high-risk behavior determinations (claim 5) falls under Mathematical Concepts. Hence, the dependent claims recite a combination of Mathematical Concepts, Mental Process and/or Certain Methods of Organizing Human Activity.
Examiner further points out that the so-called technical barriers as described by the applicant – pseudonymous nature of blockchain ledgers – are an intrinsic feature of blockchain that cannot be changed or overcome. Blockchains were designed to be pseudonymous such that each participant is identified by unique alphanumeric string rather than name or physical address but all transactions can be traced on the public ledger. Contrary to applicant’s assertion, no technical barrier has been overcome by claim 1 because all transactions on the public blockchain are available to everyone including law enforcement. An analyst or law enforcement official may identify, from the publicly available blockchain transaction metadata or from the VASP or from the financial institution (FI), every occurrence of on-ramp transaction between a fiat currency account and VASP for exchange between fiat currency and cryptocurrency as disclosed in para [0012]. This does not require overcoming any technical challenges but mere application of mental processes. Applicant’s invocation of the disclosure from para [0013], [0017], [0032], [0038] are not persuasive of technical improvement because they merely provide a high-level overview of the concepts of determining links between on-ramp and other blockchain transactions through the use of date-time values, machine learning trained modeling. This no more than conceptual overview of the application of fuzzy logic to blockchain transaction data as opposed to improvement in the functioning of the blockchain
Applicant argues that even if fuzzy logic and scoring are viewed as involving mathematical concepts, claim 1 does not recite mathematical formulas, equations, or calculations. Instead, claim 1 recites functional operations and system behavior. As emphasized in the Memo, claims that merely involve mathematics without setting forth mathematical relationships do not recite a judicial exception and are eligible without further analysis.
Examiner respectfully disagrees.
First, claims do not have to explicitly recite mathematical formula or equations in order to be deemed abstract. MPEP § 2106.04(a)(2)(I): It is important to note that a mathematical concept need not be expressed in mathematical symbols, because “[w]ords used in a claim operating on data to solve a problem can serve the same purpose as a formula.” In re Grams, 888 F.2d 835, 837 and n.1, 12 USPQ2d 1824, 1826 and n.1 (Fed. Cir. 1989). See, e.g., SAP America, Inc. v. InvestPic, LLC, 898 F.3d 1161, 1163, 127 USPQ2d 1597, 1599 (Fed. Cir. 2018) (holding that claims to a ‘‘series of mathematical calculations based on selected information’’ are directed to abstract ideas); Digitech Image Techs., LLC v. Elecs. for Imaging, Inc., 758 F.3d 1344, 1350, 111 USPQ2d 1717, 1721 (Fed. Cir. 2014) (holding that claims to a ‘‘process of organizing information through mathematical correlations’’ are directed to an abstract idea); and Bancorp Servs., LLC v. Sun Life Assurance Co. of Can. (U.S.), 687 F.3d 1266, 1280, 103 USPQ2d 1425, 1434 (Fed. Cir. 2012) (identifying the concept of ‘‘managing a stable value protected life insurance policy by performing calculations and manipulating the results’’ as an abstract idea).
Second, the limitation “adjusting the initial link scores of one or more of the initial group of blockchain transactions using a set of one or more fuzzy logic rules” in claim 2, requires adjusting a score using fuzzy logic and thus invokes mathematical calculations. Similarly, the limitation “generating, by the blockchain risk model, an account risk rating associated with the fiat currency account” in claim 3 also involves mathematical calculations.
For the above reasons, the applicant’s arguments are not persuasive.
Applicant asserts that the ability to resolve a fiat on-ramp event into its actual blockchain transaction counterpart, and only thereafter infer the correct destination wallet, is itself the technological improvement. It enables attribution and traceability that were previously impossible for blockchain or banking systems, even when performed by experts.
Examiner finds this unpersuasive because blockchains being pseudonymous, can eventually be traced to the actual user, when necessary, by the age-old practice of “follow the money.” For example, the Department of Justice has been able to identify crypto criminals by tracking them to the exchanges. See NPL Chainalysis. Identifying fraud by following the trail of (crypto) funds to a (cryptocurrency) wallet is no less a fraud detection method than following the trail of fiat currency to a conventional digital wallet and thus falls under the abstract idea grouping of Fundamental Economic Practice.
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. That is, the consideration applies equally whether it is a computer-implemented invention, an invention in the life sciences, or any other technology. 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 business process of market trading but did not improve computers or technology.
Similarly, here the focus of the claims is not on any improvement in computer capabilities but on the abstract idea of financial risk management. The problem purportedly addressed here is financial risk management and not technological – identifying malicious transaction behavior associated with cryptocurrencies. Using fuzzy logic rules on temporal and similarity metric to determine that high-risk transaction behavior associated with a fiat currency account – may help counter likely transaction fraud or risky behavior by fiat currency account holders. But it does not improve computers or technology. To the extent the claimed invention purports to provide an improvement, that improvement does not concern an improvement to computer capabilities but instead relates to achieving the aim of identifying high risk blockchain transactions – a process in which generic computers are merely used as tools in their ordinary capacity. This is risk management as opposed to technical improvement. Attribution and traceability are merely the result or effect of application of the abstract idea(s). Using fuzzy logic may facilitate identify high risk blockchain transactions but it does not achieve an improved technological result.
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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/ARUNAVA CHAKRAVARTI/Primary Examiner, Art Unit 3692
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