DETAILED ACTION
Acknowledgements
This action is in response to Applicant’s filing on Jan. 27, 2026, and is made Final. This action is being examined by James H. Miller, who is in the eastern time zone (EST), and who can be reached by email at James.Miller1@uspto.gov or by telephone at (469) 295-9082.
Interviews
Interviews are “indispensable to advance the prosecution of a patent application.” MPEP § 713. Accordingly, the following Examiner’s guidance and suggested workflow maximizes this benefit to Applicant by: (1) avoiding back and forth telephone calls for scheduling, (2) permitting Examiner out-of-office notifications to the Applicant when sending the agenda, and (3) permitting real-time document collaboration and screen sharing.
Interviews are available by telephone or, preferably, by video conferencing using the USPTO’s web-based collaboration platform. Applicants are strongly encouraged to schedule via the USPTO Automated Interview Request (AIR) portal at http://www.uspto.gov/interviewpractice. If an interview is needed more quickly than permitted by the AIR scheduling tool, note this in the AIR remarks for consideration. The Examiner routinely considers such urgent request when practicable.
An agenda submitted when filing the AIR is strongly encouraged, because Examiners use agendas when determining whether to grant an interview. The AIR has character limits, so send the agenda contemporaneously to James.Miller1@uspto.gov and reference the AIR.
After-Final Interviews Requests are granted only at the Examiner’s discretion and only if disposal or clarification for appeal may be accomplished with only nominal further consideration. MPEP § 713.09. An advance agenda explaining how the interview advances prosecution—e.g., through targeted arguments, identified Examiner error, or proposed claim amendments—is strongly suggested.
For GRANTED requests, expect an email within two (2) business days confirming a date/time slot and collaboration tool access instructions. For DENIED requests, the record will include an explanation for the denial.
The examiner is generally available for interviews, Monday through Friday, 10:00 a.m. to 4:00 p.m. ET.
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 Status
The status of claims is as follows:
Claims 1–10 and 17–26 are now pending and examined with Claims 1 and 17 in independent form.
Claims 1, 17, and 19 are presently amended.
Claims 21–26 are presently added.
No Claims are presently cancelled.
Response to Amendment
Applicant's Amendment has been reviewed against Applicant’s Specification filed Dec. 7, 2023, [“Applicant’s Specification”] and accepted for examination.
Response to Arguments
35 U.S.C. § 101 Argument
Applicant argues the amended claims recite an improvement in the functioning of a computer or other technology or technical field, citing MPEP § 2106.05(a), either because the claims do not recite an abstract idea or any alleged abstract idea is integrated into a practical application. Applicant’s Reply at 9–10. Specifically, the amended claims provide “improvements over conventional systems by addressing challenges to the financial risks associated with unauthorized transaction hold removal, such as when an unauthorized user seeks to remove a transaction hold to access assets in the financial account.” Id. at 10. The specification (¶¶ 2, 3) identifies the technological problem as existing systems allow an account custodian to freeze an account using minimal security because freezing poses low risk. However, unfreezing an account in the same manner as freezing carries significant risk from bad actors who could obtain the user’s password to remove the hold and move funds without the user’s knowledge. Applicant’s solution is an “enhanced security measures for preventing an unauthorized user from removing a transaction hold” by using a “heightened security check” (employee’s identity is determined and then checked against an authorized employee list) for hold removal instead of reusing the minimal baseline security used to place the hold. Id. at 10–11. The claim itself reflects the technological improvement and is particular because implementing the heightened security check comprises determining the employee’s identity using at least one of biometric authentication, device identity confirmation, or multi factor credential based verification, and comparing the determined employee identity to an authorized employee list stored in a bank entitlements database before updating the transaction hold status. Id.
Examiner respectfully disagrees.
Examiner notes that, as described by Applicant, the claims recite a process in which a programmed computer system receives a request to place a hold, updates a transaction hold status field in an account information database, later receives a request to remove the hold, and then, as part of a “heightened security check,” determines an employee’s identity using biometric, device, or credential based information and compares that identity to an authorized employee list in a bank entitlements database before updating the hold status from active to inactive. Examiner further notes that Applicant characterizes these steps as providing “improvements over conventional systems” and “enhanced security measures” for transaction hold removal, but does not identify in the claim language any recited data structure, protocol, or processing operation other than generic receiving, determining, comparing, and updating operations performed by conventional computer components and databases. In view of Applicant’s own description of the claimed subject matter, the claims are directed to managing financial risk in connection with account holds (i.e., deciding under what conditions a hold flag in an account database may be changed) using known authentication techniques and standard database lookups, which aligns with the type of result oriented “more secure transaction” processing the Federal Circuit held ineligible in Universal Secure Registry LLC v. Apple, Inc., 10 F.4th 1342 (Fed. Cir. 2021), where combining known security mechanisms to achieve improved security did not amount to a specific asserted improvement in computer technology. Applicant is requested to specifically address Universal Secure Registry LLC v. Apple in any response.
35 U.S.C. § 103 Argument
Applicant’s arguments, see pp. 7–8, filed Jan. 27, 2026, with respect to Claims 1–10 and 17–20 have been fully considered and are persuasive. The rejection of Claims 1–10 and 17–20 has been withdrawn.
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 1–10 and 17–26 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., an abstract idea) without significantly more.
Analysis
Step 1: Claims 1–10 and 17–26 are directed to a statutory category. Claims1–10 and 21–24 recite a “method” and are therefore, directed to the statutory category of a “process.” Claims 17–20, 25, and 26 recite a “method” and are therefore, directed to the statutory category of a "process.”
Representative Claim
Claim 1 is representative [“Rep. Claim 1”] of the subject matter under examination and recites, in part, emphasis added by Examiner to identify limitations with normal font indicating the abstract idea exception, bold limitations indicating additional elements. Each limitation is identified by a letter for later use as a shorthand notation in referencing/describing each limitation. Portions of the claim use italics to identify intended use limitations1 and underline, as needed, in further describing the abstract idea exception:
[A] 1. A computer-implemented method for authorizing a transaction hold renewal, the method comprising:
[B] receiving, by a programmed computer system, a request from an authorized custodian to place a transaction hold on a financial account associated with the authorized custodian and managed by a financial institution;
[C] updating, by the programmed computer system, a transaction hold status in an account information database from an inactive status to an active status in response to the received request to place the transaction hold on the financial account, wherein updating the transaction hold status from the active status to the inactive status comprises implementing a baseline security check by the programmed computer system;
[D] receiving, from a requesting party remote from the authorized custodian, a subsequent request to remove the transaction hold from the financial account;
[D1] updating, by the programmed computer system, the transaction hold status in the account information database from the active status to the inactive status in response to the received subsequent request to remove the transaction hold on the financial account, wherein updating the transaction hold status from the active status to the inactive status comprises implementing a heightened security check by the programmed computer system in comparison to the baseline security check, and wherein implementing the heightened security check comprises:
[E] receiving, from an employee of the financial institution, an input to update the transaction hold status from the active status to the inactive status;
[F] determining, by the programmed computer system, an identity of the employee, wherein determining the identity of the employee comprises at least one of biometric authentication, device identity confirmation, or multi-factor credential-based verification;
[G] confirming, by the programmed computer system, whether the employee is authorized to remove the transaction hold by comparing the determined employee identity to an authorized employee list stored in a bank entitlements database; and
[H] removing the transaction hold from the financial account based on the confirmed authority of the employee to remove the transaction hold.
Claims are directed to an abstract idea exception.
Step 2A, Prong One: Rep. Claim 1 recites “authorizing a transaction hold renewal” in the preamble, Limitation A, “updating … a transaction hold status … from an inactive status to an active status in response to the received request to place the transaction hold on the financial account” in Limitation C, and “removing the transaction hold from the financial account based on the confirmed authority of the employee to remove the transaction hold” in Limitation H, which recites a fundamental economic principle/practice under the organizing human activity exception because said Limitations “describe concepts relating to the economy and commerce,” such as “mitigating risks” of unauthorized “transaction hold renewal.” MPEP § 2106.04(a)(2)(II)(A). Limitations B and D–G are the required steps, data inputs, and data outputs required to “authoriz[e] a transaction hold renewal” and therefore, recites the same exception. Id.
Alternatively2, Limitations B–H, as drafted, recite the abstract idea exception of mental processes that under the broadest reasonable interpretation, in substance involve collecting information, evaluating it, and making decisions based on that information, but for the recitation of the generic computer components indicated in bold. MPEP § 2106.04(a)(2)(III).
Claims recite a mental process when they contain limitations that can practically be performed in the human mind, including for example, observations, evaluations, judgments, and opinions. Examples of claims that recite mental processes include:
• a claim to "collecting information, analyzing it, and displaying certain results of the collection and analysis," where the data analysis steps are recited at a high level of generality such that they could practically be performed in the human mind, Electric Power Group v. Alstom, S.A., 830 F.3d 1350, 1353-54, 119 USPQ2d 1739, 1741-42 (Fed. Cir. 2016);
. . .
• a claim to collecting and comparing known information (claim 1), which are steps that can be practically performed in the human mind, Classen Immunotherapies, Inc. v. Biogen IDEC, 659 F.3d 1057, 1067, 100 USPQ2d 1492, 1500 (Fed. Cir. 2011).
MPEP § 2106.04(a)(2)(III)(A). The specification teaches that a “user can initiate the hold by calling the financial institution, sending a written communication to the financial institution, calling the financial institution, and/or communicating the request to the financial institution in any suitable manner.” Spec. ¶ 24. The specification further discloses that in practice an employee receives a request to remove a hold, provides account-custodian identifying information and confirms the custodian’s identity, and then, the processor removes the hold associated with the financial account. Spec. ¶¶ 29–31. For example, but for the generic computer components claim language, here, Limitations B–H, recite collecting information (Limitations B, D, E) and analyzing it (Limitations C, D1, F, G, and H), where the data analysis steps are recited at a high level of generality such that they could practically be performed in the human mind. In such manual implementation, an employee receives a request from a custodian, reviews information about the account and the employee’s own authorization, and decides whether to maintain or remove the hold, which mirrors the logical steps recited by Rep. Claim 1. Spec. ¶¶ 24–29. For example, under a broad, technology neutral view, Limitations C, D1, and H correspond to human acts of deciding whether to place, maintain, or remove a hold on an account based on received requests and authorization information (observation and judgment) and recoding that decision by marking a hold status in a record (which could be a paper ledger rather than an electronic database). Limitation F corresponds to verifying a written credential and Limitation G corresponds to comparing that identify to a printed list of authorized employees, as in Classen’s “collecting and comparing known information.” Spec. ¶¶ 24, 25, 29, 30. Limitations C, D1, F, and H cover any solution with no restriction on how the result is accomplished and no description of the mechanism for accomplishing the result, which is so broad as to encompass mental processes. Likewise, Limitation G is a mental process that is practically performed in the human mind or with pen and paper because collecting and comparing known information (i.e., “the determined employee identity to an authorized employee list”) are steps that can be practically performed in the human mind under Classen.
If a claim limitation under BRI, covers performance of the limitation in the mind but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract idea exception. MPEP § 2106.04(a)(2)(III). Accordingly, the pending claims recite the combination of these abstract idea exceptions.
Step 2A, Prong Two: The additional elements identified in Rep. Claim 1, considered individually and as an ordered combination, do not integrate the abstract idea exception into a practical application. MPEP § 2106.04(d).
The additional elements are limited to the computer components and indicated in bold, supra. The additional elements are: computer-implemented (programmed computer); a programmed computer system; an account information database; a bank entitlements database, and a device (Claim 17)3.
The additional elements do not improve the functioning of a computer or other technology. MPEP § 2106.05(a).
A claim improves technology only when it recites a specific improvement to the way a computer itself operates, not merely the application of an existing process using a computer. MPEP § 2106.05(a) (citing Enfish, LLC v. Microsoft Corp., 822 F.3d 1327, 1336 (Fed. Cir. 2016)). Here, the abstract idea exception was previously performed manually. Spec. ¶¶ 24–29. Because the process can be performed manually, the computer is not being improved and is merely being used as a tool to perform the pre-existing manual process. Applying a pre-existing manual process using generic computer components, even via a GUI, is not an improvement to computer technology.
The specification confirms this characterization by describing the advantages of the claimed system in terms of business outcomes, such as controlling fraud risk and preventing unauthorized transactions, rather than in terms of any specific technical improvement to the computer, GUI, server, mobile device, or network infrastructure itself. Spec. ¶ 3, 22, 23, 27–31. The specification does not describe any specific technical improvement to validation algorithms, OCR, image analysis methods, network communication protocols, encryption, or geolocation processing, display technology, rendering algorithms, data structures, network protocols, or computer architecture. Spec. ¶¶ 18, 56–60. Further, the specification describes the user interfaces only at a high functional level (e.g., a graphical user interface prompting an employee to enter information and presenting a “lift hold” or “remove flag” button) without any unconventional technical mechanism. Spec. ¶¶ 29–31. Thus, these are generic GUI elements. Thus, any improvements describe business outcomes, not technical improvements to the computers themselves.
The additional elements do not apply the abstract idea with a particular machine.
Although the claims recite specific hardware components (i.e., computer-implemented (programmed computer); a programmed computer system; an account information database; a bank entitlements database, and a device (Claim 17)), these components are recited at a high functional level and perform only their generic functions of receiving, transmitting, storing, and processing data. Spec. ¶¶ 18, 27, 28, 56–60. A machine is “particular” only when it imposes a meaningful limit on the claims scope. MPEP § 2106.05(b). Here, any general-purpose computer, server, mobile device, and database would satisfy the claim’ hardware requirements, which confirms that the hardware components are generic rather than “particular.” MPEP § 2106.05(b). The specification describes each computer component using broad, open-ended language without restricting the claimed hardware to any particular design, configuration, or architecture. Spec. ¶ 18, 54, 56–60, 67, 68.
The additional elements are mere instructions to apply the abstract idea exception. MPEP § 2106.05(f).
Regarding the additional elements, Applicant’s Specification does not otherwise describe them with specificity beyond exemplary language or describes them as a general-purpose computer, as a part of a general-purpose computer, or as any known and exemplary (generic) computer component known in the prior art. The specification’s own broad, exemplary characterization confirms that these components are not described in a manner that would impose any specific technical limitation that would integrate the abstract idea into a practical application. Thus, Applicant takes the position that such hardware/software is so well known to those of ordinary skill in the art that no explanation is needed under 35 U.S.C. § 112(a). Lindemann Maschinenfabrik GMBH v. Am. Hoist & Derrick Co., 730 F.2d 1452, 1463 (Fed. Cir. 1984) (citing In re Meyers, 410 F.2d 420, 424 (CCPA 1969) (“[T]he specification need not disclose what is well known in the art”). E.g., Spec. ¶ 18 (“The one or more processors 160 may be any one of a number of single or multi-core processors known in the art.”); ¶ 54 (“While various embodiments have been described herein, it should be apparent that various modifications, alterations, and adaptations to those embodiments may occur to persons skilled in the art with attainment of at least some of the advantages.”); ¶ 56 (“it will be understood by those within the art that each function and/or operation within such block diagrams, flowcharts, and/or examples can be implemented, individually and/or collectively, by a wide range of hardware, software, firmware, or virtually any combination thereof. Those skilled in the art will recognize that some aspects of the forms disclosed herein, in whole or in part, can be equivalently implemented in integrated circuits, as one or more computer programs running on one or more computers (e.g., as one or more programs running on one or more computer systems), as one or more programs running on one or more processors (e.g., as one or more programs running on one or more microprocessors), as firmware, or as virtually any combination thereof, and that designing the circuitry and/or writing the code for the software and or firmware would be well within the skill of one of skill in the art in light of this disclosure. In addition, those skilled in the art will appreciate that the mechanisms of the subject matter described herein are capable of being distributed as one or more program products in a variety of forms, and that an illustrative form of the subject matter described herein applies regardless of the particular type of signal bearing medium used to actually carry out the distribution.”); ¶ 67 (“With respect to the appended claims, those skilled in the art will appreciate that recited operations therein may generally be performed in any order.”); ¶ 12 (“The exemplifications set out herein illustrate various disclosed embodiments, is one form, and such exemplifications are not to be construed as limiting the scope thereof in any manner”); ¶ 24 (“it is envisioned that the user can initiate the hold by calling the financial institution, sending a written communication to the financial institution, calling the financial institution, and/or communicating the request to the financial institution in any suitable manner”); ¶ 25 (“The processor 160 can communicate with a secure database 300 that includes information associated with the particular financial account including, an identity of an account custodian, account numbers, usernames, passwords, and/or any other information associated with the financial account.”); ¶ 29 (Such account custodian-identifying information includes, for example, a name of the account custodian, a social security number of the account custodian, an account number, user name, and/or password of the financial, account, and/or any suitable combination thereof.”); ¶ 30 (“Such employee identity and/or credential can be confirmed through the input of an employee's unique username and/or password, identifying the digital device used to select the "lift hold" option, a biometric authentication, and/or any combinations thereof.”); ¶ 57 (“the instructions can be distributed via a network or by way of other computer readable media. Thus a machine readable medium may include any mechanism for storing or transmitting information in a form readable by a machine (e.g., a computer),”); ¶ 57 (“the non-transitory computer-readable medium includes any type of tangible machine-readable medium suitable for storing or transmitting electronic instructions or information in a form readable by a machine (e.g., a computer).”); ¶ 58 (“Any of the software components or functions described in this application, may be implemented as software code to be executed by a processor using any suitable computer language”); ¶ 58 (“Any such computer readable medium may reside on or within a single computational apparatus and may be present on or within different computational apparatuses within a system or network.”); ¶ 59 (“As used in any aspect herein, the term "logic" may refer to an app, software, firmware and/or circuitry configured to perform any of the aforementioned operations. Software may be embodied as a software package, code, instructions, instruction sets and/or data recorded on non-transitory computer readable storage medium. Firmware may be embodied as code, instructions or instruction sets and/or data that are hard coded (e.g., nonvolatile) in memory devices.”); ¶ 60 (“As used in any aspect herein, the terms "component," "system," "module" and the like can refer to a computer-related entity, either hardware, a combination of hardware and software, software, or software in execution”); ¶ 61 (“As used in any aspect herein, an "algorithm" refers to a self-consistent sequence of steps leading to a desired result, where a "step" refers to a manipulation of physical quantities and/or logic states which may, though need not necessarily, take the form of electrical or magnetic signals capable of being stored, transferred, combined, compared, and otherwise manipulated.”); ¶ 68 (“the particular features, structures or characteristics may be combined in any suitable manner in one or more aspects.”); ¶¶ 18, 27, 28 (known and generic database for storing information and described by name only); ¶¶ 29, 30, 63 (known and generic “suitable device” or “digital device” described by name only.)
The generic processor, here, performs calculations (functions) and executes instructions that are programmed by software directed to the abstract idea. Spec. ¶¶ 18, 56–58. This is a computer doing what it is designed to do—performing directions it is given to follow, and whose directions are directed to the abstract idea.
Limitation A describes a “computer-implemented” method to perform the steps of the claimed invention. Limitations B–E describe the “programmed computer” performing the steps of the claimed invention, which represents the abstract idea exception itself. Performing the steps of the abstract idea exception using a computer, as in Universal Secure Registry LLC v. Apple (where claims that achieved “more secure” payment transactions by combining known authentication techniques were held ineligible), merely adds a general-purpose computer after the fact to an abstract idea exception without imposing any meaningful technical limitations. MPEP § 2106.05(f)(2). Alternatively, the claim generically recites an effect of the abstract idea without specifying how the computer achieves that effect in any technically meaningful way. MPEP § 2106.05(f)(3).
Therefore, the claim as a whole, considering the additional elements individually and as an ordered combination, amounts to no more than mere instructions to apply the abstract idea using generic computer components and is not a practical application. MPEP § 2106.05(f). The additional elements do not integrate the abstract idea exception into a practical application because they do not impose any meaningful limits on the abstract idea exception. Accordingly, Rep. Claim 1 is directed to an abstract idea.
Independent Claim 17 is not substantially different than Rep. Claim 1, recites the same abstract idea as Rep. Claim 1, and contain no additional elements not otherwise analyzed for Rep. Claim 1. Therefore, Independent Claim 17 is also directed to the same abstract idea.
The claims do not provide an inventive concept.
Step 2B: Rep. Claim 1 fails Step 2B because the claim as a whole, even when considering the additional elements individually and in combination, does not amount to significantly more than the abstract idea. MPEP § 2106.05. The additional elements (i.e., computer-implemented (programmed computer); a programmed computer system; an account information database; a bank entitlements database, and a device (Claim 17)), are each well-understood, routine, and conventional (“WRC”) computer components and functions in the relevant field, as evidenced by Applicant’s own disclosure4. Further, Applicant’s Specification discloses that these components operate in no particular order and are implemented using generic, off-the-shelf computing technology. Spec. ¶ 68 (steps/functions may be performed in any order or concurrently); ¶¶ 18, 27, 28, 54, 56–60 (describing each component using exemplary language as generic or known computing equipment and networks).
(1) computer-implemented (programmed computer); a programmed computer system; an account information database; a bank entitlements database, and a device (Claim 17) are WRC in the financial technology field. Spec. ¶¶ 18, 24, 25, 27, 28, 29, 30, 31, 54, 56–60, 63, 57, 68.
The Specification further confirms that the functions of receiving, storing, transmitting, and processing data are normal, well-understood operations of generic computer systems, and the steps may be performed in any order or concurrently. Spec. ¶¶ 24, 25, 27–29, 56–58, 68.
The combination is also WRC at the high level of generality recited:
The combination of the additional elements is likewise WRC. A combination of individually well-understood, routine, and conventional elements does not provide an inventive concept unless the combination itself produces an unconventional result or is applied in an unconventional manner. MPEP § 2106.05(d)(2). Here, the combination performs each step in exactly the manner described as conventional throughout Applicant’s own Specification. There is no indication that the combination of these elements operates in an unconventional manner or produces a result that is other than what would be expected from the generic application of these individual components. The processor simply receives requests, consults conventional databases for flag status and employee entitlements, and updates the status field, accordingly, as indicated in Figs. 3 & 4 and associated text, Spec. ¶¶ 24–31.
Unlike BASCOM, where the claims recited a specific non-conventional arrangement of installing a filtering tool at a specific network location (an ISP server) rather than on individual end-user devices, Rep. Claim 1 does not recite how the elements are combined in a non-conventional way. The claims recite each element at a high level of generality without specifying the particular arrangement or order that constitutes the alleged improvement. At the high level of generality recited, the combination is WRC. Any BASCOM argument fails because the specification itself characterizes the hardware and software in broad, exemplary terms and does not describe any particular network or system architecture. Spec. 18, 54, 56–60, 67, 68.
Further, unlike cases where an inventive concept was found in a specific security mechanism (e.g., CosmoKey), the claims are like the ineligible USR v. Apple where the Federal Circuit held combining known authentication techniques to achieve “more secure” transactions did not supply the inventive concept. The present claims likewise use known authentication techniques to achieve “a more secure” hold removal without any unconventional technical arrangement.
To the extent Applicant points to any arrangement in the specification as “enhanced security measures,” those measures consist of using known forms of authentication (passwords, multi-factor authentication, biometrics, and device identification) before updating a hold flag, and are described at a high level and are not claimed in any specific unconventional arrangement. Spec. ¶¶ 3, 4, 24–31, 33–35.
Rep. Claim 1 recites only the abstract steps of receiving requests, updating a status field, determining identity, comparing identity to an authorized employee list, and removing a hold without incorporating any specific technical details for how these elements are performed. A non-conventional arrangement that is described only in general terms, and not claimed as a particular technical configuration, cannot supply the inventive concept at Step 2B. Because the claims here recite only generic components performing generic functions at a high level of generality, the abstract idea recited in claims cannot be improved by a computer. MPEP § 2106.05(f). No inventive concept is present under Step 2B. MPEP § 2106.05(d).
Accordingly, the additional elements of Rep. Claim 1 have been recognized, based on Applicant’s own disclosure, as WRC activity in the field. MPEP § 2106.05(d). These elements do no more than “apply” the recited abstract idea(s) using known computer and computer-related components. See also Step 2A, Prong Two, supra.
Independent Claim 17 is method claim reciting steps that perform the same abstract processing and generic computer operations recited in Rep. Claim 1. Independent Claim 17 adds no additional elements beyond those of Rep. Claim 1 that would amount to significantly more than the abstract idea. Therefore, Independent Claim 17 also does not recite an inventive concept under Step 2B.
Dependent Claims Not Significantly More
The dependent claims have been given the full two-part analysis including analyzing the additional limitations both individually and in combination with the elements of the independent claims. Each dependent claim incorporates all the limitations of its parent Independent Claim and therefore recites the same abstract idea. The additional limitations recited in the dependent claims do not integrate the abstract idea exception into a practical application under Step 2A, Prong Two, and do not amount to significantly more than the abstract idea under Step 2B, for the following reasons:
Dependent Claims 2 recites a “wherein” clause that further limits the abstract idea of the Independent Claims but contains the additional elements of: electronically characterization of “transmitting.” Examiner interprets “electronically” as using the claim programmed computer is some way to transmit “the subsequent request,” which merely invokes computers or other machinery in its ordinary capacity to receive, store, or transmit data. MPEP § 2106.05(f)(2). Thus, “electronically” amounts to mere instructions to apply the exception with a computer. MPEP § 2106.05(f).
Dependent Claims 3, 4, 5, and 6 all recite additional limitations that form part of the same abstract idea exception as recited in Independent Claims and contain no additional elements. These limitations merely describe additional financial consequences of the same abstract “authorizing a transaction hold renewal” and do not introduce any new computer component or technical mechanism. An inventive concept or practical application cannot be furnished by an abstract idea exception itself. MPEP §§ 2106.05(I), 2106.04(d)(III).
Dependent Claims 7, 8, 9, and 18 all recite “wherein” clauses or limitations that further limit the abstract idea of the Independent Claims and contain no additional elements. Regarding Dependent Claims 7 and 9 and “device identity confirmation” (Claim 7) and “credential-based verification” (Claim 9), Applicant’s Specification teaches “Such employee identity and/or credential can be confirmed through the input of an employee's unique username and/or password, identifying the digital device used to select the "lift hold" option, a biometric authentication, and/or any combinations thereof.” Spec. ¶ 30. Thus, “device identity confirmation” (Claim 7) and “credential-based verification” (Claim 9) describes receiving a unique username and password, comparing the username and password to the one stored before permitting an update to the transaction hold status, which merely invokes computers or other machinery in its ordinary capacity to receive, store, or transmit data. MPEP § 2106.05(f)(2). The “comparing” is a mental process under Classen. Regarding Dependent Claim 8 and the “biometric authentication”, Applicant’s Specification teaches “The biometric authentication can include a fingerprint, facial recognition, voice recognition, and/or a retina scan, for example.” Spec. ¶ 30. Thus, “biometric authentication” describes the mental process of recognizing a person’s face (i.e., facial recognition). Regarding Dependent Claim 18 and the “multi-factor authentication”, Applicant’s Specification teaches “the account custodian-identifying information involves multi-factor authentication where the account custodian must provide multiple identifiers to the employee.” Spec. ¶ 29. Thus, “multi-factor authentication” describes receiving “multiple identifiers” and comparing the “multiple identifiers” to those stored before “determining an identity of the employee,” which merely invokes computers or other machinery in its ordinary capacity to receive, store, or transmit data. MPEP § 2106.05(f)(2). The “comparing” is a mental process under Classen. These are well known authentication techniques implemented in a routine way and this merely add conventional data gathering and comparison processes to the abstract idea. Even if not treated as a mental process, these limitations do not significantly more because they only specify the type of information used to carry out the same authentication logic with generic computer components. An inventive concept or practical application cannot be furnished by an abstract idea exception itself. MPEP §§ 2106.05(I), 2106.04(d)(III).
Dependent Claims 10, 19, and 20 all recite additional limitations that form part of the same abstract idea exception as recited in Independent Claims and contain no additional elements. All “receiving” limitations merely invokes computers or other machinery in its ordinary capacity to receive, store, or transmit data. MPEP § 2106.05(f)(2). Examiner interprets “electronically” as using the claim programmed computer is some way to “receive … a second input,” which merely invokes computers or other machinery in its ordinary capacity to receive, store, or transmit data. MPEP § 2106.05(f)(2). The “determining” limitations are mental processes that are practically performed in the human mind or with pen and paper because it requires mere “observation, evaluation, judgment, and/or opinion” and cover any solution with no restriction on how the result is accomplished and no description of the mechanism for accomplishing the result, which is so broad as to encompass mental processes. Even if not treated as a mental process, these limitations do not significantly more because they only specify the type of information used to carry out the same authentication logic with generic computer components. An inventive concept or practical application cannot be furnished by an abstract idea exception itself. MPEP §§ 2106.05(I), 2106.04(d)(III).
Regarding Claims 21 and 22, these limitations simply further limit how and where the same abstract authorization steps are initiated in a generic user interface and do not add any technical improvement to the UI. These are business/user-experience rules implemented with generic remote systems and interfaces. MPEP § 2106.05(f)(2).
Regarding Claims 23 and 24, verifying a credential and operating remote systems are routine authentication and network operations and are described generically in the specification. Spec. ¶ 2, 3, 18, 24, 25, 27, 28, 56–60. These limitations further limit the business policy and do not add significantly more. MPEP § 2106.05(f).
Regarding Claims 25 and 26, these limitations are business choices about which actors may trigger each direction of status change and are implemented with generic remote computers. They di not introduce any non-conventional technical mechanism and do not add significantly more. MPEP § 2106.05(f).
Conclusion
Claims 1–10 and 17–26 are therefore drawn to ineligible subject matter as they are directed to an abstract idea without significantly more. The analysis above applies to all statutory categories of invention. As such, the presentment of Rep. Claim 1 otherwise styled as another statutory category is subject to the same analysis.
Conclusion
THIS ACTION IS MADE FINAL. 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.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to JAMES H MILLER whose telephone number is (469)295-9082. The examiner can normally be reached M-F: 10- 4 PM (EST).
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/JAMES H MILLER/Primary Examiner, Art Unit 3694
1 Statements of intended use fail to limit the scope of the claim under BRI. MPEP § 2103(I)(C).
2 “It should be noted that these groupings are not mutually exclusive, i.e., some claims recite limitations that fall within more than one grouping or sub-grouping. … Accordingly, examiners should identify at least one abstract idea grouping, but preferably identify all groupings to the extent possible, if a claim limitation(s) is determined to fall within multiple groupings and proceed with the analysis in Step 2A Prong Two.” MPEP § 2106.04(a).
3 Claim 17 identifies additional computer equipment to perform Rep. Claim 1 functions that are not otherwise recited in Rep. Claim 1. Examiner also analyzes the specific Claim 17 computer equipment with Rep. Claim 1.
4 See Changes in Examination Procedure Pertaining to Subject Matter Eligibility, Recent Subject Matter Eligibility Decision (Berkheimer v. HP, Inc.), 3-4, https://www.uspto.gov/sites/default/files/documents/memo-berkheimer-20180419.PDF (April, 18, 2018) (That additional elements are well-understood, routine, or conventional may be supported by various forms of evidence, including "[a] citation to an express statement in the specification or to a statement made by an applicant during prosecution that demonstrates the well-understood, routine, conventional nature of the additional element(s).").
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