DETAILED ACTION
Introduction
This Office action is responsive to the communications filed March 24, 2026. Claims 1, 4-8, 10, 12-20 were amended. Claims 1-20 are pending.
Response to Arguments
1. Applicant has amended the claims, thereby overcoming the 35 U.S.C. 112(b) rejection set forth in the Non-Final rejection. However, the claims are rejection under this statute for the reasons indicated below.
2. As per the rejection under 35 U.S.C. 101, Applicant submits that the claims “are not directed merely a fundamental economic practice.” Also, it is asserted that the claims recite significantly more than an abstract idea. Particularly, the “ordered combination improves computerized transaction processing by providing tamper-resistant lifecycle tracking, automated document-compliance evaluation, and controlled release of funds in a distributed environment.”
However, the Examiner respectfully disagrees. The claims, as amended, are directed to the abstract idea of releasing funds and recording information based on an agreement, which is categorized under certain methods of organizing human activity. The additional elements are “generally linking the use of a judicial exception to a particular” field of use. MPEP 2106.05(h). The “additional element or combination of elements must do ‘more than simply stat[e]the [judicial exception] while adding the words ‘apply it’”. MPEP 2106.05(f).
3. Applicant’s arguments with respect to the 35 U.S.C. 103 rejection of the claims have been considered, but are moot in light of the new ground of rejection necessitated by the amendment.
Claim Interpretation
The following is a quotation of 35 U.S.C. 112(f):
(f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.
The following is a quotation of pre-AIA 35 U.S.C. 112, sixth paragraph:
An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.
The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked.
As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph:
(A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function;
(B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and
(C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function.
Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function.
Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function.
Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action.
This application includes one or more claim limitations that do not use the word “means,” but are nonetheless being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, because the claim limitation(s) uses a generic placeholder that is coupled with functional language without reciting sufficient structure to perform the recited function and the generic placeholder is not preceded by a structural modifier. Such claim limitation(s) is/are:
“artificial intelligence model configured to analyze” in claim 1.
The claim recites the generic placeholder “artificial intelligence” for performing the functions identified above. Upon review, the Examiner notes that the claimed phrase meets Prongs (A) and (B) as set forth in MPEP § 2181, subsection I. Additionally, the Examiner notes that “artificial intelligence” is not being modified by sufficiently definite structure, material, or acts for achieving the specified function; therefore, the claimed phrase meets Invocation Prong (C).
Because this/these claim limitation(s) is/are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it/they is/are being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof.
It is unclear from the specification which structure and algorithm are performing the corresponding function.
If applicant does not intend to have this/these limitation(s) interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, applicant may: (1) amend the claim limitation(s) to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph (e.g., by reciting sufficient structure to perform the claimed function); or (2) present a sufficient showing that the claim limitation(s) recite(s) sufficient structure to perform the claimed function so as to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph.
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.
The following is a quotation of 35 U.S.C. 112(b):
(b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention.
The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph:
The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention.
Claims 1-9 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.
Claim 1 recites “at least one artificial intelligence model,” which is not supported the specification. The specification recites an artificial intelligence module, agent, and assistants. Although the elements relate, they are not the same as a model.
Claims 1-9 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor, or for pre-AIA the applicant regards as the invention.
Claim limitation the “artificial intelligence model configured to analyze…”in claim 1; invoke 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. However, the written description fails to disclose the corresponding structure, material, or acts for performing the entire claimed function and to clearly link the structure, material, or acts to the function.
It is unclear from the specification which structure and algorithm are performing the corresponding function.
Claims 2-9 are rejected based on their dependency from independent claim 1.
Therefore, the claim is indefinite and is rejected under 35 U.S.C. 112(b) or pre-AIA 35 U.S.C. 112, second paragraph.
Applicant may:
(a) Amend the claim so that the claim limitation will no longer be interpreted as a limitation under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph;
(b) Amend the written description of the specification such that it expressly recites what structure, material, or acts perform the entire claimed function, without introducing any new matter (35 U.S.C. 132(a)); or
(c) Amend the written description of the specification such that it clearly links the structure, material, or acts disclosed therein to the function recited in the claim, without introducing any new matter (35 U.S.C. 132(a)).
If applicant is of the opinion that the written description of the specification already implicitly or inherently discloses the corresponding structure, material, or acts and clearly links them to the function so that one of ordinary skill in the art would recognize what structure, material, or acts perform the claimed function, applicant should clarify the record by either:
(a) Amending the written description of the specification such that it expressly recites the corresponding structure, material, or acts for performing the claimed function and clearly links or associates the structure, material, or acts to the claimed function, without introducing any new matter (35 U.S.C. 132(a)); or
(b) Stating on the record what the corresponding structure, material, or acts, which are implicitly or inherently set forth in the written description of the specification, perform the claimed function. For more information, see 37 CFR 1.75(d) and MPEP §§ 608.01(o) and 2181.
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 an abstract idea without significantly more.
In the instant case, claims 1-12 are directed to system. Claims 13-20 are directed to a method. Therefore, these claims fall within the four statutory categories of invention.
For example, claim 1 recites an abstract idea of releasing funds and recording information based on an agreement. The claim under its broadest reasonable interpretation recites limitations grouped within the “certain methods of organizing human activity” grouping of abstract ideas. The certain methods of organizing human activity abstract idea grouping is defined as concepts related to fundamental economic principles or practices, commercial or legal interactions including agreements in the form of contracts, legal obligations, advertising, marketing or sales activities or behaviors, and business relations. See MPEP § 2106.04(a)(2), subsection II. The claim limitations reciting the abstract idea are grouped within the “certain methods of organizing human activity” grouping of abstract ideas as they relate to releasing funds and recording information based on an agreement. More specifically, the following the bolded claim elements recite additional elements while the other claim elements recite the abstract idea. according to MPEP 2106.04(a).
1. A computer system comprising:
(a) a decentralized and immutable ledger;
(b) a letter of credit (LC) object stored in said decentralized and immutable ledger;
(c) a plurality of documents related to said LC object uploaded to said computer system;
(d) at least one artificial intelligence model configured to analyze said plurality of documents to determine compliance with one or more requirements of said LC object, wherein said at least one artificial intelligence model utilizes one or both of natural language processing (NLP) and large language model (LLM) techniques; and
(e) a buyer wallet for a buyer onboarded to said computer system, and an escrow wallet related to said LC object; wherein said computer system facilitates a payment from said escrow wallet to a seller in accordance with said one or more requirements by:
(i) determining, for each of said one or more requirements, a compliance status selected from Complete and Pending;
(ii) recording, in said decentralized and immutable ledger in association with said LC object, compliance status information for said one or more requirements: and
(iii) in response to determining that said one or more requirements are satisfied, causing an escrow service coupled to said escrow wallet to release funds from said escrow wallet in accordance with said LC object, and recording, in association with said LC object, a cryptographic hash of each analyzed document.
Independent claims 10 and 13 recite similar language.
This judicial exception is not integrated into a practical application because, when analyzed under prong two of step 2A of the Alice/Mayo test (See MPEP 2106.04(d)), the additional element(s) of the claim(s) such as the escrow wallet, decentralized and immutable ledger, computer system, buyer wallet, and artificial intelligence model are merely used as tools to perform an abstract idea and/or generally link the use of a judicial exception to a particular technological environment. Specifically, these additional elements perform the steps or functions of releasing funds and recording information based on an agreement. Viewed as a whole, the use of escrow wallet, decentralized and immutable ledger, computer system, buyer wallet, and artificial intelligence model as tools to implement the abstract idea and/or generally linking the use of the abstract idea to a particular technological environment does not integrate the abstract idea into a practical application because it requires no more than a computer or computer networks performing functions that correspond to acts required to carry out the abstract idea. The additional elements do not involve improvements to the functioning of a computer, or to any other technology or technical field (MPEP 2106.05(a)), and the claims do not apply or use the abstract idea in some other meaningful way beyond generally linking the use of the abstract idea to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception (MPEP 2106.05(e) and Vanda Memo). Therefore, the claims do not, for example, purport to improve the functioning of a computer. Nor do they effect an improvement in any other technology or technical field. Accordingly, the additional elements do not impose any meaningful limits on practicing the abstract idea, and the claims are directed to an abstract idea.
The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when analyzed under step 2B of the Alice/Mayo test (See MPEP 2106.05), the additional element(s) of the escrow wallet, decentralized and immutable ledger, computer system, buyer wallet, and artificial intelligence model to perform the steps amounts to no more than using generic hardware or software to automate and/or implement the abstract idea of releasing funds and recording information based on an agreement. Viewed as a whole, the combination of elements recited in the claims merely recite the concept of releasing funds and recording information based on an agreement. Therefore, the use of these additional elements does no more than employ the computer as a tool to automate and/or implement the abstract idea. The use of a computer or processor to merely automate and/or implement the abstract idea cannot provide significantly more than the abstract idea itself (MPEP 2106.05 (f) & (h)). Therefore, the claim is not patent eligible.
The dependent claims further describe the abstract idea such as analyzing utilizes one or both of natural language processing and large language model.
The dependent claims do not include additional elements that integrate the abstract idea into a practical application or that provide significantly more than the abstract idea. Therefore, the dependent claims are also not patent eligible.
Claim Rejections - 35 USC § 103
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
Claims 1-20 are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Publication No. 2021/0126791 to Lu et al. (“Lu”) in view of U.S. Publication No. 2023/0015846 to Toffey et al. (“Toffey”), U.S. Publication No. 2025/0156828 to Sliwka et al. (“Sliwka”), and U.S. Publication No. 2025/0390947 to Shepherd et al. (“Shepherd”).
As per claim 1, Lu discloses a decentralized and immutable ledger (abstract and paragraph [0002]); a letter of credit (LC) object stored in said decentralized and immutable ledger (Fig. 5); a plurality of documents related to said LC object uploaded to said computer system (abstract).
Lu does not expressly disclose at least one artificial intelligence model configured to analyze said plurality of documents to determine compliance with one or more requirements of said LC object, wherein said at least one artificial intelligence model utilizes one or both of natural language processing (NLP) and large language model (LLM) techniques; and
a buyer wallet for a buyer onboarded to said computer system, and a custodial escrow wallet related to said LC object; wherein said computer system facilitates a payment from said custodial wallet to a seller in accordance with said requirements.
Toffey discloses at least one artificial intelligence model configured to analyze said plurality of documents to determine compliance with one or more requirements of said LC object, (paragraphs [0012]- a data processing and artificial intelligence system for processing data about events, transactions and entities and facilitating development and deployment of automation, machine learning, artificial intelligence, and/or analytics for a wide variety of trade finance network applications; [0037] – letter of credit);
wherein said at least one artificial intelligence model utilizes one or both of natural language processing (NLP) and large language model (LLM) techniques (paragraph [0101]).
Sliwka discloses a buyer wallet for a buyer onboarded to said computer system, and a escrow wallet related to a LC object; wherein said computer system facilitates a payment from said custodial wallet to a seller in accordance with said requirements (paragraphs [0134], [0156] – trade and [0150]).
Also, the “wherein clause” has been considered; however, it merely expresses the intended results. See MPEP§ 2111.04. It is not a step that needs to be performed and does not patentable distinguish over the disclosure of the prior art.
Shepherd discloses an escrow wallet (abstract); a buyer wallet (paragraph [0085])
(i) determining, for each of said one or more requirements, a compliance status selected from Complete and Pending (paragraphs [0067] and [0105]);
(ii) recording, in said decentralized and immutable ledger in association with said LC object, compliance status information for said one or more requirements: (paragraph [0071]) and
(iii) in response to determining that said one or more requirements are satisfied, causing an escrow service coupled to said escrow wallet to release funds from said escrow wallet in accordance with said LC object, and recording, in association with said LC object, a cryptographic hash of each analyzed document (paragraph [0119]).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to include the elements of Toffey, Sliwka, and Shepherd into Lu as these references relate to processing blockchain transactions. Hence, since the claimed invention is merely a combination of old elements, and in the combination each element merely would have performed the same function as it did separately, one of ordinary skill in the art would have recognized that the results of the combination were predictable.
As per claim 2, Lu discloses decentralized and immutable ledger is based on blockchain technology (abstract).
As per claim 3, Lu discloses one or more of said plurality of documents are tamper-proofed by employing digital signatures (paragraph [0090]).
As per claim 4, Toffey discloses analyzing utilizes one or both of natural language processing (NLP) and large language model (LLM) techniques (paragraph [0101]).
As per claim 5, Toffey discloses the computer system marks a status of a document as one of Complete and Pending based on said analyzing (paragraph [0082] -updating, which could include complete or pending).
As per claim 6, Lu in combination with Toffey, Sliwka, and Shepherd disclose seller is also onboarded to said computer system, and wherein the computer system further comprises a seller wallet for said seller (Toffey at paragraph [0017]) and a non-custodial wallet for said seller (Sliwka -see claim 1 above).
As per claim 7, Sliwka discloses wherein user access to said computer system requires biometric authentication from one or both of said buyer and said seller b (paragraph [1339]).
As per claim 8, Sliwka discloses said payment is made in one of a fiat currency or and a cryptocurrency (paragraph [0326] – currency tokens and fiat currency).
As per claim 9, Lu in combination with Toffey and Sliwka discloses said payment is made to an international bank account number (IBAN) of said seller (Lu at paragraphs [0004] – international transactions; [0178] – offshore bank).
Claims 10-12 are rejected on the same rationale as claims 1-3, respectively.
Claims 13-16 are rejected on the same rationale as claims 1-4, respectively.
Claims 17-20 is rejected on the same rationale as claims 6-9, respectively.
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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/Jalatee Worjloh/Primary Examiner, Art Unit 3697
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