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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 3/17/2026 has been entered.
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 1-6, 8-13, 15-19 and 21-23 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (abstract idea) without significantly more.
Analysis
Claim 8: Ineligible.
STEP 1:
The claim recites a series of acts. The claim is directed to a process, which is a statutory category of invention (Step 1: YES).
STEP 2A (PRONG 1):
The claim is analyzed to determine whether it is directed to a judicial exception. The claim recites the steps of:
receiving, by at least one computing device of a provider, a selection of images and data fields of a company associated with an invoicer;
{generating, by the at least one computing device, an invoice payment detail web page that is customized for the invoice using the selection of images and data fields, wherein the invoice payment detail web page targets the invoicee by presenting company information associated with the invoice and the invoicer and access to at least the invoice;
generate an invoice directed to an invoicee from the invoicer, the invoice comprising at least a uniform resource locator (URL) link to the invoice payment detail web page;}
sending, by the at least one computing device the invoice to an invoicee device of the invoicee; receiving, by the at least one computing device, from the invoicee device, an invoice payment detail response through the invoice payment detail web page, the invoice payment detail response comprising at least an invoice payment amount for the invoice and a selected one of a plurality of credit line payment options; and
initiating, by the at least one computing device, a payment from a provider account to an invoicer account, the provider account being held by the provider and the invoicer account being held by the invoicer.
Examiner submits that the foregoing bolded limitation(s) constitute fundamental economic practice and/or commercial interactions between parties. In order words the bolded limitations describe generating and managing invoices and payments between and invoicee and invoicer. Therefore, the bolded claim limitations fall under the abstract idea category of “certain methods of organizing human activity” group in the form of fundamental economic practice and/or commercial interactions of sales activities or behavior. (Step 2A1-Yes). See MPEP 2106.04(a)-(c)
STEP 2A (PRONG 2):
Next, the claim is analyzed to determine if it is integrated into a practical application. The claim recites additional elements of invoicee and invoicer devices, and at least one computing device (processors). The processors in the steps are recited at a high level of generality, i.e., as generic processors performing generic computer functions. These generic processor limitations are no more than mere instructions to apply the exception using generic computer components. (see MPEP 2106.05(f)).
Furthermore, the additional elements of “generating, by the at least one computing device, an invoice payment detail web page that is customized for the invoice using the selection of images and data fields, wherein the invoice payment detail web page targets the invoicee by presenting company information associated with the invoice and the invoicer and access to at least the invoice; generate an invoice directed to an invoicee from the invoicer, the invoice comprising at least a uniform resource locator (URL) link to the invoice payment detail web page” are insignificant extra-solution activities (see MPEP 2106.05(g)).
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. The claim is directed to the abstract idea (Step 2A2-No). See MPEP 2106.04(II)(A)(2) and MPEP 2106.04(d)(2)
STEP 2B:
Next, the claim is analyzed to determine if there are additional claim limitations that individually, or as an ordered combination, ensure that the claim amounts to significantly more than the abstract ideas (whether claim provides inventive concept). As discussed with respect to Step 2A2 above, the additional element in the claim amount to no more than mere instructions to apply the exception using a generic computer component. The same analysis applies here in Step 2B, i.e., mere instructions to apply an exception using a generic computer component cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. Because the steps “generating, by the at least one computing device, an invoice payment detail web page that is customized for the invoice using the selection of images and data fields, wherein the invoice payment detail web page targets the invoicee by presenting company information associated with the invoice and the invoicer and access to at least the invoice; generate an invoice directed to an invoicee from the invoicer, the invoice comprising at least a uniform resource locator (URL) link to the invoice payment detail web page”, were considered to be extra-solution activities in Step 2A, they are re-evaluated in Step 2B to determine if they are more than what is well-understood, routine and conventional in the field. The disclosure does not provide any indication that these steps are anything other than conventional steps, and Siegel (USPAP 2011/0276365) at paragraph [0027]; Koike et al (USPN 7,194,678) at abstract and Col. 3, lines 12-61; indicate that the steps of generating a customized web page and URL link to the web page are well-understood, routine and conventional in the field (as they are here). Accordingly, a conclusion that these steps are well-understood, routine and conventional activities is supported under Berkheimer option 3. See MPEP 2106.05(d)).
Viewing the limitations as an ordered combination does not add anything further than looking at the limitations individually. When viewed either individually, or as an ordered combination, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea itself. Therefore, the claim does not amount to significantly more than the recited abstract idea (Step 2B: NO). The claim is not patent eligible. See MPEP 2106.05
Claims 2, 9 and 16 recite generating the URL link, the URL link being unique to the invoice.
This limitation further narrows the abstract idea, but is nonetheless part of the abstract idea identified in claim 8. The additional elements, as similarly analyzed in claim 8 above, do not integrate the abstract idea into a practical application. The claimed invention as a whole also does not amount to significantly more than the abstract idea. The claim is similarly rejected under the same rationale as claim 8, supra.
Claims 3, 10 and 17 recite generating the URL link, the URL link being unique to the invoicee associated with the invoicee device.
This limitation further narrows the abstract idea, but is nonetheless part of the abstract idea identified in claim 8. The additional elements, as similarly analyzed in claim 8 above, do not integrate the abstract idea into a practical application. The claimed invention as a whole also does not amount to significantly more than the abstract idea. The claim is similarly rejected under the same rationale as claim 8, supra.
Claims 4, 11 and 18 recite receiving, by the at least one computing device, a request from the invoicee device, the request being directed to the URL link; determining, in response to receiving the request [from the invoicee device], that the invoicee does not have an account; receiving an account creation request, the account creation request includes at least at least bank account information of an invoicee and an identity of the invoicee; and creating, in response to determining that the invoicee is approved for a line of credit, the account based at least in part on the account creation request.
These limitations further define the abstract idea noted in claim 8, and the additional elements are as addressed in the Steps 2A2 and 2B in the claim 8 analysis above. Therefore, these claims are similarly rejected under the same rationale as claim 8, supra.
Claims 5 and 12 recite sending, [to the invoicee device], an account creation web page, the account creation web page having form fields filled with information extracted from the invoice.
These limitations further define the abstract idea noted in claim 8, and the additional elements are as addressed in the Steps 2A2 and 2B in the claim 8 analysis above. Therefore, these claims are similarly rejected under the same rationale as claim 8, supra.
Claims 6, 13 and 19 recite wherein the plurality of credit line payment term options include an interest rate.
This limitation further narrows the abstract idea, but is nonetheless part of the abstract idea identified in claim 8. The additional elements, as similarly analyzed in claim 8 above, do not integrate the abstract idea into a practical application. The claimed invention as a whole also does not amount to significantly more than the abstract idea. The claim is similarly rejected under the same rationale as claim 8, supra.
Claims 21-23 recite electronically extracting data from the invoice that is used in generating the invoice payment page.
This limitation further narrows the abstract idea, but is nonetheless part of the abstract idea identified in claim 8. The additional elements, as similarly analyzed in claim 8 above, do not integrate the abstract idea into a practical application. The claimed invention as a whole also does not amount to significantly more than the abstract idea. The claim is similarly rejected under the same rationale as claim 8, supra.
Claim Rejections - 35 USC § 103
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action.
The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
1. Determining the scope and contents of the prior art.
2. Ascertaining the differences between the prior art and the claims at issue.
3. Resolving the level of ordinary skill in the pertinent art.
4. Considering objective evidence present in the application indicating obviousness or nonobviousness.
Claims 1-3, 6, 8-10, 13, 15-17, 19 and 21-23 are rejected under 35 U.S.C. 103 as being unpatentable over Sokolic et al. (USPAP 2008/0015982) in view of Cox et al. (USPAP 2018/0158039) in view of Stolz et al. (USPAP 2019/0108560).
Re claims 1, 8 and 15: Sokolic teaches receiving, by at least one computing device of a provider, a selection of images and data fields of a company associated with an invoicer ([0165], figs. 23A, 26-32); generating, by the at least one computing device, an invoice payment detail web page that is customized for the invoice using the selection of images and data fields, wherein the invoice payment detail web page targets the invoicee by presenting company information associated with the invoicee and the invoicer and access to at least the invoice ([0175]-[0177], figs. 26-32); generate an invoice directed to an invoicee from the invoicer, the invoice comprising at least a uniform resource locator (URL) link to the invoice payment detail web page ([0175]); sending, by the least one computing device, the invoice to an invoicee device of the invoicee ([0175]); receiving, from the invoicee device, an invoice payment detail response through the invoice payment detail web page, the invoice payment detail response comprising at least the invoice payment amount for the invoice ([0174]-[0175]); and initiating a payment from a provider account to an invoicer account, the provider account being held by a provider and the invoicer account being held by the invoicer (abstract, [0147], [0155], [0172]).
Sokolic does not explicitly teach an invoice payment detail response comprising a selected one of a plurality of credit line options.
However, Cox teaches multiple financing options with different interest rates, time periods, down payments etc., and receiving a selected one of the financing options ([0078]).
Examiner notes that while Cox does not explicitly teach “credit line” payment option as recited in the claim, it would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to modify Cox to include “credit line” payment option as one of the financing options. For example, Stolz teaches financing options that include credit line as part of several financing options (0057). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of Sokolic to include plurality of “credit line” payment options with different rates and term periods as taught by Cox and Stolz combination for the obvious reason of expanding the flexibility of the financing payment options.
Re claims 2-3, 9-10 and 16-17: Sokolic teaches generating the URL link, the URL link being unique to the invoice; generating the URL link, the URL link being unique to the invoicee associated with the invoicee device ([0175]).
Re claims 6, 13 and 19: Sokolic does not explicitly teach wherein the plurality of credit line payment options include an interest rate.
However, Cox further teaches this feature at ([0078]). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to modify Sokolic to include plurality of payment options including interest rate as taught by Cox for the obvious reason of expanding the flexibility of the payment options.
Re claims 21-23: Sokolic/Cox/Stolz/Barreiro combination does not explicitly teach electronically extracting data from the received invoice that is used in generating the invoice payment page.
However, Official Notice is hereby taken that the concept of extracting data from documents for generating a webpage is notoriously old and well known.
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to modify Sokolic/Cox/Stolz combination to include this feature for the obvious reason of exhancing the flexibility of the payment options.
Support for this Official Notice can be found in Dedhia et al (USPAP 2018/0173681) at ([0026]).
Claims 4, 11 and 18 are rejected under 35 U.S.C. 103 as being unpatentable over Sokolic in view of Cox in view of Stolz, and further in view of Kaditz et al. (USPN 10,686,781).
Re claims 4, 11 and 18: Sokolic further teaches receiving, by the at least one computing device, a request from the invoicee device, the request being directed to the URL link ([0175]); and determining, in response to receiving the request from the invoicee device, that the invoicee does not have an account ([0175]).
Sokolic does not explicitly teach receiving an account creation request, the account creation request includes at least at least bank account information of an invoicee and an identity of the invoicee; and creating, in response to determining that the invoicee is approved for a line of credit, the account based at least in part on the account creation request.
Kaditz teaches concept of determining, in response to receiving the request from the invoicee device, that the invoicee does not have an account; receiving an account creation request, the account creation request includes at least at least bank account information of an invoicee and an identity of the invoicee; and creating, in response to determining that the invoicee is approved for a line of credit, the account based at least in part on the account creation request (col. 17, lines 65-col. 18, lines 15, 40-45; fig. 27).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to modify Sokolic/Cox/Stolz combination to include these features as taught by Kaditz since the claimed invention is merely a combination of old elements, and in the combination each element merely would have performed the same function as it did separately, and one of ordinary skill in the art would have recognized that the results of the combination were predictable. It further would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to modify Sokolic/Cox/ combination, to include the teachings of Kaditz in order to provide the invoicee with an alternative option for completing the transaction.
Claims 5, 12 and 21-23 are rejected under 35 U.S.C. 103 as being unpatentable over Sokolic in view of Cox in view of Stolz in view of Kaditz, and further in view of Keithley (USPAP 2008/0167956).
Re claims 5 and 12: Kaditz further teaches sending to the invoice device, an account creation webpage (col. 17, lines 65-col. 18, lines 15, 40-45; fig. 27). However, Sokolic/Cox/Stolz/Kaditz combination does not explicitly teach that the account creation web page having form fields filled with information extracted from the invoice.
Keithley teaches the concept of pre-populating a credit application for a credit line with extracted information ([0031], [0038], [0041], figs. 3 & 4).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to modify Sokolic/Cox/Stolz/Kaditz combination to include these features as taught by Keithley since the claimed invention is merely a combination of old elements, and in the combination each element merely would have performed the same function as it did separately, and one of ordinary skill in the art would have recognized that the results of the combination were predictable. It further would have been obvious to one of ordinary skill in the art before the effective filing date of the invention since pre-population of data fields provides an extra convenience to the customer and facilitates a smoother transaction and credit product acquisition process (Keithley: [0038]).
Response to Arguments
Applicant's arguments filed 11/28/2025 have been fully considered but they are not persuasive.
101 Rejection:
Applicant argues that claimed limitations “generating, by the at least one computing device, an invoice payment detail web page that is customized for the invoice using the selection of images and data fields, wherein the invoice payment detail web page targets the invoicee by presenting company information associated with the invoice and the invoicer and access to at least the invoice; generate an invoice directed to an invoicee from the invoicer, the invoice comprising at least a uniform resource locator (URL) link to the invoice payment detail web page” are neither commercial interactions, legal interactions, nor agreements in the form of contracts, legal obligations, advertising, marketing or sales activities or behaviors, and business relations. Instead, Applicant further asserts that the claim provides a technical computing process for "generating and transmitting an invoice with an invoice link."
Examiner respectfully disagrees. The aforementioned limitations are considered under Step 2A-prong 2 and Step 2B. They are considered extra-solution activities (See the updated 101 analysis supra.). The claim as a whole, does not amount to significantly more than the abstract idea itself. The claim (as interpreted in light of the Specification) does not effect an improvement to another technology (processor) or technical field; and the claim does not move beyond a general link of the use of an abstract idea to a particular technological environment. The focus of the claims is not on such an improvement in computer components as tools, but on certain independent abstract ideas that use computers as tools.
102/103 Rejection:
Applicant argues that Sokolic does not teach “generating, by the at least one computing device, an invoice payment detail web page that is customized for the invoice using the selection of images and data fields, wherein the invoice payment detail web page targets the invoicee by presenting company information associated with the invoice and the invoicer and access to at least the invoice”
Examiner respectfully disagrees. Sokolic explicitly teaches these features at least in fig. 30.
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Conclusion
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/OLABODE AKINTOLA/Primary Examiner, Art Unit 3691
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