DETAILED ACTION
1. The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . This Office action is in response to Applicant’s communication filed on October 6, 2025. Amendments to claims 1, 2, 6, 11, 12, 16 and 20 have been entered. The statement of reasons for the indication of allowable subject matter over prior art was already discussed in the Office action mailed on May 5, 2025 and hence not repeated here. Claims 1-18, 20 and 21 are pending and have been examined. The rejections and response to arguments are stated below.
Claim Rejections - 35 USC § 101
2. 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.
3. Claims 1-18, 20 and 21 are rejected under 35 U.S.C. § 101 because the claimed invention is directed to an abstract idea without significantly more.
The claim(s) recite(s) a method/system of calculating a sum of one or more transfer amounts associated with one or more in-application transfers during a time period, the one or more in-application transfers being associated with the first account and including the first transfer, the one or more in-application transfers being associated with one or more applications of the first type; determining, based on a threshold defined for the time period, that the sum satisfies defined criteria; and in response to determining that the sum satisfies the defined criteria, transmitting an instruction configured to cause a generation of a second notification on a second user computing device, the second notification indicating that the defined criteria have been satisfied, which is considered a judicial exception because it falls under the category of “Certain Methods of organizing human activity” such as fundamental economic practice as well as commercial or legal interactions including agreements as discussed below. This judicial exception is not integrated into a practical application as discussed below. The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception as discussed below.
Analysis
Step 1: In the instant case, exemplary claim 1 is directed to a system.
Step 2A – Prong One: The limitations of “A computer system comprising:
a processor;
a communications module coupled to the processor; and
a memory coupled to the processor and storing instructions that, when executed by the processor, cause the computer system to:
receive, from a first user computing device, a transfer request for a first transfer comprising a first device token identifying a first application on the first user computer device; determine, based on a first transfer identifier associated with the first transfer having a first transfer amount, that the first transfer represents a first in-application transfer associated with the first application having a first type, the first transfer being associated with a first account and initiated at the first user computing device;
calculate a sum of one or more transfer amounts associated with one or more in-application transfers during a time period, the one or more in-application transfers being associated with the first account and including the first transfer, the one or more in-application transfers being associated with one or more applications of the first type;
determine, based on a threshold defined for the time period, that the sum satisfies defined criteria;
identify, based on device token records, a second device token associated with the first account and identifying a second user computing device and a second application; and
in response to determining that the sum satisfies the defined criteria, transmit, using the second device token, an instruction configured to cause a generation of a second notification on the second user computing device, the second notification indicating that the defined criteria have been satisfied” as drafted, when considered collectively as an ordered combination without the italicized portions, is a process that, under the broadest reasonable interpretation, covers the category of “Certain Methods of organizing human activity” such as fundamental economic practice as well as commercial or legal interactions including agreements.
Transmitting an instruction configured to cause a generation of a second notification on the second user computing device, the second notification indicating that the defined criteria have been satisfied. is fundamental economic practice such as mitigating risk. The steps of “determining, based on a threshold defined for the time period, that the sum satisfies defined criteria; identifying, based on device token records, a second device token associated with the first account and identifying a second user computing device and a second application; and in response to determining that the sum satisfies the defined criteria, transmitting, using the second device token, an instruction configured to cause a generation of a second notification on the second user computing device, the second notification indicating that the defined criteria have been satisfied” considered collectively is a form fulfilling agreements between the parties involved. Hence, the steps of the claim, considered collectively as an ordered combination without the italicized portions, covers the abstract category of “Certain Methods of organizing human activity”.
That is, other than, a computer system comprising a processor; a communications module coupled to the processor, a memory coupled to the processor, a first device token and a second device token, a first application and a second application, a first user computing device and a second user computing device, nothing in the claim precludes the steps from being performed as a method of organizing human activity. If the claim limitations, under the broadest reasonable interpretation, covers methods of organizing human activity but for the recitation of generic computer components, then it falls within the “Certain methods of organizing human activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
Step 2A – Prong Two: The judicial exception is not integrated into a practical application. In particular, the claim only recites the additional elements of a computer system comprising a processor, a communications module, a memory, a first device token and a second device token, a first application and a second application, a first user computing device and a second user computing device to perform all the steps. A plain reading of Figures 1-3, and 6-8 and associated descriptions in at least paragraphs [0039] – [0090], and [0124] reveal that a computer system comprising generic processor suitably programmed may be used to execute the claimed steps. The communications module and the memory are generic computer components suitably programmed to perform the associated functions. The first device token and the second device token are broadly interpreted to correspond to generic computer components suitably programmed to perform the associated functions. The first and second applications are broadly interpreted to correspond to generic software suitably programmed to perform the associated functions. The two user computing devices are broadly interpreted to correspond to generic computing devices suitably programmed to perform the associated functions. Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. The additional elements in all the steps are recited at a high-level of generality (i.e., as generic computer components performing generic computer functions) such that it amounts no more than mere instructions to apply the exception using generic computer components. Accordingly, these 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. Hence, claim 1 is directed to an abstract idea.
Step 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, using the additional elements (identified above) to perform the claimed steps amounts to no more than mere instructions to apply the exception using a generic computer component. The additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Hence, independent claim 1 is not patent eligible. Independent claims 11 and 20 are also not patent eligible based on similar reasoning and rationale.
Dependent claims 2-10, 12-18 and 21, when analyzed as a whole are held to be patent ineligible under 35 U.S.C. 101 because the additional recited limitations only refine the abstract idea further.
For instance, in claims 2 and 12, the steps “wherein the instructions further cause the computer system to:
establish, via the communications module and through a first application programming interface (API) associated with the first user computing device, a communications connection with the first user computing device; and
transmit, via the communications module, an instruction configured to cause a generation, by the first user computing device, of a first notification” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the intermediate steps of the underlying process.
In claims 3 and 13, the steps “wherein the instructions further cause the computer system to:
restrict, for a remainder of the time period, approval of subsequent transfer requests in connection with an in-application transfer associated with an application of the first type, wherein the subsequent transfer requests are associated with the first account” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the intermediate steps of the underlying process.
In claims 4 and 14, the steps “wherein the one or more in-application transfers are further associated with a first transfer card associated with the first account” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the one or more in-application transfers in the intermediate steps of the underlying process.
In claims 5 and 15, the steps “wherein prior to calculating the sum, the computer system is further caused to:
determine, based on a second transfer identifier associated with a second transfer having a second transfer amount, that the second transfer represents a second in-application transfer in connection with a second application of the first type, the second transfer being associated with the first account, wherein the one or more transfer amounts further include the second transfer amount” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the intermediate steps of the underlying process.
In claims 6 and 16, the steps “wherein the instructions further cause the computer system to:
establish, via the communications module and through a first API associated with the first user computing device, a communications connection with the first user computing device;
transmit, via the communications module, an instruction configured to cause a generation, by the first user computing device, of a first notification;
establish, via the communications module and through a second API associated with the second user computing device, a communications connection with the second user computing device.” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the intermediate steps of the underlying process.
In claims 7 and 17, the steps “wherein prior to transmitting the instruction, the computer system is further caused to:
determine that a third transfer represents a third in-application transfer associated with a third application of the first type, the third transfer being associated with the first account and occurring outside of the time period, and
wherein the instructions further cause the computer system to:
identify a third user computing device associated with the third application;
establish, via the communications module and through a third API associated with the third user computing device, a communications connection with the third user computing device; and
transmit, via the communications module, an instruction configured to cause a generation, by the third user computing device, of a third notification” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the in-application transfers and the intermediate steps of the underlying process. The additional elements (in the claims) of a third user computing device associated with the third application and a third API associated with the third user computing device, are broadly interpreted to correspond to generic computer components suitably programmed to perform the associated functions. These additional elements, perform their traditional functions recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using generic computer components.
In claims 8 and 18, the step “wherein the instructions further cause the computer system to:
provide user interface data to a fourth user computing device associated with the first account, the user interface data causing the fourth user computing device to display a user interface including a fourth notification” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the intermediate steps of the underlying process. The additional elements (in the claims) of a fourth user computing device with a user interface is broadly interpreted to correspond to generic computer components suitably programmed to perform the associated functions. These additional elements, perform their traditional functions recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using generic computer components.
In claim 9, the steps “wherein the first transfer is associated with a first transfer card associated with the first account, and wherein the second transfer is associated with a second transfer card associated with the first account” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the first transfer and second transfer in the intermediate steps of the underlying process.
In claim 10, the step “wherein the threshold is a defined amount and wherein the defined criteria are satisfied when the calculated sum exceeds a certain percentage of the defined amount” under the broadest reasonable interpretation, is a further refinement of methods of organizing human activity because this step describe the threshold and criteria used in the intermediate steps of the underlying process.
In claim 21 the steps “wherein the instructions further cause the computer system to:
retrieve one or more device token associated with the first user computing device and the second user computing device authorized for the first account; and
establish, via the communications module and through one or more APIs corresponding to the retrieved one or more device token, communications connections with the first user computing device and the second user computing device” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the intermediate steps of the underlying process. The additional elements of one or more device token associated with the first user computing device and the second user computing device are broadly interpreted to correspond to generic computer components suitably programmed to perform the associated functions. These additional elements, perform their traditional functions recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using generic computer components.
In all the dependent claims, the judicial exception is not integrated into a practical application because the limitations are recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using generic computer components. Also, the claims do not affect an improvement to another technology or technical field; the claims do not amount to an improvement to the functioning of a computer system itself; the claims do not affect a transformation or reduction of a particular article to a different state or thing; and the claims do not move beyond a general link of the use of an abstract idea to a particular technological environment. In addition, the dependent claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. The additional elements of the instant underlying process, when taken in combination, together 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. For these reasons, the dependent claims also are not patent eligible.
Response to Arguments
4. In response to Applicants arguments on pages 9-12 of the Applicant’s remarks that the claims are patent-eligible under 35 USC 101 when considered under MPEP 2106, the Examiner respectfully disagrees.
The fact that the claims are Patent-Ineligible when considered under the MPEP 2106 has already been addressed in the rejection and hence not all the details of the rejection are repeated here.
Response to Applicants’ arguments regarding Step 2A – Prong one:
The claims recite a method/system of calculating a sum of one or more transfer amounts associated with one or more in-application transfers during a time period, the one or more in-application transfers being associated with the first account and including the first transfer, the one or more in-application transfers being associated with one or more applications of the first type; determining, based on a threshold defined for the time period, that the sum satisfies defined criteria; identifying, based on device token records, a second device token associated with the first account and identifying a second user computing device and a second application; and in response to determining that the sum satisfies the defined criteria, transmitting an instruction configured to cause a generation of a second notification on a second user computing device, the second notification indicating that the defined criteria have been satisfied, which is considered a judicial exception because it falls under the category of “Certain Methods of organizing human activity” such as fundamental economic practice as well as commercial or legal interactions including agreements as discussed in the rejection. The additional elements in the claims such as “device-specific tokens, transfer identifiers, and defined criteria to evaluate cumulative transfer activity and to trigger a notification on another device linked to the same account ….. distributed computing behavior involving cross-device communication” are used as tools in their normal capacity to apply the abstract idea. The alleged advantages such as “trigger a notification on another device linked to the same account when that activity meets or exceeds a threshold …. threshold-based evaluation of transfer data, and real-time notification generation …. causing generation of a notification on a different device, improving both coordination and responsiveness …. enabling synchronized awareness across the multiple devices and using device tokens to associate otherwise independent transfers” are due to improvements in the abstract idea using the additional elements as tools as tools in their normal capacity to apply the abstract idea. Hence, the claims recite an abstract idea.
Response to Applicants’ arguments regarding Step 2A – Prong two:
According to MPEP 2106, limitations that are indicative of integration into a practical application include:
Improvements to the functioning of a computer, or to any other technology or technical field - see MPEP 2106.05(a)
Applying or using a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition
Applying the judicial exception with, or by use of, a particular machine - see MPEP 2106.05(b)
Effecting a transformation or reduction of a particular article to a different state or thing - see MPEP 2106.05(c)
Applying or using the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception - see MPEP 2106.05(e).
In the instant case, the judicial exception is not integrated into a practical application, because none of the above criteria is met. The claim (exemplary claim 1) only recites the additional elements of a computer system comprising a processor, a communications module, a memory, a first device token and a second device token, a first application and a second application, a first user computing device and a second user computing device to perform all the steps. A plain reading of Figures 1-3, and 6-8 and associated descriptions in at least paragraphs [0039] – [0090], and [0124] reveal that a computer system comprising generic processor suitably programmed may be used to execute the claimed steps. The communications module and the memory are generic computer components suitably programmed to perform the associated functions. The first device token and the second device token are broadly interpreted to correspond to generic computer components suitably programmed to perform the associated functions. The first and second applications are broadly interpreted to correspond to generic software suitably programmed to perform the associated functions. The two user computing devices are broadly interpreted to correspond to generic computing devices suitably programmed to perform the associated functions. Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. The additional elements in all the steps are recited at a high-level of generality (i.e., as generic computer components performing generic computer functions) such that it amounts no more than mere instructions to apply the exception using generic computer components. Accordingly, these 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. Hence, the claims are directed to an abstract idea.
The claimed features including those recited on page 11 of the remarks such as “using device tokens as active routing mechanisms to enable precise, targeted communication between the system and specific devices ….. using the token to send actionable instructions that cause the identified device to display a user notification under defined conditions …. rule-based communication framework that enables context-aware, cross-device interaction ….. performing coordinated monitoring of in-application transfers across multiple devices and multiple applications of a defined type, all associated with a single user account ….. aggregating transfer activity over a defined time period, applying threshold logic to the calculated sum, and, if certain criteria are satisfied, causing a targeted notification to be generated on a second device associated with the account” may at best be considered an improvement in the abstract idea of a method/system of calculating a sum of one or more transfer amounts associated with one or more in-application transfers during a time period, and determining, based on a threshold defined for the time period, that the sum satisfies defined criteria, using the additional elements as tools in their ordinary capacity. The alleged advantages such as “enabling cross-device coordination for transfer activity, …. providing a more efficient and responsive computing environment by enhancing how applications, devices, and user accounts interact and communicating with each other in a controlled, automated, and technically coordinated manner ….. enhancing the efficiency and effectiveness of in-application transaction monitoring and control …. intelligently recognizing that multiple computing devices running different applications can be linked through a common user account, enabling it to trigger a notification on one device in response to a transfer request made on another - thereby ensuring consistent and timely user awareness across platform …. ensuring that relevant users, not just the account owner, are alerted when limits are approached or exceeded” are due to improvements in the abstract idea. An improvement in abstract idea is still abstract (SAP America v. Investpic *2-3 (“We may assume that the techniques claimed are “groundbreaking, innovative, or even brilliant,” but that is not enough for eligibility. Association for Molecular Pathology v. Myriad Genetics, Inc., 569 U.S. 576, 591 (2013); accord buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1352 (Fed. Cir. 2014). Nor is it enough for subject-matter eligibility that claimed techniques be novel and nonobvious in light of prior art, passing muster under 35 U.S.C. §§ 102 and 103. See Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66, 89–90 (2012); Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 1151 (Fed. Cir. 2016) (“A claim for a new abstract idea is still an abstract idea). The additional elements (identified in the rejection) are generic computer components used to apply the abstract idea. It does not involve any improvements to another technology, technical field, or improvements to the functioning of the computer itself. Therefore, the claims are directed to an abstract idea.
Response to Applicants’ arguments regarding Step 2B:
As discussed in the rejection, the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, using the additional elements (identified in the rejection) to perform the claimed steps, amount to no more than mere instructions to apply the exception using a generic computer component. The additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept.
The claimed features including those recited on page 12 of the remarks such as “enabling monitoring and enforcement of in-application transfer activity across multiple devices and applications associated with a shared account ….. classifying transfer types, calculating cumulative transfer amounts over a defined time period, and using device tokens to identify other associated devices and transmitting targeted instructions to generate notification ….. enforcing transfer thresholds across multiple platforms in real-time, without requiring manual oversight. By leveraging device tokens and transfer identifiers, the system improving how transfer activity is tracked, how user context is preserved across devices, and how responsive feedback is delivered” may at best be considered an improvement in the abstract idea of a method/system of calculating a sum of one or more transfer amounts associated with one or more in-application transfers during a time period, the one or more in-application transfers being associated with the first account and including the first transfer, the one or more in-application transfers being associated with one or more applications of the first type; determining, based on a threshold defined for the time period, that the sum satisfies defined criteria; and in response to determining that the sum satisfies the defined criteria, transmitting an instruction configured to cause a generation of a second notification on a second user computing device, the second notification indicating that the defined criteria have been satisfied, using the additional elements as tools in their ordinary capacity. The Applicant’s claims do not recite sufficient subject matter to take them from being in the realm of what is encompassed as an abstract idea into patentable subject matter and fail to add significantly more to “transform” the nature of the claims. Hence, the claims are not patent eligible.
The Examiner does not see the parallel between the Applicant’s claims and those in BASCOM. Therefore, the Applicant’s arguments are not persuasive.
For these reasons and those discussed in the rejection, the rejections under 35 USC § 101 are maintained.
Conclusion
5. The prior art made of record and not relied upon is considered pertinent to applicant's disclosure:
(a) Dieter; Steven et al. (US Pub. 2024/0220961 A1) discloses a method wherein hands-free transaction is processed by utilizing an account management system to authorize a transaction and to provide payment account information to a payment processing system while allowing the transaction settlement to occur between the payment processing system and the merchant. After the account of the user is verified, a POS device generates a payment authorization request based on a user verification and other transaction information. The POS device transmits the payment authorization request to the account management system, and the account management system identifies the user payment data. The account management system receives an authorization from the payment processing system and transmits the payment authorization to the merchant. The merchant salesperson completes the transaction with the user by providing the product or service being purchased. The payment processing system and the merchant system then settle the transaction without involvement of account management system.
6. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice.
Any inquiry concerning this communication or earlier communications from the Examiner should be directed to Narayanswamy Subramanian whose telephone number is (571) 272-6751. The examiner can normally be reached Monday-Friday from 9:00 AM to 5:00 PM. If attempts to reach the examiner by telephone are unsuccessful, the examiner's supervisor, Abhishek Vyas can be reached at (571) 270-1836. The fax number for Formal or Official faxes and Draft to the Patent Office is (571) 273-8300.
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/Narayanswamy Subramanian/
Primary Examiner
Art Unit 3691
October 26, 2025