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 .
DETAILED ACTION
This action is in response to the Request for Continued Examination (RCE) filed 1/12/2026. Applicant has amended claims 1-3, 6-7, 9, 11-13, 16 and 19 and cancelled claims 8 and 18. Accordingly, claims 1-7, 9-17 and 19-20 are pending for examination.
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 1-7, 9-17 and 19-20 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.
Claim 1 recites the abstract idea of “selecting and recommending account name based on transaction data and consolidating existing list of accounts”, which is grouped under “Certain Methods of Organizing Human Activity” such as “fundamental economic principles or practices” (managing financial information or transactions; mitigating risk), “commercial or legal interactions” (providing services to facilitate transactions; business relations). (MPEP 2016.04(a)). Specifically, claim 1 recites “receiving an incoming transaction data record associated with a transaction”, “the transaction data record comprising a plurality of fields indicating corresponding categories and a plurality of corresponding category of text values”, “… on the plurality of fields and the plurality of corresponding category of text values …. a recommended account name text value for the transaction and agnostic to an existing list of accounts”, “appending the recommended account name text value to the existing list of accounts”, “determining a hierarchical text relationship between the recommended account name text value and the existing list of accounts, the recommended account name text value being hierarchically below at least one account text value of the existing list of accounts”, “….an account name for the transaction from the existing list of accounts”, “using … to consolidate the existing list of accounts, wherein the consolidation comprises combining the recommended account name text value with another account name text value hierarchically below the at least one account of the existing list of accounts”, “displaying … a recommendation comprising a first account name text value hierarchically below a second account name text value based the selected account name, the existing list of accounts, and the hierarchical text relationship” and “updating a chart of accounts … with the consolidated existing list of accounts”. Accordingly, the claim recites an abstract idea.
This judicial exception is not integrated into a practical application because, when analyzed under prong two of step 2A (MPEP 2106.04II), the additional elements of claim 1 such as “using a first language model”, “using a second language model”, “using a third language model” and displaying “through a graphical user interface” represent the use of a computer as a tool to perform an abstract idea and/or does no more than generally link the abstract idea to a particular technological environment or field of use. Additionally, the claimed “first/second/third” language model” limitations described only the result (to generate/to select/to consolidate) but not how they are accomplished. Therefore, these functionalities are no more than “apply it” (MPEP 2106.05(f)(1)) and do not provide a practical application of “selecting and recommending account name”. Further, as the additional elements do not provide a practical application, they do not improve computer functionality and do not improve another technology or technical field.
When analyzed under step 2B (MPEP 2106.04II), because the additional elements do no more than represent the use of a computer as a tool to perform an abstract idea and/or does no more than generally link the abstract idea to a particular field of use, they do not provide an improvement to computer functionality, or an improvement to another technology or technical field and, therefore, do not amount to significantly more than the judicial exception itself (MPEP 2106.05(I)(A)(f)&(h)).
Hence, claim 1 is not patent eligible.
Claim 11 is also directed to the abstract idea of “selecting and recommending account name based on transaction data and consolidating existing list of accounts”, which is grouped under “Certain Methods of Organizing Human Activity” such as “fundamental economic principles or practices” (managing financial information or transactions; mitigating risk), “commercial or legal interactions” (providing services to facilitate transactions; business relations). (MPEP 2016.04(a)).
As in the case of claim 1, the exception is not integrated into a practical application. Claim 11 includes the additional elements such as ““a non-transitory storage medium storing computer program instructions”, “one or more processors configured to execute the computer program instructions to cause the system to perform operations”, “using a first language model”, “using a second language model”, “using a third language model”, and displaying “through a graphical user interface” represent the use of a computer as a tool to perform an abstract idea and/or does no more than generally link the abstract idea to a particular technological environment or field of use. Additionally, the claimed “first/second/third language model” limitations described only the result (to generate/to select/to consolidate) but not how they are accomplished. Therefore, these functionalities are no more than “apply it” (MPEP 2106.05(f)(1)) and do not provide a practical application of “selecting and recommending account name”. Further, as the additional elements do not provide a practical application, they do not improve computer functionality and do not improve another technology or technical field.
When analyzed under step 2B (MPEP 2106.04II), because the additional elements do no more than represent the use of a computer as a tool to perform an abstract idea and/or does no more than generally link the abstract idea to a particular field of use, they do not provide an improvement to computer functionality, or an improvement to another technology or technical field and, therefore, do not amount to significantly more than the judicial exception itself (MPEP 2106.05(I)(A)(f)&(h)).
Hence, claim 11 is not patent eligible.
Depending claims 2-10 and 12-20 further recite “…. the recommended account name text value for the transaction (claims 2 and 12)”, “…the recommended account name for the transaction (claims 3 and 13)”, “…select the account name for the transaction from the existing list of accounts (claims 4 and 14), “…select the account name for the transaction from the existing list of accounts (claims 5 and 15)”... the recommended account name text value for the transaction agnostic to the existing list of accounts (claims 6 and 16)”, “after appending the recommended account name text value to the existing list of accounts, ….to consolidate the existing list of accounts (claims 7 and 17), “….to the hierarchical relationship between the recommended account name text value and the existing list of accounts (claims 9 and 19)”, “prior to …, storing the incoming transaction data record in a chart of accounts …(claims 10 and 20)”, which is grouped under “Certain Methods of Organizing Human Activity” such as “fundamental economic principles or practices” (managing financial information or transactions; mitigating risk), “commercial or legal interactions” (providing services to facilitate transactions; business relations). (MPEP 2016.04(a)).
This judicial exception is not integrated into a practical application because, when analyzed under prong two of step 2A (MPEP 2106.04II), the additional elements of claims 2-7, 9-10, 12-17 and 19-20, such as “large language model” (claims 2, 4, 6, 12, 14 and 16), “machine learning model or deep learning model (claims 3, 5, 13, 15)”, “third language model (claims 7 and 17)”, “database (claims 10 and 20)”, “fourth language model (claims 9 and 19), “first language model (claims 10 and 20)” represent the use of a computer as a tool to perform an abstract idea and /or does no more than generally link the abstract idea to a particular field of use. Additionally, the claimed “using large language model/machine learning model/deep learning model/fourth language model/first language model” described only the result (to generate/to select/to consolidate) but not how they are accomplished. Therefore, these functionalities are no more than “apply it” (MPEP 2106.05(f)(1)) and do not provide a practical application of “selecting and recommending account name”. Further, as the additional elements do not provide a practical application, they do not improve computer functionality and do not improve another technology or technical field.
When analyzed under step 2B (MPEP 2106.04II), because the additional elements do no more than represent the use of a computer as a tool to perform an abstract idea and/or does no more than generally link the abstract idea to a particular field of use, they do not provide an improvement to computer functionality, or an improvement to another technology or technical field and, therefore, do not amount to significantly more than the judicial exception itself (MPEP 2106.05(I)(A)(f)&(h)).
Hence, depending claims 2-7, 9-10, 12-17 and 19-20 are not patent eligible.
Claims 1-7, 9-17 and 19-20 have been searched and reviewed. No prior art has been found that discloses, either expressly or inherently, all of the limitations of the claimed invention. Even though Pei (US 2022/0277399 A1) discloses determining hierarchical relationship between recommended account name and existing list of accounts and using language model to generate account name, see at least paragraphs 0093, 0095, 0036, 0005 and Fig 3, the rest of limitations recited in claims 1 and 11, considered as a whole including all limitations in the independent claims, is not taught by the prior arts found in examiner’s search. Therefore, no rejection under 102/103 is made.
Related But Not Relied Upon
Relevant art cited but not applied: Todd US 2012/0101882 A1, directed to multi-account payment consolidation system.
Response to Arguments
Applicant's arguments filed 1/12/2026 have been fully considered but they are not persuasive.
Applicant argues that the claims are statutory under 35 U.S.C. 101 because 1) the claims are not directed to “Certain Methods of Organizing Human Activity” because text processing is inherently computer-implemented 2) the specification discloses technical details of the improved computer application which is generally recited in claim 1. The Examiner disagrees. In response to applicant’s argument that the claims are not directed to abstract idea, it is noted that the claims are directed to “selecting and recommending account name based on transaction data and consolidating existing list of accounts”, which is grouped under “Certain Methods of Organizing Human Activity” such as “fundamental economic principles or practices” (managing financial information or transactions; mitigating risk), “commercial or legal interactions” (providing services to facilitate transactions; business relations). (MPEP 2016.04(a)). In response to applicant’s argument that the specification and claims are directed to improved computer application, it is noted that the additional elements of claim 1 such as “using a first language model”, “using a second language model”, “using a third language model” and displaying “through a graphical user interface” represent the use of a computer as a tool to perform an abstract idea and/or does no more than generally link the abstract idea to a particular technological environment or field of use. Review of the specification does not indicate that specialized computer hardware is necessary to implement the claimed method/system. According to paragraph 0049 of the Specification, suitable processors for the execution of a program of instructions may be general microprocessors or any kind of computer. Additionally, the claimed “first/second/third” language model” limitations described only the result (to generate/to select/to consolidate) but not how they are accomplished. Therefore, these functionalities are no more than “apply it” (MPEP 2106.05(f)(1)) and do not provide a practical application of “selecting and recommending account name”. Further, as the additional elements do not provide a practical application, they do not improve computer functionality and do not improve another technology or technical field. Therefore, applicant’s arguments are not persuasive.
Conclusion
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/CHIA-YI LIU/Primary Examiner, Art Unit 3692