DETAILED ACTION
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 office action. 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office Action has been withdrawn pursuant to 37 CFR 1.114.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 26 February 2026 has been entered.
Status of Claims
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
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 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.
This action is in reply to the remarks/arguments for Application 18/541,294 filed on 26 February 2026.
Claims 1, 10, and 12 have been amended.
Claims 1-20 are currently pending and have been examined.
Response to Arguments
A. Claim Rejections - 35 U.S.C. § 101:
Claims 1-20 stand rejected under 35 U.S.C. 101 on the basis that the claimed subject matter is directed to an abstract idea without significantly more.
1. Applicant argues that Step 2A: Prong II, the claims recite additional elements that amount to significantly more than the abstract idea.
Examiner respectfully disagrees. The judicial exception is not integrated into a practical application because, when analyzed under step 2A prong two, the additional elements of the claim such as a “processor”, “memory”, “display device”, represent the use of a computer as a tool (intermediary) to perform an abstract idea and/or does no more than generally apply the abstract idea to a particular field of use. Therefore, the additional elements do not integrate the abstract idea into a practical application as they do no more than represent a computer performing functions that correspond to (i.e. automate) implement the acts of using rules and/or instructions to implement a commercial-related interaction comprising the steps of merely transmitting (e.g., communicating, linking) data/information in a remote manner which is a fundamental and/or existing economic concept and/or practice.
Moreover, claiming the improved speed or efficiency inherent with applying the abstract idea on a computer does not provide a sufficient inventive concept, nor does claiming the improved speed or efficiency inherent with applying the abstract idea on a computer provide a sufficient inventive concept. See Bancorp Servs., LLC v. Sun Life Assurance Co. of Can., 687 F.3d 1266, 1278 (Fed. Cir. 2012) (“[T]he fact that the required calculations could be performed more efficiently via a computer does not materially alter the patent eligibility of the claimed subject matter.”); CLS Bank, Int’l v. Alice Corp., 717 F.3d 1269, 1286 (Fed. Cir. 2013) (en banc) aff’d, 134 S. Ct. 2347 (2014) (“[S]imply appending generic computer functionality to lend speed or efficiency to the performance of an otherwise abstract concept does not meaningfully limit claim scope for purposes of patent eligibility.” (citations omitted)). Applicant’s argument is therefore unpersuasive.
2. Applicant argues that the claimed systems and methods offer an improvement in computing technology and are therefore patent-eligible.
Examiner respectfully disagrees. There is no actual improvement made to the operations or physical structure of the additional elements claimed. There are no actual improvements to another technology or technical field, no improvements to the functioning of the computer itself, and there are no meaningful limitations beyond generally linking or applying the use of the abstract idea to a particular technological environment evident in the claims.
The computer-related device is recited at a high-level of generality and is merely invoked as a tool (intermediary) to perform the steps recited such that it amounts to no more than mere instructions to apply the exception using a computer-relate component. Simply implementing the abstract idea on a computer is not a practical application of the abstract idea. Moreover, nothing in the steps involve an improvement to the functioning of a computer or to any other technology, applying or using a judicial exception with, or, use of a particular machine, effecting a transformation or reduction of a particular article to a different state or thing aside from merely using a computer as a tool to perform an abstract idea while also generally linking the use of the judicial exception to a particular technological environment or field of use. As such, the additional element does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Applicant’s argument is therefore unpersuasive.
The rejection is therefore maintained.
B. Claim Rejections - 35 U.S.C. §§ 102/103:
Claim 10 stands rejected under 35 U.S.C. 102(a)(1) as being anticipated by Vineyard, IV et al., US 2024/0112179 A1 (“Vineyard”).
Claims 1-9 and 11-20 stand rejected under 35 U.S.C. § 103 as being unpatentable over Newsom, US 2022/0147957 A1(“Newsom”), in view of Vineyard, IV et al., US 2024/0112179 A1 (“Vineyard”).
Applicant’s arguments with regard to distinct differences between limitations of the instant application and the cited references have been considered and are persuasive. Accordingly, the rejection of the above claims on the grounds of 35 U.S.C. § 102 and § 103 is 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 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
In the instant case, representative method claim 12 is directed towards facilitating establishing and linking (integrating) an account associated with a financial institution with a separate entity. Claim 12 is directed to the abstract idea of using rules and/or instructions to implement a commercial-related interaction comprising the steps of merely transmitting (e.g., communicating, linking) data/information in a remote manner which is a fundamental and/or existing economic concept and/or practice grouped under the certain methods of organizing human activity – fundamental economic principles, practices or concepts; sales activity; following set of instructions; commercial or legal interactions (agreements in the form of contracts; business relations); managing interactions between people (including social activities, teachings, following rules or instructions) grouping, in step 2A prong one. Accordingly, for these reasons, the claim recites an abstract idea.
Claim 12 recites:
“following an occurrence of an enrollment event associated with a gaming establishment account of a user:
reducing a quantity of inputs received in association with creating an integrated bank account by a component of a banking institution operating independent of the processor by communicating identifying information associated with the user to the component of the banking institution, and
responsive to a creation, on behalf of the user, of an integrated bank account, linking, by a processor, the integrated bank account to the gaming establishment account of the user, wherein the creation of the integrated bank account is at least partially based on the identifying information communicated to the component of the banking institution.”
Based on the underlined elements above, abstract ideas and/or concepts are identified. Accordingly, the claim recites an abstract idea.
This judicial exception is not integrated into a practical application because, when analyzed under step 2A prong two, the additional elements of the claim such as a “processor”, “memory”, “display device”, represent the use of a computer as a tool (intermediary) to perform an abstract idea and/or does no more than generally apply the abstract idea to a particular field of use. Therefore, the additional elements do not integrate the abstract idea into a practical application as they do no more than represent a computer performing functions that correspond to (i.e. automate) implement the acts of using rules and/or instructions to implement a commercial-related interaction comprising the steps of merely transmitting (e.g., communicating, linking) data/information in a remote manner which is a fundamental and/or existing economic concept and/or practice.
When analyzed under step 2B, the claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception itself. Viewed as a whole, the combination of elements recited in the claims merely describe the concept of using rules and/or instructions to implement a commercial-related interaction comprising the steps of merely transmitting (e.g., communicating, linking) data/information in a remote manner which is a fundamental and/or existing economic concept and/or practice using computer computer-related technology and/or devices that merely perform as designed to function. Therefore, the use of these additional elements does no more than employ a computer as a tool to automate and/or implement the abstract idea, which cannot provide significantly more than the abstract idea itself (MPEP 2106.05(I)(A)(f) & (h)). Hence, claim 12 is not patent eligible.
Independent claim 1 recites substantially the same limitations as claim 12 above and is ineligible for the same reasons. The subject matter of claim 1 corresponds to the subject matter of claim 12 in terms of a system (e.g., machine). Therefore the reasoning provided for claim 12 applies to claim 1 accordingly.
In the instant case, representative method claim 10 is directed towards facilitating establishing and linking (integrating) an account associated with a financial institution with a separate entity. Claim 10 is directed to the abstract idea of using rules and/or instructions to implement a commercial-related interaction comprising the steps of merely transmitting (e.g., communicating, linking) data/information in a remote manner which is a fundamental and/or existing economic concept and/or practice grouped under the certain methods of organizing human activity – fundamental economic principles, practices or concepts; sales activity; following set of instructions; commercial or legal interactions (agreements in the form of contracts; business relations); managing interactions between people (including social activities, teachings, following rules or instructions) grouping, in step 2A prong one. Accordingly, for these reasons, the claim recites an abstract idea.
Claim 10 recites:
“a processor; and
a memory device that stores a plurality of instructions that, when executed by the processor responsive to a receipt of data requesting a creation of an integrated bank account to be maintained by a component of a distinct banking institution operating independent of the processor, cause the processor to:
determine whether a gaming establishment account exists in association with a user,
responsive to the gaming establishment account not existing in association with the user, communicate data that results in a display device displaying a request of a first set of identifying information associated with the user and needed by a component of a banking institution to create the integrated bank account on behalf of the user, and
responsive to the gaming establishment account existing in association with the user, reduce a quantity of inputs received in association with creating the integrated bank account on behalf of the user by:
communicating data that results in the display device displaying a request of a second set of identifying information associated with the user, and
requesting, from a gaming establishment component that maintains the gaming establishment account, a third set of identifying information associated with the user, wherein the second set of identifying information combined with the third set of identifying information comprises the first set of identifying information.”
Based on the underlined elements above, abstract ideas and/or concepts are identified. Accordingly, the claim recites an abstract idea.
This judicial exception is not integrated into a practical application because, when analyzed under step 2A prong two, the additional elements of the claim such as a “processor”, “memory”, “display device”, represent the use of a computer as a tool (intermediary) to perform an abstract idea and/or does no more than generally apply the abstract idea to a particular field of use. Therefore, the additional elements do not integrate the abstract idea into a practical application as they do no more than represent a computer performing functions that correspond to (i.e. automate) implement the acts of using rules and/or instructions to implement a commercial-related interaction comprising the steps of merely transmitting (e.g., communicating, linking) data/information in a remote manner which is a fundamental and/or existing economic concept and/or practice.
When analyzed under step 2B, the claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception itself. Viewed as a whole, the combination of elements recited in the claims merely describe the concept of using rules and/or instructions to implement a commercial-related interaction comprising the steps of merely transmitting (e.g., communicating, linking) data/information in a remote manner which is a fundamental and/or existing economic concept and/or practice using computer computer-related technology and/or devices that merely perform as designed to function. Therefore, the use of these additional elements does no more than employ a computer as a tool to automate and/or implement the abstract idea, which cannot provide significantly more than the abstract idea itself (MPEP 2106.05(I)(A)(f) & (h)). Hence, claim 10 is not patent eligible.
Dependent claims 2-9, 11, and 13-20 add further details and contain limitations that narrow the scope of the invention. However, these details do not result in significantly more than the abstract idea itself. As explained in the December 16, 2014 Interim Eligibility Guidance from the USPTO (in reference to the BuySAFE, Inc. v. Google, Inc. decision), further narrowing the details of an abstract idea does not change the § 101 analysis since a more narrow abstract idea does not make it any less abstract.
Viewed individually and in combination, these additional elements do not provide meaningful limitations to transform the abstract idea such that the claims amount to significantly more than the abstraction itself.
Accordingly, the present pending claims are not patent eligible and are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter.
Conclusion
The prior art(s) made of record and not relied upon is/are considered pertinent to Applicant's disclosure.
ANBAZHAGAN et al. (US 2023/0137728 A1) discloses a system and method for implementing single account and single wallet for distributed gaming system across jurisdictions. A distributed gaming system and methods for implementing a user experience in which a user maintains a single account
and single wallet for distributed gaming systems, including gambling systems, across multiple jurisdictions. A plurality of local databases and a universal database may each have account information associated with the user stored thereon. A geolocation service may detect the geographic location of a user device associated with the user. Upon detecting that the user device has moved from a first geographic location to a second geographic location, the a balance stored in a local database in the first geographic may be transferred to a local database in a second geographic location.
Claims 1-20 are rejected.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to Clifford Madamba whose telephone number is 571-270-1239. The examiner can normally be reached on Mon-Thu 7:30-5:00 EST Alternate Fridays.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Ryan Donlon, can be reached at 571-272-3602. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/CLIFFORD B MADAMBA/Primary Examiner, Art Unit 3692
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