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 § 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 101 because the claimed invention is directed to an abstract idea without significantly more.
Step 1: Claim 1 is directed to a method, claim 11 is directed to a computing device, and claim 16 is directed to one or more non-transitory computer-readable media. Therefore, the claims are directed to statutory subject matter under Step 1 (Step 1: YES). See MPEP 2106.03.
Prong 1, Step 2A: Claim 1 or claim 11 or claim 16 recites providing information corresponding to one or more reasons relating to an authorization decision for a payment card transaction between a merchant and a user, the method comprising: receiving, supplemental transaction metadata comprising one or more data elements corresponding to one or more attributes of the payment card transaction, wherein the supplemental transaction metadata is associated with a concurrent transmission of payment card information, for the payment card transaction, to a payment processing service; receiving, and from the payment processing service payment card authorization information indicating whether the payment card information was approved by the payment processing service; selecting, based on timing requirements associated with completion of processing of the supplemental transaction metadata, a first portion of the supplemental transaction metadata; determining, based on the timing requirements based on the first portion of the supplemental transaction metadata received from, and based on the payment card authorization information received from the payment processing service, whether the payment card transaction is authorized; sending, and based on the payment card authorization information and the supplemental transaction metadata, an authorization decision indicating whether the payment card transaction was authorized; receiving, a request for additional information, wherein the request for additional information comprises a reference identification (ID); querying, based on the reference ID, a database storing at least a second portion of the supplemental transaction metadata; and sending, and in response to the request for additional information, the at least the second portion of the supplemental transaction metadata. The above limitations, under their broadest reasonable interpretation, fall within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas, enumerated in MPEP 2106.04(a)(2)(II), in that they recite fundamental economic practices and commercial interactions. Claims 11 and 16 recite similar limitations as claim 1.
Metadata, as defined by Merriam-Webster, is “data that provides information about other data.” [0010] of the specification provides examples of transaction metadata comprising one or more data elements.
The limitation “wherein the supplemental transaction metadata is associated with a concurrent transmission of payment card information, for the payment card transaction” is not an active step of the method and thus merely further defines the metadata and thus the abstract idea. Even if the limitation was an active step, a step of wherein the supplemental transaction metadata is associated with a concurrent transmission of payment card information, for the payment card transaction would further fall within the “Certain Methods of Organizing Human Activity” grouping. The BRI of this limitation would include the user concurrently providing payment information to a payment processing service.
Accordingly, under Prong 1 of Step 2A, claims 1, 11, and 16 recite an abstract idea (Step 2A, Prong One: YES). See MPEP 2106.04(a).
Prong 2, Step 2A: The recitation of the additional elements of by a computing device and from a merchant device via a first application programming interface (API), by the merchant device by the computing device, via a second interface different from the first API, by the computing device, by the computing device, to the merchant device, by the computing device and from the merchant device, by the computing device, to the merchant device, the merchant device in claim 1 is acknowledged. Claim 11 further recites the additional elements of one or more processors, and memory storing instructions that, when executed by one or more processors, cause the data share computing device: a first application programming interface (API); second interface. Claim 16 recites the additional elements of non-transitory computer-readable media storing instructions that, when executed by one or more processors, cause a computing device; first application programming interface, computing device; a second interface. These additional elements are described at a high level in applicant’s specification without any meaningful detail about their structure or configuration. As such, these computer-related limitations are not found to be sufficient to integrate the abstract idea into a practical application. Although these additional computer-related elements are recited, claims 1, 11, and 16 merely invoke such additional elements as a tool to perform the abstract idea and generally link the use of the abstract idea to a particular technological environment or field of use. See MPEP 2106.05(f) and 2106.05(h).
The specification at [0048] indicates that using both transaction metadata and authorization information to determine whether to authorize a transaction, rather than just authorization information alone, is a significant improvement over conventional payment processing system. While using both transaction metadata and authorization information is recited in the claim, the claim, as drafted, reflects a business improvement, not a technological improvement. While the specification at other portions may describe technological improvements, such technological improvements are not claimed. The claim must include the components or steps of the invention that provide the improvement described in the specification. See MPEP 2106.05(a).
As detailed at MPEP 2106.05(a)(II), examples that the courts have indicated may not be sufficient to show an improvement in computer-functionality include: accelerating a process of analyzing audit log data when the increased speed comes solely from the capabilities of a general-purpose computer; and mere automation of manual processes, such as using a generic computer to process an application for financing a purchase or speeding up a loan-application process by enabling borrowers to avoid physically going to or calling each lender and filling out a loan application. Similarly, the claim 1 merely automates manual processes, such as using generic computers to receive transaction metadata, allow a user to determine whether to authorize the transaction, receive a dispute or fraud claim, and, when the claim is received, send or storing portion of the transaction metadata to avoid physically going to a financial institution to perform the same steps in person. The claimed invention may accelerate the manual process; however, the increased speed comes solely from the capabilities of general-purpose computers.
As such, under Prong 2 of Step 2A, when considered both individually and as a whole, the limitations of claims 1, 11, and 16 are not indicative of integration into a practical application (Step 2A, Prong Two: NO). See MPEP 2106.04(d).
Since claims 1, 11, and 16 recite an abstract idea and fail to integrate the abstract idea into a practical application, claims 1, 11, and 16 are “directed to” an abstract idea under Step 2A (Step 2A: YES). See MPEP 2106.04(d).
Step 2B: The recitation of the additional elements of by a computing device and from a merchant device via a first application programming interface (API), by the merchant device by the computing device, via a second interface different from the first API, by the computing device, by the computing device, to the merchant device, by the computing device and from the merchant device, by the computing device, to the merchant device, the merchant device in claim 1 is acknowledged, as identified above with respect to Prong 2 of Step 2A. Claim 11 recites the additional elements of one or more processors, and memory storing instructions that, when executed by one or more processors, cause the data share computing device: a first application programming interface (API); second interface. Claim 15 further recites the additional elements of non-transitory computer-readable media storing instructions that, when executed by one or more processors, cause a computing device; first application programming interface, computing device; a second interface. As discussed above, although additional computer-related elements are recited, claims 1, 11, and 16 merely invoke such additional elements as a tool to perform the abstract idea and recite the additional elements in order to further define the field of use of the abstract idea, therein attempting to generally link the use of the abstract idea to a particular technological environment. MPEP 2106.05(f) and MPEP 2106.05(h). Further, the additional limitations generally links the use of the abstract idea to a particular technological environment or field of use, e.g., a computer-implemented environment. As described above, claims 1, 11, and 16 do not purport to improve the functioning of the computer itself or any other technology or technical field. See MPEP 2106.05(a).
Even when considered as an ordered combination, the additional elements of claims 1, 11, and 16 do not add anything that is not already present when they are considered individually. Therefore, under Step 2B, there are no meaningful limitations in claims 1, 11, and 16 that transform the judicial exception into a patent eligible application such that the claims amount to significantly more than the judicial exception itself (Step 2B: NO). See MPEP 2106.05.
Accordingly, under the Subject Matter Eligibility test, claims 1, 11, and 16 are ineligible.
While the above addresses claim 1, 11, and 16, it is suggested to reconsider the eligibility of the dependent claims.
As for dependent claims 2-10, these claims recite limitation that further define the same abstract idea noted in claim 1. Therefore, they are considered patent ineligible for the reasons given above.
As for dependent claims 12-15, these claims recite limitation that further define the same abstract idea noted in claim 11. Therefore, they are considered patent ineligible for the reasons given above.
As for dependent claims 17-20, these claims recite limitation that further define the same abstract idea noted in claim 16. Therefore, they are considered patent ineligible for the reasons given above.
Response to Arguments
Applicant's arguments filed 3/10/2026 have been fully considered but they are not persuasive.
The applicant amended the claims, the examiner has updated the 35 U.S.C. §101 base on applicant’s amendment.
In response to applicant’s argument that the claims are not directed to an abstract idea, the examiner respectfully disagrees. Claims recite at least the following limitations that recite an abstract idea: providing information corresponding to one or more reasons relating to an authorization decision for a payment card transaction between a merchant and a user, the method comprising: receiving, supplemental transaction metadata comprising one or more data elements corresponding to one or more attributes of the payment card transaction, wherein the supplemental transaction metadata is associated with a concurrent transmission of payment card information, for the payment card transaction, to a payment processing service; receiving, and from the payment processing service payment card authorization information indicating whether the payment card information was approved by the payment processing service; selecting, based on timing requirements associated with completion of processing of the supplemental transaction metadata, a first portion of the supplemental transaction metadata; determining, based on the timing requirements based on the first portion of the supplemental transaction metadata received from, and based on the payment card authorization information received from the payment processing service, whether the payment card transaction is authorized; sending, and based on the payment card authorization information and the supplemental transaction metadata, an authorization decision indicating whether the payment card transaction was authorized; receiving, a request for additional information, wherein the request for additional information comprises a reference identification (ID); querying, based on the reference ID, a database storing at least a second portion of the supplemental transaction metadata; and sending, and in response to the request for additional information, the at least the second portion of the supplemental transaction metadata. The above limitations, under their broadest reasonable interpretation, fall within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas, enumerated in MPEP 2106.04(a)(2)(II), in that they recite fundamental economic practices and commercial interactions. The BRI of these limitations includes merchants based on transaction metadata (e.g., a listing of items involved in the transaction, the price of the items, etc., see [0046] of the specification). Therefore, the applicant’s argument is not persuasive.
In response to applicant’s argument that the claims integrate any alleged abstract idea into a practical application, the examiner respectfully disagrees. The recitation of the additional elements of by a computing device and from a merchant device via a first application programming interface (API), by the merchant device by the computing device, via a second interface different from the first API, by the computing device, by the computing device, to the merchant device, by the computing device and from the merchant device, by the computing device, to the merchant device, the merchant device in claim 1 is acknowledged. Claim 11 further recites the additional elements of one or more processors, and memory storing instructions that, when executed by one or more processors, cause the data share computing device: a first application programming interface (API); second interface. Claim 16 recites the additional elements of non-transitory computer-readable media storing instructions that, when executed by one or more processors, cause a computing device; first application programming interface, computing device; a second interface. These additional elements are described at a high level in Applicant’s specification without any meaningful detail about their structure or configuration. As such, these computer-related limitations are not found to be sufficient to integrate the abstract idea into a practical application. Although these additional computer-related elements are recited, claims 1, 11, and 16 merely invoke such additional elements as a tool to perform the abstract idea and generally link the use of the abstract idea to a particular technological environment or field of use. See MPEP 2106.05(f) and 2106.05(h). The specification at [0048] indicates that using both transaction metadata and authorization information to determine whether to authorize a transaction, rather than just authorization information alone, is a significant improvement over conventional payment processing system. While using both transaction metadata and authorization information is recited in the claim, the claim, as drafted, reflects a business improvement, not a technological improvement. While the specification at other portions may describe technological improvements, such technological improvements are not claimed. The claim must include the components or steps of the invention that provide the improvement described in the specification. See MPEP 2106.05(a). Therefore, the applicant’s argument is not persuasive.
In response to applicant’s argument that the claims add significantly more than any alleged abstract idea, the examiner respectfully disagrees. The recitation of the additional elements by a computing device and from a merchant device via a first application programming interface (API), by the merchant device by the computing device, via a second interface different from the first API, by the computing device, by the computing device, to the merchant device, by the computing device and from the merchant device, by the computing device, to the merchant device, the merchant device in claim 1 is acknowledged. Claim 11 further recites the additional elements of one or more processors, and memory storing instructions that, when executed by one or more processors, cause the data share computing device: a first application programming interface (API); second interface. Claim 16 recites the additional elements of non-transitory computer-readable media storing instructions that, when executed by one or more processors, cause a computing device; first application programming interface, computing device; a second interface. These additional elements are described at a high level in Applicant’s specification without any meaningful detail about their structure or configuration. As such, these computer-related limitations are not found to be sufficient to integrate the abstract idea into a practical application. Although these additional computer-related elements are recited, claims 1, 11, and 16 merely invoke such additional elements as a tool to perform the abstract idea and generally link the use of the abstract idea to a particular technological environment or field of use. See MPEP 2106.05(f) and 2106.05(h). The specification at [0048] indicates that using both transaction metadata and authorization information to determine whether to authorize a transaction, rather than just authorization information alone, is a significant improvement over conventional payment processing system. While using both transaction metadata and authorization information is recited in the claim, the claim, as drafted, reflects a business improvement, not a technological improvement. While the specification at other portions may describe technological improvements, such technological improvements are not claimed. The claim must include the components or steps of the invention that provide the improvement described in the specification. See MPEP 2106.05(a). Therefore, the applicant’s argument is not persuasive.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to I JUNG LIU whose telephone number is (571)270-1370. The examiner can normally be reached Monday-Friday.
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I JUNG LIU
Examiner
Art Unit 3695
/I JUNG LIU/Primary Examiner, Art Unit 3695