DETAILED ACTION Status of the Claims
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . The following is in response to a Request for Continued Examination dated December 22, 2025. Claims, 1, 8-10, 15-16 and 19-20 are amended. Claims 2-3 and 11-12 are cancelled. Claims 1, 4-10 and 13-24 are pending. All pending claims are examined.
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.
Response to Arguments
101 Analysis
In line with the "2019 Revised Patent Subject Matter Eligibility Guidance," which explains how we must analyze patent-eligibility questions under the judicial exception to 35 U.S.C. § 101. 84 Fed. Reg. 50-57 ("Revised Guidance"), the first step of Alice (i.e., Office Step 2A) consists of two prongs. In Prong One, we must determine whether the claim recites a judicial exception, i.e., an abstract idea, a law of nature, or a natural phenomenon. 84 Fed. Reg. at 54 (Section III.A. I.). If it does not, the claim is patent eligible. Id.
An abstract idea must fall within one of the enumerated groupings of abstract ideas in the Revised Guidance or be a "tentative abstract idea, "with the latter situation predicted to be rare. Id. at 51-52 (Section I, enumerating three groupings of abstract ideas), 54 (Section III.A. I., describing Step 2A Prong One), 56-57 (Section III.D., explaining the identification of claims directed to a tentative abstract idea).
If a claim does recite a judicial exception, the next is Step 2A Prong Two, in which we must determine if the "claim as a whole integrates the recited judicial exception into a practical application of the exception." Id. at 54 (Section II.A.2.) If it does, the claim is patent eligible. Id.
If a claim recites a judicial exception but fails to integrate it into a practical application, we move to the second step of Alice (i.e., Office Step 2B). to evaluate the additional limitations of the claim, both individually and as an ordered combination, to determine whether they provide an inventive concept. Id. at 56 (Section III.B.). In particular, we look to whether the claim:
• Adds a specific limitation or combination of limitations that are not well-understood, routine, conventional in the field, which is indicative that an inventive concept may be present; or
• simply appends well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception, which is indicative that an inventive concept may not be present.
The analysis in line with current 101 guidelines. Even if the abstract idea is deemed to be novel, the abstract idea is no less abstract (see Flook- new mathematical formula was an abstract idea).
Taking the broadest reasonable interpretation, the invention is directed to a method of organizing human activity in which there is account opening.
“In accordance with judicial precedent and in an effort to improve consistency and predictability, the 2019 Revised Patent Subject Matter Eligibility Guidance extracts and synthesizes key concepts identified by the courts as abstract ideas to explain that the abstract idea exception includes the following groupings of subject matter, when recited as such in a claim limitation(s) (that is, when recited on their own or per se):
(b) Certain methods of organizing human activity—fundamental economic principles or practices (including hedging, insurance, mitigating risk); commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or
behaviors; business relations); managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions)1 – See Federal Register / Vol. 84, No. 4 / Monday, January 7, 2019 / p.52.
Step 1: The claims are directed to one or more of the following statutory categories; a process, a machine, a manufacture, and a composition of matter.
Claim 1 which is illustrative of the independent claims including 10 and 16 recite:
A method comprising:
sending, from a server to a first device, balance information for a plurality of accounts of an organization, the first device displaying the balance information at a first user interface;
receiving, by the server, an indication of a selection of a first account of the plurality of accounts;
generating, by the server using a machine learning model trained on historical balance data and cash sweep data, forecasted sweeps based on trend data for the first account determining, by the server, a blend of predicted sweeps comprising unsettled transactions and the forecasted sweeps, wherein the blend is dynamically weighted based on elapsed time within a particular time period;
sending, from the server to the first device based on the selection and for display at the first user interface, first information for first expected sweeps received within a first time period, for the first account, second information for second expected sweeps for a second time period, for the first account,
the second time period for the first account comprising the blend of predicted sweeps and forecasted sweeps, and third information for reconciled sweeps for the second time period, for the first account,
wherein at least one of the first expected sweeps or the second expected sweeps include a first portion of expected sweeps which are automatically initiated by a first service; wherein the first device displays via the first user interface the first information, the second information, and the third information;
in response to detecting an anomaly between the second information and the third information in the first account, the anomaly indicating a discrepancy between the second information and the third information, providing an indication of the discrepancy to the first device, and when the discrepancy exceeds a threshold, causing the first device to display at the first user interface an icon in a first location of the first user interface in contextual relation to a second location corresponding to the first account; thereby reducing network resource consumption by consolidating balance information at a central location to reduce balance requests to multiple account servers; and
in further response to detecting the anomaly in the first account
causing the first service to schedule an automated action to resolve the anomaly, reporting the automated action to the first device via the icon displayed at the first user interface,
wherein upon selection of the icon at the first device, the reporting of the automated action is displayed on the first user interface at the first device or
not causing the first service to schedule the automated action to resolve the anomaly, wherein upon selection of the icon at the first device, causing one or more suggested actions [[are]] to be displayed on the first user interface to resolve the anomaly,
receiving an input from the first device indicating a selected action of the one or more suggested actions to resolve the anomaly and
causing the selected action to be performed by the first service responsive to receiving the input.
2A, Prong One, The invention is directed to a metho of organizing human activity that is a commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations) or and a fundamental economic practice of management of cash sweeps used in settlement of financial transactions(see App. Spec. paras. 0029-0030).
Beyond the abstract idea, the additional elements recite hardware components such as a computing device (network, processor – see App. Spec. paras.0023-0025, 0098;see also paras. 0033-0036), there does not appear to be any technology being improved. They are described at a high level of generality where each step does no more than require a generic computer to perform generic computer functions. Absent is any support in the specification that the claims as recited require specialized computer hardware or other inventive computer components.
Unlike, McRO, the present claims contain improvements to the context in which transactions are executed and not one of a technology or technological field.
Although the claims recite:
generating, by the server using a machine learning model trained on historical balance data and cash sweep data, forecasted sweeps based on trend data for the first account determining, by the server, a blend of predicted sweeps comprising unsettled transactions and the forecasted sweeps, wherein the blend is dynamically weighted based on elapsed time within a particular time period;
sending, from the server to the first device based on the selection and for display at the first user interface, first information for first expected sweeps received within a first time period, for the first account, second information for second expected sweeps for a second time period, for the first account,
the second time period for the first account comprising the blend of predicted sweeps and forecasted sweeps, and third information for reconciled sweeps for the second time period, for the first account,
wherein at least one of the first expected sweeps or the second expected sweeps include a first portion of expected sweeps which are automatically initiated by a first service; wherein the first device displays via the first user interface the first information, the second information, and the third information;
in response to detecting an anomaly between the second information and the third information in the first account, the anomaly indicating a discrepancy between the second information and the third information, providing an indication of the discrepancy to the first device, and when the discrepancy exceeds a threshold, causing the first device to display at the first user interface an icon in a first location of the first user interface in contextual relation to a second location corresponding to the first account; thereby reducing network resource consumption by consolidating balance information at a central location to reduce balance requests to multiple account servers; and
and a bare assertion of an improvement is made, the necessary detail on how the machine learning is executed has to be apparent to a person of ordinary skill in the art. However, absent is support (explanation) for how the identified improvement to machine learning technology is executed. As recited it suggests a process similar to a feedback loop in which feedback is used to update the data fed the model.
These limitations suggests the checks and balances for transaction settlements that involve cash sweeps and the additional description of the conditions for the output, absent is any support for the claims as recited for how it is an improvement to the computer or technical field beyond automating the sweep and settlement process.
In particular, there is a lack of improvement to a computer or technical field of accessing the data because the data processing performed merely uses a system as a tool to perform an abstract idea- see MPEP 2106.05(f). Therefore, the claims are directed to an abstract idea. The invention as claimed recites a generic computer component and the claim does not pass step 2A, Prong Two.
Step 2B; The next step is to identify any additional limitations beyond the judicial exception. The additional elements are computer device which is disclosed in the specification at a high degree of generality. Absent is any genuine issue of material fact that this component requires any specialized hardware or inventive computer component.
Likewise, the dependent claims 4-9, 13-15 and 17-24 are rejected under 35 U.S.C. § 101. For example, claims 4-9 provide descriptive details of what types of information are used in processing the sweeps in light of the settlement request and describes conditions for executing the request. These claim limitations recite steps at a high level of generality and performed in a traditional manner and therefore do not integrate the abstract idea into a practical application or provide an inventive concept.
Independent claims 1, 10 and 16 are rejected under 35 U.S.C. § 101 including dependent claims 4-9, 13-15 and 17-24 which fall with claims 1, 10 and 16. Therefore, claims 1, 4-10 and 13-24 are not patent eligible under 35 USC 101.
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, 4-10 and 13-24 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (abstract idea) without significantly more.
The claim recites abstract idea of organizing human activities. This judicial exception is not integrated into a practical application and the claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Analysis
The claims are directed to one or more of the following statutory categories: a process, a machine, a manufacture, and a composition of matter.
A method comprising:
sending, from a server to a first device, balance information for a plurality of accounts of an organization, the first device displaying the balance information at a first user interface;
receiving, by the server, an indication of a selection of a first account of the plurality of accounts;
generating, by the server using a machine learning model trained on historical balance data and cash sweep data, forecasted sweeps based on trend data for the first account determining, by the server, a blend of predicted sweeps comprising unsettled transactions and the forecasted sweeps, wherein the blend is dynamically weighted based on elapsed time within a particular time period;
sending, from the server to the first device based on the selection and for display at the first user interface, first information for first expected sweeps received within a first time period, for the first account, second information for second expected sweeps for a second time period, for the first account,
the second time period for the first account comprising the blend of predicted sweeps and forecasted sweeps, and third information for reconciled sweeps for the second time period, for the first account,
wherein at least one of the first expected sweeps or the second expected sweeps include a first portion of expected sweeps which are automatically initiated by a first service; wherein the first device displays via the first user interface the first information, the second information, and the third information;
in response to detecting an anomaly between the second information and the third information in the first account, the anomaly indicating a discrepancy between the second information and the third information, providing an indication of the discrepancy to the first device, and when the discrepancy exceeds a threshold, causing the first device to display at the first user interface an icon in a first location of the first user interface in contextual relation to a second location corresponding to the first account; thereby reducing network resource consumption by consolidating balance information at a central location to reduce balance requests to multiple account servers; and
in further response to detecting the anomaly in the first account
causing the first service to schedule an automated action to resolve the anomaly, reporting the automated action to the first device via the icon displayed at the first user interface,
wherein upon selection of the icon at the first device, the reporting of the automated action is displayed on the first user interface at the first device or
not causing the first service to schedule the automated action to resolve the anomaly, wherein upon selection of the icon at the first device, causing one or more suggested actions [[are]] to be displayed on the first user interface to resolve the anomaly,
receiving an input from the first device indicating a selected action of the one or more suggested actions to resolve the anomaly and
causing the selected action to be performed by the first service responsive to receiving the input.
Taking the broadest reasonable interpretation, the invention (as recited in claims 1, 4-10 and 13-24) is directed towards an a method of organizing human activity that is a commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations) or and a fundamental economic practice of management of cash sweeps used in settlement of financial transactions(see App. Spec. paras. 0029-0030).
Besides reciting the abstract idea, the remaining claim limitations recite generic computer components (e.g. processor; see App. specification, paras. 0024-0028; Fig. 1). This recited abstract idea is not integrated into a practical application. In particular, the claim only recites generic computer components to execute the steps. The additional elements are recited at a high-level of generality such that they amount to 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. Therefore, the claim is directed to an abstract idea.
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, the additional elements - (e.g. processor) amount to no more than mere instructions to apply the abstract idea using generic computer components.
Dependent claims 4-9, 13-15 and 17-24 provide additonal details about the different step and how the predefined rules are applied to the evaluation process. For example, claims 4-6 describe the type of information and the sequence of additional types of steps used as part of the account management process and do not address the issues raised in the independent claims and therefore do not amount to a technical improvement or an integration of a practical application.
In conclusion, merely “applying” the exception using generic computer components cannot provide an inventive concept. Therefore, the claims 1, 4-10 and 13-24 are not patent eligible under 35 USC 101.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure:
Ahn, USP Pub. No. 20120191579 (Selective Processing Of Reverse Invoices In Computer Systems For Financial Transactions)
Ackley, USP Pub. No. 20130103576(Transaction Management System And Method)
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/CHIKAODINAKA OJIAKU/Primary Examiner, Art Unit 3696
1 Interval Licensing, 896 F.3d at 1344–45 (concluding that ‘‘[s]tanding alone, the act of providing someone an additional set of information without disrupting the ongoing provision of an initial set of information is an abstract idea,’’ observing that the district court ‘‘pointed to the nontechnical human activity of passing a note to a person who is in the middle of a meeting or conversation as further illustrating the basic, longstanding practice that is the focus of the [patent ineligible] claimed invention.’’); Voter Verified, Inc. v. Election Systems & Software, LLC, 887 F.3d 1376, 1385 (Fed. Cir. 2018) (finding the concept of ‘‘voting, verifying the vote, and submitting the vote for tabulation,’’ a ‘‘fundamental activity’’ that humans have performed for hundreds of years, to be an abstract idea);
In re Smith, 815F.3d 816, 818 (Fed. Cir. 2016) (concluding that ‘‘[a]pplicants’ claims, directed to rules for conducting a wagering game’’ are abstract).
14 If a claim, under its broadest reasonable interpretation, covers performance in the mind but for the recitation of generic computer components, then it is still in the mental processes category unless the claim cannot practically be performed in the mind. See Intellectual Ventures I LLC v. Symantec Corp., 838 F.3d 1307, 1318 (Fed. Cir . 2016) (‘‘[W]ith the exception of generic computer-implemented steps, there is nothing in the claims themselves that foreclose them from being performed by a human, mentally or with pen and paper.’’); Mortg. Grader, Inc. v. First Choice Loan Servs. Inc., 811 F.3d. 1314, 1324 (Fed. Cir. 2016)(holding that computer-implemented method for ‘‘anonymous loan shopping’’ was an abstract idea because it could be ‘‘performed by humans without a computer’’); Versata Dev. Grp. v. SAP Am., Inc., 793 F.3d 1306, 1335 (Fed. Cir. 2015) (‘‘Courts have examined claims that required the use of a computer and still found that the underlying, patent-ineligible invention could be performed via pen and paper or in a person’s mind.’’); CyberSource Corp. v. Retail Decisions, Inc., 654 F.3d 1366, 1375, 1372 (Fed. Cir. 2011) (holding that the incidental use of ‘‘computer’’ or ‘‘computer readable medium’’ does not make a claim otherwise directed to process that ‘‘can be performed in the human mind, or by a human using a pen and paper’’ patent eligible); id. at 1376 (distinguishing Research Corp. Techs. v. Microsoft Corp., 627 F.3d 859 (Fed. Cir. 2010), and SiRF Tech., Inc. v. Int’l Trade Comm’n, 601 F.3d 1319 (Fed. Cir. 2010), as directed to inventions that ‘‘could not, as a practical matter, be performed entirely in a human’s mind’’). Likewise, performance of a claim limitation using generic computer components does not necessarily preclude the claim limitation from being in the mathematical concepts grouping, Benson, 409 U.S.at 67, or the certain methods of organizing human activity grouping, Alice, 573 U.S. at 219–20 - – See Federal Register / Vol. 84, No. 4 / Monday, January 7, 2019