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 .
Claim Rejections - 35 USC § 112
The following is a quotation of the first paragraph of 35 U.S.C. 112(a):
(a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention.
The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112:
The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention.
Claims 1-6, 8-13, 15-19 and 21-23 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention.
Claims 1, 8 and 15 recite “receive an invoice from an invoicer device of the invoicer that is directed to a purchase made by an invoice. The is not support for this limitation in the original disclosure. The invoice in the entire disclosure does not distinguish between an invoice for purchase made by an invoicee or an invoice for purchase yet to be made by an invoicee. Applicant is requested to cite portions of the original disclosure that support this limitation.
Claims 2-6, 9-13, 16-19 and 21-23 are similarly rejected by dependency.
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.
The claim recites a series of acts. The claim is directed to a process, which is a statutory category of invention (Step 1: YES).
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; receiving, by at least one computing device, an invoice from an invoicer device that is directed to a purchase made by an invoicee; generating, by the at least one computing device, an invoice payment detail web page for the invoicer that is customized for the invoice using the selected images and data fields, wherein the invoice detail web page targets the invoicee by presenting company information associated with the invoicee and access to at least the invoice directed to the invoicee from the invoicer; hosting the invoice payment detail web page on the at least one computing device, wherein the computing device is associated with a third party to the invoicer and the invoicee; sending, by the at least one computing device the invoice to an invoicee device of the invoicee, the invoice comprising at least a uniform resource locator (URL) link to the invoice payment detail web page; receiving, by the at least one computing device, a request from the invoicee device, the request being directed to the URL link; sending, by the at least one computing device, the invoice payment detail web page to the invoicee device, the invoice payment detail web page comprising at least an amount input field to capture an invoice payment amount for the invoice and a plurality of credit line payment options having different term periods for reimbursing the invoice payment amount to a provider, wherein the third party comprises the provider; receiving, by the at least one computing device, from the invoicee device, an invoice payment detail response comprising at least the invoice payment amount for the invoice and a selected one of the 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, wherein the payment from the provider account to the invoicer account is initiated in response to receiving the invoice from the invoicer device. These recited limitations, other than the use of generic computer components, fall “Certain methods of organizing human activity” grouping of abstract ideas as it relates to fundamental economic practices and/or commercial interactions of sales activities or behavior (Step 2A1-Yes).
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. The sending and receiving of information are mere extra-solution activities. Accordingly, the combination of additional elements does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. The claim is directed to the abstract idea (Step 2A2-No).
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 of sending and receiving information to and from the device 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 computing system (processor) is anything other than a generic processor, and the Symantec, TLI, and OIP Techs., court decisions cited in MPEP 2106.05(d)(II) indicate that mere collection or receipt of data over a network, is a well understood, routine and conventional function when it is claimed in a generic manner (as it is here). Accordingly, a conclusion that these steps are well-understood, routine and conventional activity is supported under Berkheimer option 2.
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.
Claims 1 and 15 recite corresponding system and non-transitory machine-readable medium equivalents of claim 8. This claim is similarly rejected under the same rationale as claim 8, supra.
Claims 2, 9 and 16 recite generating the URL link, the URL link being unique to the invoice.
This limitation further defines the abstract idea noted in claim 8. Therefore, these claims are 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 defines the abstract idea noted in claim 8. Therefore, these claims are similarly rejected under the same rationale as claim 8, supra.
Claims 4, 11 and 18 recite 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 defines the abstract idea noted in claim 8. Therefore, these claims are similarly rejected under the same rationale as claim 8, supra.
Claims 21-23 recite electronically extracting data from the received invoice that is used in generating the invoice payment page.
This limitation further defines the abstract idea noted in claim 8. Therefore, these claims are 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) and further in view of Barreiro et al. (USPAP 2008/0195527).
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); receiving, by at least one computing device, an invoice from an invoicer device of the invoicer that is directed to a purchase made by an invoicee ([0175]-[0177], see EOB example for services already rendered); generating, by the at least one computing device, an invoice payment detail web page for the invoicer that is customized for the invoice, using the selected images and data fields, wherein the invoice detail web page targets the invoicee by presenting company information associated with the invoicee and access to at least the invoice directed to the invoicee from the invoicer ([0175]-[0177], figs. 26-32); hosting the invoice payment detail web page on the at least one computing device, wherein the computing device is associated with a third party to the invoicer and the invoicee ([0175]); sending, by the least one computing device, the invoice to an invoicee device of the invoicee, the invoice comprising at least a uniform resource locator (URL) link to the invoice payment detail web page ([0175]); receiving, by the least one computing device, a request from the invoicee device, the request being directed to the URL link ([0175]); sending, by the at least one computing device, the invoice payment detail web page to the invoicee device, the invoice payment detail web page comprising at least an amount input field to capture an invoice payment amount for the invoice, wherein the third party comprises the provider ([0174]-[0175]); receiving, from the invoicee device, an 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 is silent on the nature of the invoice, that is, invoice for purchase made by an invoicee or an invoice for purchase yet to be made by an invoicee. However, given the EOB example, it would have been obvious to one of ordinary skill in the art before the effective filing date of Sokolic to include both types of invoices, because the outcome/result of the process/system described by the Sokolic will be the same, thereby making the process/system more flexible.
Sokolic does not explicitly teach wherein the payment detail web page comprises a plurality of credit line payment options having different term periods for reimbursing the invoice payment amount to a provider; and receiving a selected one of the credit line payment 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.
Sokolic does not explicitly teach wherein the payment from the provider account to the invoicer account is initiated in response to receive the invoice from an invoicer device.
Barreiro teaches that wherein the payment from the provider account to the invoicer account is initiated in response to receiving the invoice from an invoicer device or invoicee device (0047 fig. 3). 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 this alternative approach as taught by Barreiro for the obvious reason of enhancing the flexibility of the process/system.
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/Barreiro 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 in view of Barreiro, and further in view of Kaditz et al. (USPN 10,686,781).
Re claims 4, 11 and 18: Sokolic further teaches 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/Barreiro 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/Barreiro 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 Barreiro 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/Barreiro/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/Barreiro/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 invention provides a technical improvement that creates a streamlined system which benefits both the invoicer and the invoice (citing para. 0022). Applicant further asserts that customization of the images and data fields by the invoicer makes it possible for targeted invoicee to view the invoice. Therefore, the invention improves payment processing and transfer.
Examiner respectfully disagrees. The customization of the invoice by the invoicer for targeted invoicee is still an abstract idea. 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 certain features, please refer to the updated rejection above. In particular, with respect to the EOB example. The invoice here is customized using information associated with the invoicer, and targets the invoicee by presenting “company information associated with the invoicee (inherently using the name, address, date of birth and other pertinent information of the patient and/or insurance company details for generating EOB).
Applicant’s argument about the nature of the invoice in Cox (credit line payment option for an invoice directed to a purchase made by an invoicee) has already been addressed using the Sokolic reference (see explanation above). Furthermore, Applicant argues that Cox financing options includes a loan, and not credit line as recited in the claims. While the loan is an exemplary financing option discussed in Cox, it would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to incorporate other forms of financing options in order the enhance the flexibility of the process. See updated rejection/analysis above, including the additional Stolz reference.
In response to applicant's arguments against the references individually, one cannot show nonobviousness by attacking references individually where the rejections are based on combinations of references. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981); In re Merck & Co., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986).
.
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. 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 nonprovisional extension fee (37 CFR 1.17(a)) 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 mailing date of this final action.
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/OLABODE AKINTOLA/Primary Examiner, Art Unit 3691