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 .
Response to Amendment
Applicant’s “Response to Amendment and Reconsideration” filed on 11/26/2025 has been considered.
Claim 7 is are added. Claims 2-3, 6 are cancelled. Claims 1, 4-5, 7 are pending in this application and an action on the merits follows.
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, 4-5, 7 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (abstract idea) without significantly more.
Regarding claims 1, 4-5, 7, under Step 2A, recites a judicial exception (abstract idea) that is not integrated into a practical application and does not provide significantly more.
Under Step 2A (prong 1), and taking claim 1 as representative recite:
a storage device in which a receipt information database and a return receipt information database are configured;
register receipt information received from a payment device in the receipt information database, the registered receipt information including a receipt ID and purchased product information on one or more products purchased in a transaction;
receive, from a payment device, transaction specifying information specifying the receipt ID and return information indicating returned product information on one or more products that have returned regarding the transaction;
upon receiving the transaction specifying information and the return information,
i) generate return receipt information based on the received return information and register the generated return receipt information in the return receipt information database, the registered return receipt information associated with the receipt ID, and return product information of the one or more returned products,
ii) correct the receipt information obtained registered in the receipt information database based on the return information, by correcting purchased product information, and adding access information to access the return receipt information registered in the return receipt information database;
and upon receiving a request for the corrected receipt information, extract the corrected receipt information from the receipt information database and output first display data for the extracted corrected receipt information to a customer terminal, causing a selectable object to select the access information to be displayed in a corrected receipt screen on the customer terminal;
and the corrected receipt screen causing a return receipt screen to be displayed on the customer terminal.
These limitations recite fundamental economic principles for example processing sales and returns, organizing human activities such as commercial transaction record management and mental processes such as receiving transaction data, updating records and associating related records. This is because the limitations above recite storing original receipt information, receiving return information, generating and storing return receipt information, correcting the original receipt based on returned products, outputting corrected receipt data with selectable access to a return receipt display.
Under Step 2A (prong 2), viewed individually or as a whole the abstract idea is not integrated into a practical application. The Examiner acknowledges that representative claim 1 recite additional elements such as server, storage, payment device, controller, customer terminal, screen, database. Although reciting additional elements, these elements are not sufficient to integrate the abstract idea into a practical application. This is because the additional elements are recited at a high level of generality (i.e. as generic computing hardware) such that they amount to nothing more than the mere instructions to implement or apply the abstract idea on generic computing hardware or, merely uses a computer as a tool to perform an abstract idea. For example, the server performs conventional database operations such as registering data, generating records, updating stored information and extracting and outputting data. The selectable object/display screen is standard UI behavior. Further, the additional elements do no more than generally link the use of a judicial exception to a particular technological environment or field of use (such as computers or computing networks).
Secondly, the additional elements are insufficient to integrate the abstract idea into a practical application because the claim fails to (i) reflect an improvement in the functioning of a computer, or an improvement to other technology or technical field, (ii) implement the judicial exception with, or use the judicial exception in conjunction with, a particular machine or manufacture that is integral to the claim, (iii) effect a transformation or reduction of a particular article to a different state or thing, or (iv) applies or uses the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment. Even considered as an ordered combination (as a whole), the additional elements of dependent claims 4-5, 7 do not add anything further than when they are considered individually. In view of the above, claims 4-5, 7 do not integrate the recited exception into a practical application.
In view of the above, under Step 2A (prong 2), claims 1, 4-5, 7 do not integrate the recited exception into a practical application (see again: 2019 PEG).
Under Step 2B, examiners should evaluate additional elements individually and in combination to determine whether they provide an inventive concept (i.e., whether the additional elements amount to significantly more than the exception itself). In this case, the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Returning to claim 1 taken individually or as a whole the additional elements do not provide an inventive concept (i.e. they do not amount to “significantly more” than the exception itself). As discussed above with respect to the integration of the abstract idea into a practical application, the additional elements used to perform the claimed process amount to no more than the mere instructions to apply the exception using a generic computer and/or no more than a general link to a technological environment. All functions could be implemented with ordinary/back-end server operations.
The additional elements fail to provide significantly more also because the claim simply appends well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception. For example, the additional elements of claims 1 utilize operations the courts have held to be well-understood, routine, and conventional (see: MPEP 2106.05(d)(II)), including at least:
receiving or transmitting data over a network
storing and retrieving information in memory
performing repetitive calculations
Further, see MPEP 2106.05(f), “Other examples where the courts have found the additional elements to be mere instructions to apply an exception, because they do no more than merely invoke computers or machinery as a tool to perform an existing process include: i. A commonplace business method or mathematical algorithm being applied on a general purpose computer, Alice Corp. Pty. Ltd. V. CLS Bank Int’l, 134 S. Ct. 2347, 1357, 110 USPQ2d 1976, 1983 (2014); Gottschalk v. Benson, 409 U.S. 63, 64, 175 USPQ 673, 674 (1972); Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015);”.
See MPEP 2106.05(d), “i. Receiving or transmitting data over a network, e.g., using the Internet to gather data, Symantec, 838 F.3d at 1321, 120 USPQ2d at 1362 (utilizing an intermediary computer to forward information); TLI Communications LLC v. AV Auto. LLC, 823 F.3d 607, 610, 118 USPQ2d 1744, 1745 (Fed. Cir. 2016) (using a telephone for image transmission); OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1093 (Fed. Cir. 2015) (sending messages over a network); buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014) (computer receives and sends information over a network); but see DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d 1245, 1258, 113 USPQ2d 1097, 1106;
Even considered as an ordered combination (as a whole), the additional elements of dependent claims 4-5, 7 do not add anything further than when they are considered individually.
In view of the above, claims 1, 4-5, 7 do not provide an inventive concept (“significantly more”) under Step 2B, and is therefore ineligible for patenting.
Claim Rejections - 35 USC § 102
The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
A person shall be entitled to a patent unless –
(a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention.
Claims 1, 4-5, 7 are rejected under 35 U.S.C. 102a2 as being anticipated by Argue et. al. (U.S. Patent Publication No. 2014/0122270).
Regarding claim 1, Argue teaches server device comprising:
a storage device in which a receipt information database and a return receipt information database are configured; (The system 100 may include a server system 102, The server system 102 may be in data communication with one or more user computers 104a, 104b and one or more point of sale (POS) locations 106a, 106b [23], An archiving module 122 may receive records of transactions from a POS location 106a, 106b. The information may be received in the form of an electronic receipt including some or all of a unique transaction identifier, the items purchased, [29], A version control module 126 may maintain an accurate record of modifications to a transaction. This may include recording such information as the date of a return, the item(s) returned, the amount of money refunded, [31], see Fig.1);
register receipt information received from a payment device in the receipt information database, the registered receipt information including a receipt ID and purchased product information on one or more products purchased in a transaction; (An archiving module 122 may receive records of transactions from a POS location ,[29], storing the electronic receipt, [48-49], The information may be received in the form of an electronic receipt including some or all of a unique transaction identifier, the items purchased, [29]);
receive, from a payment device, transaction specifying information specifying the receipt ID and return information indicating returned product information on one or more products that have returned regarding the transaction; (a transaction identifier may be received at the POS location 106a, 106b and the transaction identifier sent to the server system 102 with a request for some or all of the receipt data for the transaction, [33], The item identification module 134 may receive an identifier or some other indication of a user's selection of an item to be returned, where the item is listed on an electronic receipt, [34]_;
upon receiving the transaction specifying information and the return information,
i) generate return receipt information based on the received return information and register the generated return receipt information in the return receipt information database, the registered return receipt information associated with the receipt ID, and return product information of the one or more returned products, (A version control module 126 may maintain an accurate record of modifications to a transaction, [31], A notification module 140 may notify the server system 102 once a return has been completed and the server may update an electronic receipt accordingly, [34]);
ii) correct the receipt information obtained registered in the receipt information database based on the return information, by correcting purchased product information, and adding access information to access the return receipt information registered in the return receipt information database; (The electronic receipt is updated for returns and the electronic receipt may be viewable by a user, as a number of versions of the receipt or a markup showing modifications to the transaction, abstract);
and upon receiving a request for the corrected receipt information, extract the corrected receipt information from the receipt information database and output first display data for the extracted corrected receipt information to a customer terminal, (The retrieval module 110 may retrieve full receipt information for each transaction or only an identifier, date, or other information sufficient to identify a transaction such that a user may select a receipt and invoke the retrieval module 110 to retrieve the receipt as needed, [25], the version selection module 112 may enable a user to navigate among the different versions of the receipt. A display module 114 may use data defining a receipt or version of a receipt to render a graphical representation of a receipt or version of a receipt. The graphical representation of the receipt may resemble or be identical to a printed receipt generated at a POS location, [26]);
causing a selectable object to select the access information to be displayed in a corrected receipt screen on the customer terminal; (a displayed receipt or version of a receipt may include interface elements, or data operable as an interface element, to enable a user to select an item on a receipt. The selection may be received to enable the user to select an item for returning for a refund. The return module 118 may enable the user to invoke returning of the item at a POS location, [27],
and the corrected receipt screen causing a return receipt screen to be displayed on the customer terminal, (The selection module 116 may enable a user to select an item listed in a receipt…The return module 118 may enable the user to invoke returning of the item at a POS location, [27], the version selection module 112 may enable a user to request and/or invoke display by the user computer 104a, 104b of a version of a receipt. After each return is made of one or more items purchased in a transaction, a new version of the receipt may be generated or the change to the transaction otherwise recorded by the server system 102 in association with the transaction. Accordingly, the version selection module 112 may enable a user to navigate among the different versions of the receipt. A display module 114 may use data defining a receipt or version of a receipt to render a graphical representation of a receipt or version of a receipt, [26]).
Regarding claim 4, Argue teaches when the controller receives return information for same transaction specifying information multiple times, the controller generates the return receipt information each time receiving the received return information, and the first display data output by the controller causes multiple selectable objects corresponding to the return information received multiple times, respectively, to be displayed on the corrected receipt screen, (After each return is made of one or more items purchased in a transaction, a new version of the receipt may be generated or the change to the transaction otherwise recorded by the server system 102 in association with the transaction, [26]).
Regarding claim 5, Argue teaches the server according to wherein the multiple selectable objects are arranged on the corrected receipt screen in an order of receiving the corresponding return information, (A version control module 126 may maintain an accurate record of modifications to a transaction. This may include recording such information as the date of a return, [31]).
Regarding claim 7, Argue teaches wherein the corrected receipt screen indicates a list of the one or more products purchased in the transaction with indication of return with respect to the one or more products that have been returned regarding the transaction, and wherein the return receipt screen indicates details of the one or more products that have been returned regarding the transaction, (The electronic receipt is updated for returns and the electronic receipt may be viewable by a user, as a number of versions of the receipt or a markup showing modifications to the transaction, abstract, A version control module 126 may maintain an accurate record of modifications to a transaction. This may include recording such information as the date of a return, the item(s) returned, the amount of money refunded, [31]);
Response to Arguments
Applicant's arguments with respect to 35 U.S.C. 101 rejection have been fully considered but they are not persuasive.
Applicant argues “it is possible to responsively provide display of the return receipt screen on the customer terminal with reduced data traffic”. Examiner does not agree. The claim does not recite any specific technological mechanism for reducing data traffic or improving network performance. The claims merely recite storing receipt data, generating return receipt data, updating stored information and displaying information upon request using generic components (server device, payment device, customer terminal). Such operations constitute routine data storage, retrieval and presentation.
Applicant argues “computer functionality amounts to significantly more than an abstract idea in the same manner as Amdocs..” Examiner does not agree. Unlike Amdocs, the present claims do not require a specific distributed architecture operating in an unconventional manner, nor does it recite any particular network protocol or technical solution to network congestion. The claim instead reflects conventional client-server interaction in which additional information is displayed upon user selection, which is well-understood and routine.
Applicant’s arguments with respect to 35 U.S.C. 102 rejection have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument.
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.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to MILENA RACIC whose telephone number is (571)270-5933. The examiner can normally be reached M-F 7:30am-4pm EST.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Florian (Ryan) Zeender can be reached at (571)272-6790. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/MILENA RACIC/Patent Examiner, Art Unit 3627
/FLORIAN M ZEENDER/Supervisory Patent Examiner, Art Unit 3627