DETAILED ACTION
Notice of Pre-AIA or AIA Status
1. 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
2. The Amendment filed on March 12, 2026 has been entered. Claims 1, 11, and 20 have been amended. No claims have been cancelled. No new claims have been added. Thus, claims 1-20 are pending and rejected for the reasons set forth below.
Claim Rejections - 35 USC § 101
3. 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.
4. 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.
In sum, claims 1-20 are rejected under 35 U.S.C. §101 because the claimed invention is directed to a judicial exception to patentability (i.e., a law of nature, a natural phenomenon, or an abstract idea) and do not include an inventive concept that is something “significantly more” than the judicial exception under the January 2019 patentable subject matter eligibility guidance (2019 PEG) analysis which follows.
Under the 2019 PEG step 1 analysis, it must first be determined whether the claims are directed to one of the four statutory categories of invention (i.e., process, machine, manufacture, or composition of matter). Applying step 1 of the analysis for patentable subject matter to the claims, it is determined that the claims are directed to the statutory category of a process (claims 11-19), a machine (claims 1-10), and a manufacture (claim 20). Therefore, we proceed to step 2A, Prong 1.
Under the 2019 PEG step 2A, Prong 1 analysis, it must be determined whether the claims recite an abstract idea that falls within one or more designated categories of patent ineligible subject matter (i.e., organizing human activity, mathematical concepts, and mental processes) that amount to a judicial exception to patentability. Here, the claims recite the abstract idea of receiving transfer identification to identify a code to carry out a transfer of funds by;
configure a unique identifier to be associated with at least a first data record tracking a first resource type and a second data record tracking a second resource type;
receive, via the communications module, a first computer-readable message that includes the unique identifier and a request to transfer a first amount of resources;
analyze the first computer-readable message to identify a code indicating the first resource type; and
responsive to the code indicating the first resource type, bypass a default-resource conversion operation and update the first data record to include the first amount of the first resources transferred.
Here, the recited abstract idea falls within one or more of the three enumerated 2019 PEG categories of patent ineligible subject matter, to wit: certain methods of organizing human activity, which includes fundamental economic practices or principles as well as commercial or legal interactions (e.g., receiving transfer identification to identify a code to carry out a transfer of funds).
Under the 2019 PEG step 2A, Prong 2 analysis, the identified abstract idea to which the claim is directed does not include limitations that integrate the abstract idea into a practical application, since the recited features of the abstract idea are being applied on a computer or computing device or via software programming that is simply being used as a tool (“apply it”) to implement the abstract idea. (See, e.g., MPEP §2106.05(f)). Therefore, the claim is directed to an abstract idea.
Under the 2019 PEG step 2B analysis, the additional elements are evaluated to determine whether they amount to something “significantly more” than the recited abstract idea. (i.e., an innovative concept). Here, the additional elements, such as: a “module,” “processor,” and “memory” do not amount to an innovative concept since, as stated above in the step 2A, Prong 2 analysis, the claims are simply using the additional elements as a tool to carry out the abstract idea (i.e., “apply it”) on a computer or computing device and/or via software programming. (See, e.g., MPEP §2106.05(f)). The additional elements are specified at a high level of generality to simply implement the abstract idea and are not themselves being technologically improved. (See, e.g., MPEP §2106.05 I.A.); (see also, paragraphs [0013] of the specification). Claims 11 and 20 are nearly identical to claim 1 so the same analysis applies to those claims as well.
Dependent claims 2–10 and 12–19 have been considered and do not integrate the abstract idea into a practical application. Dependent claims 2 and 12 recite nearly identical limitations that further define the abstract idea noted in claim 1 in that they describe that analyzing the message to identify a code indicating another resource type. Dependent claims 3 and 13 recite nearly identical limitations that further define the abstract idea noted in claim 1 in that they describe converting the third amount of resources to a fourth type. Dependent claims 4 and 14 recite nearly identical limitations that further define the abstract idea noted in claim 1 in that they describe configuring the unique identifier. Dependent claims 5 and 15 recite nearly identical limitations that further define the abstract idea noted in claim 1 in that they describe determining that the request satisfies criteria. Dependent claims 6 and 16 recite nearly identical limitations that further define the abstract idea noted in claim 1 in that they describe that a third data record is required. Dependent claims 7 and 17 recite nearly identical limitations that further define the abstract idea noted in claim 1 in that they describe that the unique identifier is associated with a same user as the third data record and the fourth data record. Dependent claims 8 and 18 recite nearly identical limitations that further define the abstract idea noted in claim 1 in that they describe that the unique identifier includes a primary account number. Dependent claims 9 and 19 recite nearly identical limitations that further define the abstract idea noted in claim 1 in that they describe determining a trigger condition and generating a statement.
The additional elements of the dependent claims merely refine and further limit the abstract idea of the independent claims and do not add any feature that is an “inventive concept” which cures the deficiencies of their respective parent claim under the 2019 PEG analysis. None of the dependent claims considered individually, including their respective limitations, include an “inventive concept” of some additional element or combination of elements sufficient to ensure that the claims in practice amount to something “significantly more” than patent-ineligible subject matter to which the claims are directed.
The elements of the instant process steps when taken in combination do not offer substantially more than the sum of the functions of the elements when each is taken alone. The claims as a whole, do not amount to significantly more than the abstract idea itself because the claims do not effect an improvement to another technology or technical field (e.g., the field of computer coding technology is not being improved); the claims do not amount to an improvement to the functioning of an electronic device itself which implements the abstract idea (e.g., the general purpose computer and/or the computer system which implements the process are not made more efficient or technologically improved); the claims do not perform a transformation or reduction of a particular article to a different state or thing (i.e., the claims do not use the abstract idea in the claimed process to bring about a physical change. See, e.g., Diamond v. Diehr, 450 U.S. 175 (1981), where a physical change, and thus patentability, was imparted by the claimed process; contrast, Parker v. Flook, 437 U.S. 584 (1978), where a physical change, and thus patentability, was not imparted by the claimed process); and the claims do not move beyond a general link of the use of the abstract idea to a particular technological environment (e.g., simply claiming the use of a computer and/or computer system to implement the abstract idea).
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Response to Arguments
5. Applicant’s arguments filed on March 12, 2026 have been fully considered.
As a result of Applicant’s amendments and its arguments, the pending rejection of the claims under 35 U.S.C. 102(a)(2) is hereby withdrawn. Yang’s system does not inspect an identifier to determine a resource type since all resources disclosed are monetary funds of the same currency, i.e., same resource type. It also does not transfer amounts to multiple resource types.
Applicant’s arguments concerning the 35 U.S.C. §101 rejection of the claims, including supposed deficiencies in the rejection, are not persuasive. Applicant argues that “The pending claims are not directed to a fundamental economic practice or a commercial or legal interaction.” (See Applicant’s Arguments, p. 8). However, the heart of this invention is tied to performing a transfer a certain amount of resources. The recited abstract idea falls within one or more of the three enumerated 2019 PEG categories of patent ineligible subject matter, to wit: certain methods of organizing human activity, which includes fundamental economic practices or principles as well as commercial or legal interactions (e.g., receiving transfer identification to identify a code to carry out a transfer of funds). These claims most definitely recite an abstract idea.
Applicant next argues that “Accordingly, even if the claims were viewed at a high level as implicating a judicial exception, the claimed subject matter integrates that alleged abstract idea into a practical application that improves the functioning of the transaction-processing computer itself.” (See Applicant’s Arguments, p. 13). There are no interactive elements within this invention. Instead, the system in place is using generic components to carry out the functions in the backend. There is no user involvement here. Applicant finally argues that “Therefore, the claims, both individually and in their ordered combination, amount to ‘significantly more’ than any alleged abstract idea and are eligible at Step 2B.” (See Applicant’s Arguments, p. 15). Here, the additional elements, such as: a “module,” “processor,” and “memory” do not amount to an innovative concept since, as stated above in the step 2A, Prong 2 analysis, the claims are simply using the additional elements as a tool to carry out the abstract idea (i.e., “apply it”) on a computer or computing device and/or via software programming. (See, e.g., MPEP §2106.05(f)). The additional elements are specified at a high level of generality to simply implement the abstract idea and are not themselves being technologically improved. (See, e.g., MPEP §2106.05 I.A.); (see also, paragraphs [0013] of the specification). Maintaining separate data records for different resource types, receiving a transaction message with a resource-type code, conditionally bypassing a default-resource conversion (normalization) operation, and updating the corresponding resource-specific record is not a technological improvement.
Therefore, the rejection under 35 U.S.C. §101 is maintained.
Conclusion
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 extension fee 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 date of this final action.
Any inquiry concerning this communication or earlier communications from the Examiner should be directed to Amit Patel whose telephone number is (313) 446-4902. The Examiner can normally be reached Mon - Thu 8 AM - 6 PM EST. If attempts to reach the Examiner by telephone are unsuccessful, the Examiner’s supervisor, Matthew Gart, can be reached at (571) 272-3955. The Examiner’s fax number is (571) 273-6087. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/Amit Patel/
Examiner
Art Unit 3696
/EDWARD CHANG/Primary Examiner, Art Unit 3696
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