DETAILED ACTION
This action is in response to the amendment received on May 27, 2026. The Examiner acknowledges that claims 1 & 12 were amended, no claims were canceled, and no claims were added. Therefore, claims 1-20 are currently pending.
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 § 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. The claims recite systems and methods for accounting of funds by managing redemption limitations of issued funds. These are fundamental economic practices of long standing and are methods of organizing human activities. In addition, the method can be performed by a human without the aid of a computer. Thus, the claims are drawn to an abstract idea.
This judicial exception is not integrated into a practical application because:
(a) It does not improve the functioning of a computer or to any other technology or technical field;
(b) Applying the judicial exception does not effect a particular treatment or prophylaxis for a disease or medical condition;
(c) Do not apply the judicial exception with, or by use of a particular machine;
(d) It does not effect a transformation or reduction of a particular article to a different state or thing;
(e) It does not apply or use the judicial exception in some other meaningful way beyond generally linking the use of the exception to a particular technological environment such that the claims as a whole are more than a drafting effort designed to monopolize the exception.
The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the systems and methods utilize generic computing elements as shown by Applicant’s specification at paragraphs 0089.
The system includes gaming establishment devices, ticket printers, processors, and memory, each of which appear to be generic computers performing generic computing functionality (e.g. data communication, storage, display, voucher issuance, etc.).
Regarding exemplary claim 1, the functionality of the system is a process of identifying when a service mode is enabled, determining if a voucher is issued and responsive to, managing the assignment of a redemption limitation to the voucher. The process is abstract and merely implemented by generic computing. The abstract idea can be carried out by a person without the aid of aid generic computing. A human can perform functions responsive to identifying that a gaming establishment device is in a service mode. A human can identify or observe the issuance of a voucher associated with an amount of funds. And, a human can communicate that the voucher is to be assigned a redemption limitation. The computing elements, as claimed are generic, per Applicant’s specification, as such the communication between generic computing elements (e.g. data storage, communication, and the like) is the conventional use of generic computers to carry out the abstract idea.
The dependent claims merely describe the data more specifically or specify the form the data takes. Data is abstract. Or, the dependent claims set forth specificities of the redemption limitations and further funds management (e.g. timing or basis of funds voucher issuance), each of which are similarly abstract. Therefore, the dependent claims cannot add “significantly more” to the abstract idea. Adding abstraction to abstraction cannot make the claims less abstract.
Currently, implementation of an abstract idea on generic computers is not patent-eligible without “significantly more.” Neither the abstract idea itself nor parts of the abstract idea can supply “significantly more” than the abstract idea. As written, current claims are drawn to an abstract idea with essentially the words “implement it” on a generic computer appended thereto. As such, the claims are not patent-eligible.
A thorough analysis or each and every limitation of each and every claim, both individually and as a part of an ordered combination shows that the claims are not patent-eligible under 35 USC §101, as none of the claims, provide a technological improvement over existing/conventional technology or a technical solution to a technical problem in order to set forth the abstract idea with the significantly more required.
Claim Rejections - 35 USC § 102
The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
A person shall be entitled to a patent unless –
(a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention.
Claims 1-20 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Shepherd et al. (U.S. Patent Application Publication No. 2023/0282064; hereinafter “Shepherd”).
Claims 1, 10, & 12: Shepherd discloses a system comprising:
a processor (paragraphs 0003, 0013, 0044-0051); and
a memory device that stores a plurality of instructions (paragraphs 0003, 0013, 0044-0051) that, when executed by the processor following an establishment of a service mode of a gaming establishment device which differs from any game play mode of the gaming establishment device and an occurrence of a ticket voucher request being received from the gaming establishment device operating in the service mode (paragraph 0027, wherein Shepherd, under a broadest reasonable interpretation discloses that a service mode is activated upon a player requesting a ticket, which causes a “service mode” to be initiated to send a ticket voucher request to the anti-money laundering system, the ticket voucher request being sent during the service mode in which the anti-money laundering system is providing a service to the EGM to interface with the EGM for security purposes, which is interpreted as differing from a game play mode, such as when a player is merely engaging in gameplay on the EGM), cause the processor to:
cause a ticket voucher associated with an amount of funds to be issued (paragraph 0027, wherein Shepherd discloses upon interfacing with the anti-money laundering system, a ticket voucher is issued or printed), and
communicate, to a component of a gaming establishment device management system, data associated with the issued ticket voucher, wherein the communication of data results in the issued ticket voucher being associated with a redemption limitation (paragraph 0027, wherein Shepherd discloses that after issuing the ticket voucher, data indicative of a redemption limitation as an update is communicated to, and stored at, the ticket voucher system (gaming establishment device), the update causing communication of data that results in the issued voucher being associated with the redemption limitation; additionally, Applicant is directed to paragraphs 0021-0043 that further detail relevant specific processes performed by the system pertaining to the anti-money laundering service mode that causes the EGM, ticket voucher system, and the anti-money laundering systems to interface with one another and communicate data that ultimately results in issued ticket vouchers being associated with redemption limitations).
Regarding claim 10, all of the above with respect to claim 1 applies, such that Shepherd discloses the system of claim 1 similarly performs the functions of: following enabling an identified gaming machine operator access to service the EGM (i.e. interfacing with the anti-money laundering system is interpreted as identified gaming machine operator access to service the EGM, wherein for security purposes, EGM identifiers are utilized for access to the anti-money laundering system, the identifiers enabling “an identified gaming machine operator” to access the service; see paragraph 0027), determining any printing of any ticket voucher by the ticket printer of the EGM and responsive to the printing of a ticket voucher associated with an amount of funds, communicating, to a component of a gaming establishment device management system (the ticket voucher system), data associated with the printed voucher and a redemption limitation associated with the printed ticket voucher (at least paragraph 0027, and further detailed in the specificity disclosed in at least paragraphs 0021-0043).
Regarding claim 12, all of the above with respect to claim 1 applies, such that Shepherd clearly discloses the same method which substantially corresponds to the functionality of the system as detailed above.
Claims 2-4, 11, & 13-15: Shepherd discloses that the redemption limitation comprises (i) a location where the issued ticket voucher may be redeemed for the amount of funds, (ii) a device that the issued ticket voucher may be redeemed at for the amount of funds, or (iii) an entity whom may redeem the issued ticket voucher for the amount of funds (paragraphs 0022-0023).
Claims 5 & 16: Shepherd discloses that the establishment of the service mode of the gaming establishment device occurs in association with gaming establishment personnel and the communicated data comprises data identifying the gaming establishment personnel (paragraph 0027, wherein a query to the anti-money laundering system, interpreted as the establishment of the service mode, includes identifiers such as an EGM identifier or an EGM asset number, interpreted as “gaming establishment personnel” and communicates the data comprising the information in the query).
Claims 6 & 17: Shepherd discloses that the ticket voucher is caused to be issued following manufactured funds being added to a credit balance of the gaming establishment device (paragraphs 0011 & 0014, wherein Shepherd discusses money laundering activities such as large quantities of bills being added to a credit balance of the EGM, the large quantities of bills interpreted as “manufactured funds”).
Claims 7 & 18: Shepherd discloses that the ticket voucher is caused to be issued following a meter of the gaming establishment device being reset (paragraph 0027, i.e. a ‘cashout event’ is interpreted as a ticket voucher being issued following a meter of the EGM being reset).
Claims 8 & 19: Shepherd discloses that the ticket voucher comprises a virtual ticket voucher (paragraphs 0019, 0033).
Claims 9 & 20: Shepherd discloses that the gaming establishment device comprises the EGM or electronic gaming machine as discussed above (figure 1[EGM 108]).
Response to Arguments
With regards to the 35 U.S.C. 101 rejection of claims 1-20, Applicant's arguments filed May 27, 2026 have been fully considered but they are not persuasive.
The claims are still directed to an abstract idea under Step 2A, Prong One. As explained in the maintained rejection, the claims recite systems and methods for accounting of funds by managing redemption limitations of issued funds, in the context of gaming devices and personnel, which are fundamental economic practices and methods of organizing human activity. The current independent claims are focused on: (i) enabling or recognizing a service/servicing context, (ii) issuing or printing a ticket voucher associated with an amount of funds, and (iii) controlling or assigning redemption limitations to that voucher, including who, where, and on which device it may be redeemed. These are representative examples of commercial/financial control schemes and managing personal behavior in a regulated environment.
Applicant argues that the claims cannot be performed “by a human without the aid of a computer” and cites MPEP § 2106.04(a)(2)(III), Enfish, and SRI. However, the identification of an abstract idea is not limited to processes literally executable entirely in the human mind. The “mental process” and “organizing human activity” groupings encompass concepts of rules, policies, and administrative schemes for economic and behavioral control, even when implemented with devices. The logical scheme here is fundamentally an accounting and anti-embezzlement policy, not a specific improvement to computer technology.
The new limitations in claims 1 and 12 including “following an establishment of a service mode of a gaming establishment device which differs from any game play mode of the gaming establishment device and an occurrence of a ticket voucher request being received from the gaming establishment device operating in the service mode” do not change that focus. They narrow the context in which the redemption-limitation scheme operates (service mode vs game play mode), but they still describe when the abstract funds-management rule is triggered, not a new technological mechanism or improvement in how the device or computer operates.
Under Step 2A, Prong Two, the additional elements do not integrate the exception into a practical application. The “service mode” limitation, the “ticket voucher request” limitation, and the recitation that communication of data “results in the issued ticket voucher being associated with a redemption limitation” specify the circumstances and outputs of applying the abstract accounting/security policy. Such as: when a service mode is active and a voucher is requested, the system issues the voucher and associates it with constraints on redemption, and communicates information to a management system. These are generic input/state/output operations implementing the abstract idea in a specific business environment (gaming devices and management systems). Under MPEP § 2106.05(f)–(h), such field-of-use restrictions and insignificant extra-solution activity (data gathering, processing, and communication) do not amount to integration into a practical application.
Applicant asserts that the “technical combination of elements introduces an unconventional functionality beyond previous capabilities” and provides enhanced security safeguards. However, the claimed components (gaming establishment devices, electronic gaming machines, ticket printers, processors, memory, and management systems) are described at a high level and used in their ordinary way to receive data, identify a mode, respond to a voucher request, issue a voucher, store/process associated data, and communicate that data. The alleged “enhanced security” is the result of applying the abstract rule (impose redemption limitations when vouchers are issued in service mode) rather than a technical improvement in the underlying machine or software. Thus, the claims remain directed to an abstract idea and do not integrate it into a practical application under Step 2A.
Enfish and SRI do not compel a different result. In Enfish, the court found claims non-abstract because they were directed to a specific self-referential table that improved how computers store and retrieve data. In SRI, the claims were directed to specific techniques for monitoring network traffic and detecting suspicious activity, improving computer network security. Here, no comparable improvement to computer or network technology is claimed. Rather, the claims recite automated enforcement of business rules using generic gaming/computing elements.
Under Step 2B, the claims similarly lack an inventive concept that amounts to “significantly more” than the abstract idea. Applicant suggests that elements such as “service mode differing from any game play mode,” “ticket voucher request,” and the association of redemption limitations are not generic or conventional and that the Office has not provided the factual support required under Berkheimer.
However, the Office previously identified that “gaming establishment devices, ticket printers, processors, and memory” are generic components performing generic functions, and pointed to the specification’s own description of these elements as such. The amended claims still recite these same components at a functional level. The new “service mode” and “ticket voucher request” language describes logical states and events within a gaming device’s standard operational modes (service versus game play), controlled by software and access credentials in a conventional manner. There is no indication in the claims or specification of any non-routine architecture, algorithm, or hardware structure for implementing service modes, handling voucher requests, or associating redemption constraints.
The “redemption limitation” itself that constrains where, on which device, or by whom a voucher may be redeemed is a business/operational policy, not a technical feature of the computer or gaming hardware. The claims do not recite any unconventional mechanism for enforcing these limitations beyond communicating data to a management system. As in Alice, merely automating a funds-management and access-control policy on generic computer components is insufficient to supply an inventive concept.
Applicant’s characterization of the claims as solving a “recognized problem with potential embezzlement activities” does not, by itself, establish eligibility. Many abstract ideas are framed as solutions to practical business problems. The relevant question is whether the claims offer a technical solution to a technical problem (as in Enfish or SRI) or instead claim a business/organizational solution implemented with conventional technology. Here, the claims fall in the latter category by implementing an accounting/audit rule for vouchers in a service mode, using known gaming devices, printers, processors, and management systems performing their ordinary functions.
When the abstract idea is set aside, the remaining elements of generic hardware and routine operations do not, individually or in combination, amount to “significantly more.” This applies equally to unamended independent claim 10, which still recites detecting printing of vouchers by a ticket printer and communicating related data and redemption limitations upon enabling access to service an EGM, and to the dependent claims, which further define data content or particular forms of redemption limitations.
For at least these reasons, the Examiner must respectfully maintain the 35 U.S.C. 101 rejection as set forth in the previous Office action and reproduced above.
With regards to the 35 U.S.C. 102(a)(1) rejection of claims 1-20 in view of Shepherd, Applicant's arguments filed May 27, 2026 have been fully considered but they are not persuasive.
Applicant asserts that “Shepherd does not include any service mode of the EGM (as such a mode of operation is described in the specification, understood by one of ordinary skill in the art, and claimed as differentiated from a game play mode)”. The Examiner respectfully disagrees and positions that based on a broadest reasonable interpretation as claimed Shepherd reasonably discloses a “service mode” that differentiates from a game play mode. Firstly, “service mode” is not defined to any specific constraints or definition as claimed. Secondly, the Examiner is unaware of any gaming arts recognized specific definition as to what must constitute a service mode. For instance, does this mode require a human operator to provide some special access to an EGM, or would remotely placing an EGM in a testing or diagnostic mode equate to a service mode. The specification itself does not appear to explicitly define or constrain “service mode” to any specificity. Thus, there appears to be no definition that universally or by specification detail provides a fixed meaning to “service mode” to foreclose a broadest reasonable interpretation. As such, based on a broadest reasonable interpretation, Shepherd discloses that a service mode is activated upon a player requesting a ticket, which causes a “service mode” to be initiated to send a ticket voucher request to the anti-money laundering system, the ticket voucher request being sent during the service mode in which the anti-money laundering system is providing a service to the EGM, which is interpreted as differing from a game play mode, such as when a player is merely engaging in gameplay on the EGM. For at least these reasons, the Examiner respectfully maintains Shepherd as applicable to the claims as presented based on a broadest reasonable interpretation without further specificity to the claimed invention.
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 MILAP SHAH whose telephone number is (571)272-1723. The examiner can normally be reached Monday - Friday, 9:30-6PM.
Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, KANG HU can be reached at 571-270-1344. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000.
/MILAP SHAH/Primary Examiner, Art Unit 3715
Prosecution Insights