DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 3/2/2026 has been entered.
Response to Arguments
Applicant's submission filed on 3/2/2026 has been entered but are not persuasive.
Applicant’s representative has amended the independent claims to recite:
“a database comprising a plurality of invoices and rules;
a processing unit for consolidating the plurality of invoices from the one or more benefits vendors that are in at least two different formats, and wherein the processing unit standardizes each of a data element of the plurality of invoices to a common format”,
and argues that the claims now recite patentable subject matter.
In response, the claims still fail to recite additional elements that are sufficient to amount to significantly more than the judicial exception because:
The additional elements of a processing unit and a database when considered both individually and as a combination do not amount to significantly more than the abstract idea. The claims recite the additional elements of a ”processor”, “processing unit”, a “rules engine”, a ‘trained neural network”, a “database” and a computing “device.
The claimed devices, rules engine, neural network, processing unit and a processor with a database taken individually or as a whole are each seen as a general purpose computer or a computer system (see the applicant’s specification).
These claimed elements are noted to perform routine computer functions such as analyzing and comparing data, calculating data, transmitting data and communicating data.
The claimed rules engine, and processor with a database are seen as a generic computer performing generic functions without an inventive concept as such do not amount to significantly more. These devices are simply a field of use that attempts to limit the abstract idea to a particular environment. The type of data being manipulated does not impose meaningful limitations. Looking at the elements as a combination does not add anything more than the elements analyzed individually. Therefore the claims do not amount to significantly more than the abstract idea itself. The claims are not patent eligible.
Applicant’s representative also argues that the claims as now amended recite patentable subject matter and cites Bascom Glov. Internet Servs., Inc. v. AT&T Mobility LLC 827 F.3d 1341, 1350 (Fed. Cir. 20216) and Core Wireless Licensing S.A.R.L. v. LG Electronics, Inc. in support of their assertion.
In response, the claims merely recite obtaining data using a generic computer or processor with a database having a plurality of modules as noted in the applicant’s specification.
These are generic types, and conventional computerized systems. Using a known or conventional computing device for processing data is not an inventive concept as was found in Alice at 134 S. Ct. at 2359 (emphasis added). The same principle is applied here. Similarly, the claimed calls for a "processing unit” having a reconciliation module for analyzing and comparing data or financial invoices" to produce a payment to a banking system.
The additional element of a generic processing unit with modules does not add a significant more than the abstract idea. As noted in the applicant’s specification, the generic processing unit can be any known server or computer processor or software or hardware components.
However, there is not a specific or new algorithm noted in the applicant’s specification to provide a result of providing payments to a banking system. The listed "computer” or “processor” and computing devices noted in the applicant's specification are routine computer processors or computers performing generic computer functions such as analyzing data, and comparing data to produce a result
Accordingly, the reliance of a computer to perform its routine tasks even more accurately is not sufficient to transform a claim into patent eligible subject matter as noted in Alice 134 S. Ct. at 2359. As indicated by the court "use of a computer to create electronic records, track multiple transactions and issue simultaneous instructions" was not an inventive concept. The claims or even the applicant's specification does not support or provide or claim any specifically inventive technology or algorithm for performing the claimed functions. See Bascom, 2016 WL 3514158, at 5,; cf. Alice, 134 S. Ct. at 2360 (noting basic storage function of generic computer).
Furthermore, in Core Wireless Licensing S.A.R.L. v. LG Electronics, Inc., the Courts held that claims to a method for making websites easier to navigate on a small-screen device were not directed to an abstract idea. 880 F.3d 1356, 1363 (Fed. Cir. 2018). Here, the claims are not drafted in the format CoreWireless. Rather than providing a technical solution that improves on the additional elements, the applicant is merely using ways to calculate an adjusted amount based on some rules when an inaccuracy in an invoice is detected, and transmits the adjusted amount to a client device to initiate a deposit of funds for the adjusted invoice amount.
The additional elements are when applied to the abstract idea do not provide sufficient details to transform the abstract idea into patent eligible subject matter. See, e.g. Alice, 134 S. Ct. at 2360 (explaining that claims that “amount to ‘nothing significantly more’ than an instruction to apply the abstract idea…using some unspecified, generic computer” is not ‘enough’ to transform an abstract idea into a patent-eligible invention” (quoting Mayo, 566, U.S. at 77, 79)); Intellectual Ventures LLC v. Capital One Fin.Corp., 850 F. 3d 1332, 1342 (Fed. Cir. 2017) (“The claim language here provides only a result-oriented-solution with insufficient detail for how a computer accomplishes it”).
Accordingly, the claims still fail to recite statutory subject matter.
The claims as amended still do not render the claims statutory under 35 USC 101.
A rejection of the claims as amended is found below.
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 1-17 and 20-22 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.
Subject Matter Eligibility Standard
When considering subject matter eligibility under 35 U.S.C. 101, it must be determined whether the claim is directed to one of the four statutory categories of invention, i.e., process, machine, manufacture, or composition of matter.
Specifically, claims 1, 13 and 20 are directed to a system. Each of the claims falls under one of the four statutory classes of invention.
If the claim does fall within one of the statutory categories, it must then be determined whether the claim is directed to a judicial exception (i.e., law of nature, natural phenomenon, and abstract idea).
The bolded items noted below are not part of the abstract idea.
Claim 1 recites:
a database comprising a plurality of invoices and rules;
a processing unit for consolidating the plurality of invoices from the one or more benefits vendors that are in at least two different formats, and wherein the processing unit standardizes each of a data element of the plurality of invoices to a common format comprising:
a reconciliation module for analyzing and comparing one or more invoices comprising insurance benefits information against insurance benefits information provided by one or more insurance benefits vendors to detect any inaccuracies in each invoice of the one or more invoices
for each invoice where an inaccuracy is detected, the processing unit being configured to:
calculate an adjusted invoice amount by excluding a fee associated with each inaccuracy, the calculation based on rules generated by past feedback signals received from a client device,
provide to the client device an exception report of all detected inaccuracies, the exception report including the fee associated with each inaccuracy,
in response to receiving a feedback signal from the client device to exclude a fee associated with an inaccuracy, alter the adjusted invoice amount to exclude the inaccuracy and generate a new rule based on the received feedback signal, and
transmit the adjusted invoice amount to the client device to initiate a deposit of funds for the adjusted invoice amount;
a rules engine, configured to compare insurance benefits recipients eligible for the adjusted invoice amount to past feedback signals received from the client device, and
a payment processing module that communicates with an external banking system having an account that received the deposit of funds, the payment processing module configured to send instructions to the external banking system to separate the deposit of funds into multiple payments and to transmit the multiple payments to one or more benefits vendors.
Claim 2 recites wherein said processing unit includes a trained neural network which analyzes past feedback signals from the client device relating to previous actions taken with respect to exceptions, the trained neural network instructing the processing unit to how to calculate the adjusted invoice amount for each invoice where an inaccuracy is detected.
Claim 3 recites wherein the processing unit generates an exception report of any inaccuracies in each invoice.
Claim 4 recites wherein is further configured to send notifications to the client device in response to detecting said exceptions based on the rules.
Claim 5 recites: wherein the processing unit further extracts discrete data elements from at least one of: the insurance benefits information, and plurality of invoices, and apply a tag to each data element.
Claim 6 recites: wherein the tag has a timestamp of when each discrete data element was imported into the system.
Claim 7 recites: wherein the tag has a unique identifier for tracking each discrete data element within the system.
Claim 8 recites: the database comprises one or more databases.
Claim 9 recites the plurality of rules are stored in a rules database which is accessible by the processing unit, and wherein the processing unit manages and updates the rules database.
Claim 10 recites wherein the rules engine communicates with the processing unit to identify a discrepancy in payment of one or more invoices, the processing unit being configured to rectify the identified discrepancy by adjusting an invoice to include an adjusted invoice amount based on the identified discrepancy.
Claim 11 recites: wherein the reconciliation module is configured to reconcile against multiple feeds of said benefits information.
Claim 12 recites wherein the processing unit tracks the invoices and is configured to merge at least a portion of the invoices into a bill, and incorporates the adjusted invoice amount into the bill.
Claim 13 recites: A system for consolidating and reconciling data, comprising:
a processing unit
for consolidating the plurality of invoices from the one or more benefits vendors that are in at least two different formats, and wherein the processing unit standardizes each of a data element of the plurality of invoices to a common format comprising:
a consolidation module for tracking and merging a plurality of statements into a consolidated statement,
a reconciliation module for receiving the consolidated statement and comparing the consolidated statement against benefits information of one or more benefits vendors to detect any inaccuracies in each invoice,
for each statement that has at least one exception inaccuracy, said the processing unit is configured to:
exclude a statement having at least one inaccuracy based on previous actions taken with respect to similar inaccuracies,
adjust the consolidated statement to exclude the statement having at least one inaccuracy,
provide to a client device an exception report of each statement, and in response to receiving a feedback signal from the client device to exclude at least one statement having at least one inaccuracy, determining whether to adjust the consolidated statement to exclude the statement; and
a payment processing module that facilitates disbursement of money from a deposit of funds made via the client device to recipients which provided the plurality of statements, based on the consolidated statement,
wherein the payment processing module communicates with an external banking system having an account that received the deposit of funds, the payment processing module sending one or more instructions to said the external banking system to separate the deposit of funds into multiple payments and to transmit the multiple payments to the recipients; and
a rules engine configured to confirm that insurance benefits recipients are eligible for the adjusted invoice amount as calculated by the processing unit; and
an administration module configured to update rules applied by the rules engine.
Claim 14 recites wherein the processing unit extracts data elements from each statement of the plurality of statements and applies a tag to at least some data elements.
Claim 15 recites: wherein the tag has a timestamp of when the each discrete data element was imported into the system.
Claim 16 recites wherein the tag has a timestamp of when the each discrete data element is interacted with, and a username of a person who interacted with the respective data element.
Claim 17 recites: wherein the plurality of statements are in a plurality of formats, and wherein an administration module standardizes each data element of the plurality of statements toa common format.
Claim 20 recites:
a processing unit for consolidating the plurality of invoices from the one or more benefits vendors that are in at least two different formats, and wherein the processing unit standardizes each of a data element of the plurality of invoices to a common format comprising:
a reconciliation module, configured to compare benefits information, received from a plurality of customer invoices concerning one or more benefits vendors to detect inaccuracies in each invoice;
for each invoice where there is an inaccuracy, the processing unit being configured to:
calculate an adjusted invoice amount by excluding at least one fee associated with each inaccuracy, the calculation using rules generated by past feedback signals received from a client device, the feedback signals being stored in a rules engine configured to compare insurance benefits recipients eligible for the adjusted invoice amount to past feedback signals received from the client device:
provide to the client device an exception report of an inaccuracy detected in at least one invoice, and in response to the feedback signal indicating exclude, determining whether the adjusted invoice amount excludes a fee associated with the invoice, altering the adjusted invoice amount to exclude the fee associated with the invoice and creating a new rule based on the feedback signal indicating exclude; and
a payment processing module, executed by the computer processor, the payment processing module configured to: send, upon receiving the adjusted invoice amount from the mobile client device, one or more instructions to an external banking system, having a deposit of customer funds, to separate the deposit of funds into multiple payments and to transmit the multiple payments to one or more benefits vendors.
Claim 21 recites wherein the reconciliation module a trained neural network which analyzes past feedback signals from the client device relating to previous actions taken with respect to exceptions, the trained neural network instructing the reconciliation module as to how to calculate the adjusted invoice amount for each invoice where an inaccuracy is detected.
Claim 22 recites wherein the reconciliation module generates an exception report of any inaccuracies in each invoice.
Applicant is to be noted that the steps or functions of “calculate” or “calculating” involve a mathematical function. The function of “receiving” involves a data gathering function. The functions of “analyzing”, “comparing” and “generating” involve mental/manual processes and/or generic computer functions. The claimed “send” or “sending”, “transmit” or “transmitting” functions involve an insignificant post solution activity.
Here, the claimed concept falls into the category of functions of organizing human activities such as managing commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations).
The BRI of the claimed limitations of claims 1 and 20 describe for each invoice where an inaccuracy is detected, performing functions to calculate an adjusted invoice, provide an exception of detected inaccuracies, alter an adjusted invoice amount, and send deposit of payments to benefits vendors.
The BRI of claim 13 recites for each settlement that has at least one inaccuracy, exclude a statement have at least one inaccuracy, adjust the consolidated statement, provide an exception report, and sending instructions to separate deposits to multiple payment recipients as recited in independent claim 13.
Step 2A, Prong Two: The judicial exception is not integrated into a practical application. In particular, the clams recite the above noted and bolded limitations as the additional elements.
These limitations performing steps of allowing a financial transaction by comparing data to detect inequalities merely amount to instructions to implement an abstract idea on a computer or merely using a computer as a tool to perform an abstract idea (see MPEP 2106.05(1) ). Also see applicant's specification for guiding interpretation of these claim features, describing implementation with generic commercially available devices or any machine capable of executing a set of instructions, similarly describing usage of general and special purpose computer and “any kind of digital computer” including generic commercially available devices. The processing unit, and the various modules and neural network and feedback signals are similarly understood in light of applicant's specification as mere usage of any arrangement of computer software or hardware intermediate components potentially using a processor in a network to communicate with a client device to communicate and/are properly understood to be mere instructions to apply the abstraction using a computer or device.
Performing steps by a generic machine or computer processor or a generic neural network absent of how the functions are being processed, merely limit the abstraction to a computer field by execution by generic computers. See MPEP 2106.05¢h).
As noted in MPEP 2106.04(d), limitations which amount to instructions to implement an abstract idea on a computer or merely using a computer as a tool, limitations which amount to insignificant extra-solution activity, and limitations which amount to generally linking to a particular technological environment do not integrate a practical exception into a practical application.
The claimed limitations of claim 1 also recite “determine whether to exclude an invoice which has at least one exception and….and to calculate and adjusted invoice amount….”.
The breadth of these limitations reasonably includes collecting information and comparing data to generate a statement based on the comparing result and transferring funds to multiple vendors.
Receiving and transmitting or sending data using an input port within a machine or processor is similar to Alappat, which as noted in MPEP 2106. 05(b)(1) is superseded, and the correct analysis is to look whether the added elements integrate the exception into a practical application or provide significantly more than the judicial exception. The claims in the instant application are performed by a processing unit including a processor which standardizes data, compares data and generates a statement from the comparing result.
Consideration of these steps as a combination does not change the analysis as they do not add anything compared to when the steps are considered separately. The claims recite a particular sequence of functions to compare data and perform an action such as generating a statement based on the comparison result. Performance of these steps or functions technologically may present a meaningful limit to the scope of the claim but does not reasonably integrate the abstraction into a practical application.
Processing of data and calculating data ,analyzing and comparing data. and calculating of data as recited in the claims also involve mental/manual processes with a minimum generic computer functions if necessary.
The transmitting of data involves insignificant post solution activity.
Step 2B: The elements discussed above with respect to the practical application in Step 2A, prong 2 are equally applicable to consideration of whether the claims amount to significantly more. Accordingly, the clams fail to recite additional elements which, when considered individually and in combination, amount to significantly more. Reconsideration of these elements identified as insignificant extra-solution activity as part of Step 2B does not change the analysis.
Receiving data by electronic means or hardware amounts to receiving and transmitting or sending information over a network has been recognized by the courts as well- understood, routine, and conventional (See MPEP 2106.05(d)(II), citing Symantec, 835 F.3d at 1321, 120 OSPQ2d at 1362 (Utilizing an intermediary computer to forward information); TL Communications LEC v. AV Auto. LLC, 823 F.3d 607, G10, L18 USPO2d 1744, 1748 (ed. Cir. 2016) Casing a telephone for image transmission); OFF Techs., fac. v. Amazon.com, fic., 788 B.Ad 1359, 1363, LiS USPO2d 1090, 1093 (ed, Cir. 2015) (sending messages over a network}, buySAFE, fic. v. Google, Inc.. 768 F.3d 1350, 1355, 112 USPQ2d 1093, 1996 (Pod, Cyr. 2014) (computer receives and sends information over a network).
Positively reciting a client device or processor or a trained neural network with feedback signals does not change the analysis as these aspects are properly considered as additional elements which amount to instructions to apply it with a computer.
These claimed elements also as found in the dependent claims are also recited at a high level of generality such that they amount to no more than mere instructions to apply the exception using a generic component.
In processing the claims, it is noted that the recitation of these additional elements does not impact the analysis of the claims because these elements in combination are noted only to be a general purpose computer for performing basic or routine computer functions. These additional elements do not overcome the analysis as these elements are merely considered as additional elements which amount to instructions to be applied to the generic computer.
The judicial exception is not integrated into a practical application. In particular, the claimed “processor”, “rules engine” ‘trained neural network”, “database” and “device” are recited at a high level of generality such they amount to no more than mere instructions to apply the exception using a generic component. Accordingly, the additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
Accordingly, claims 1, 13 and 18 are directed to an abstract idea.
The dependent claim(s) when analyzed and each taken as a whole are held to be patent ineligible under 35 U.S.C. 101 because the additional recited limitation(s) fail(s) to establish that the claim(s) is/are not directed to an abstract idea.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to FRANTZY POINVIL whose telephone number is (571)272-6797. The examiner can normally be reached M-Th 7:00AM to 5:30PM.
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/FRANTZY POINVIL/Primary Examiner, Art Unit 3693
April 1, 2026
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