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 .
1 Applicant's amendment filed 07/14/2026 is entered. Claims 3, 7, 13, 19, and 21 are canceled. New claims 24 and 25 depending from claim 1 are added. Claims 1, 9, 17 and 20 are currently amended. Claims 1, 9, and 17 are independent claims. Claims 2,4-6, 8, 22-25 depend from claim 1, claims 10-12, 14-16 depend from claim 9, and claims 18 and 20 depend from claim 17. Claims 1-2, 4-6, 8, 9-12, 14-18, 20, 22-25 are pending for examination.
2. Telephone interview:
A telephone interview was conducted at the Applicant's request on 06/15/2026. The interview summary is reproduced below for ready reference:
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Issues Discussed:
35 U.S.C. 101
Examiner indicated that the suggested amendments are not sufficient to overcome 35 USC 101 rejection as they are generic computer functions and do not add any meaningful limits on practicing the abstract idea. No agreement reached. Future amendments, when submitted formally, will be subject to reconsideration and search.
35 U.S.C. 103
The suggested amendments to overcome the cited prior art in the Non-Final Rejection mailed 04/14/ 2026. Examiner indicated that the suggested new limitations of aggregating balances of stored value mediums in a single account or storing the stored value mediums in a table format and parsing the table data to identify the single account with the entity would require further consideration and search. No agreement reached. Future amendments, when submitted formally, will be subject to reconsideration and search.
Other
Copy of interview agenda is attached for ready reference. Applicant provided permission in written to communicate via email"
Claim Rejections - 35 USC § 101
3. 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 1-2, 4-6, 8, 9-12, 14-18, 20, 22-25 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more, when analyzed as per MPEP 2106.
Step 1 analysis:
Claims 1-2, 4-6, 8, 22-25 are to a system /apparatus, claims 9-12, 14-16 to a process comprising a series of steps, and clams 17-18 and 20 are to manufacture, which are statutory (Step 1: Yes).
Step 2A Analysis:
Claim 1 recites:
1. (Currently Amended) A system for managing a data store for stored value mediums, the system comprising: one or more memories; and one or more processors, coupled to the one or more memories, configured to:
(i) perform a risk analysis associated with a stored value medium by electronically analyzing information associated with the stored value medium, the information including at least one of entity information of an entity associated with the stored value medium, a transaction trend or pattern at the entity, a frequency of transactions at the entity, or expiration information associated with the stored value medium:
(ii) generate, based on the risk analysis, a risk score for the stored value medium, the risk score indicating a likelihood that the stored value medium is able to be used;
(iii) populate the data store with information associated with the stored value medium based on the risk score, wherein populating the data store comprises storing the information associated with the stored value medium in a table of the data store that links the information associated with the stored value medium to an entity identifier of the entity;
(iv) periodically monitor, by communicating with a backend system associated with the stored value medium, a resource balance and expiration information of the stored value medium, and update or remove the information in the table based on the resource balance or expiration status;
(v) receive an indication of an exchange associated with the entity identifier, wherein the exchange is associated with another medium that is distinct and separate from the stored value medium;
(vi) parse the table using the entity identifier to identify the information associated with the stored value medium; and
(vii) communicate, with a backend system, the identified information associated with the stored value medium to enable the exchange to be at least partially completed using an aggregated balance of resources corresponding to the identified information associated with the stored value medium.
Step 2A Prong 1 analysis: This part of the eligibility analysis evaluates whether the claim recites a judicial exception. As explained in MPEP 2106.04, subsection II, a claim “recites” a judicial exception when the judicial exception is “set forth” or “described” in the claim.
Claims 1-20 recite abstract idea.
The highlighted limitations of claim 1 comprising, “ (i) perform a risk analysis associated with a stored value medium by analyzing information associated with the stored value medium, the information including at least one of entity information of an entity associated with the stored value medium, a transaction trend or pattern at the entity, a frequency of transactions at the entity, or expiration information associated with the stored value medium: (ii)generate, based on the risk analysis, a risk score for the stored value medium, the risk score indicating a likelihood that the stored value medium is able to be used; (iii) populate the data store with information associated with the stored value medium based on the risk score, wherein populating the data store comprises storing the information associated with the stored value medium in a table of the data store that links the information associated with the stored value medium to an entity identifier of the entity;; (iv)periodically monitor, by communicating with a system associated with the stored value medium, a resource balance and expiration information of the stored value medium, and update or remove the information in the table based on the resource balance or expiration status; (vi) parse the table using the entity identifier to identify the information associated with the stored value medium; and (v) enable an exchange to be at least partially completed using an aggregated balance of resources corresponding to the information associated with the stored value medium.”, under their broadest reasonable interpretation, fall within the mental process groupings of abstract ideas because they cover concepts performed in the human mind, including observation, evaluation, judgment, and opinion. See MPEP 2106.04(a)(2), subsection III. That is, other than reciting “by one or more processors” nothing in the claim elements precludes the steps from practically being performed in the mind. For example, but for the “by the one or more processors” language, the claim encompasses a person looking at data collected of a stored value medium such as of a gift card and analyzing the same to calculate a risk score based on the analysis of information of a person owning the gift card, his transaction patterns, frequency of some specific purchase/transactions, and on knowing the amount and expiry date of the gift card and add/populate/store information related to the risk to the stored data in a tabular form so that the information can be linked to an entity in the table, and further periodically monitor the stored data of the gift card by personally communicating with the issuer of the gift card to collect all the information of the gift card including the balance, expiration date, and accordingly can update or remove information from the stored data. The human operator can further parse the data in the table by reading/observing the data in the table, extract necessary information related with stored value medium [gift card] and organize into a structured format in the table. The mere nominal recitation of by a processor does not take the claim limitations out of the mental process grouping. See MPEP 2106.04(a)(2) Abstract Idea Groupings [R-07.2022] II. MENTAL PROCESSES: claims do 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);
Thus, claim 1 with its dependent claims 2, 4-8, 21-23 recite “Mental Processes”.
The highlighted limitations of claim 1 comprising, “enable the exchange to be at least partially completed using an aggregated balance of resources corresponding to the identified information associated with the stored value medium, “under their broadest reasonable interpretation, amount to making a payment for a transaction using the available resources that is the amount available on a gift card [stored value medium] and fall within “Certain Methods of Organizing Human Activity” abstract idea. See MPEP 2106.04(a)(2), subsection II.
Since the limitations of the other two independent claims 9 and 17 recite similar limitations as claim 1, they are analyzed on the same basis as reciting “Mental Processes” and “Certain Methods of Organizing Human Activity” abstract ideas. Accordingly, independent claims 1, 9, and 17 with their dependent claims 2, 4-6, 8, 10-12, 14-16, 18, 20, 22-25 recite these abstract ideas. Under circumstances where the claim recites more than one types of abstract ideas, , however, the Supreme Court has treated such claims in the same manner as claims reciting a single judicial exception. (discussing Bilski v. Kappos, 561 U.S. 593 (2010)). Here, steps (1), (ii), fall within the mental process grouping of abstract ideas, and step (iii) falls within “Certain Methods of Organizing Human Activity grouping of abstract ideas. Limitations in all the three steps (i), (ii), and (iii) are considered together as a single abstract idea for further analysis. (Step 2A, Prong One: YES).
Step 2A Prong 2 analysis: This part of the eligibility analysis evaluates whether the claim as a whole integrates the recited judicial exception into a practical application of the exception or whether the claim is “directed to” the judicial exception. This evaluation is performed by (1) identifying whether there are any additional elements recited in the claim beyond the judicial exception, and (2) evaluating those additional elements individually and in combination to determine whether the claim as a whole integrates the exception into a practical application. See MPEP 2106.04(d).
Claims 1-20: The judicial exception is not integrated into a practical application.
Claim 1 recites the additional elements of using generic computer components comprising generic processors in communication with other generic computer devices and implementing the steps (i)perform a risk analysis associated with a stored value medium by electronically analyzing information associated with the stored value medium, the information including at least one of entity information of an entity associated with the stored value medium, a transaction trend or pattern at the entity, a frequency of transactions at the entity, or expiration information associated with the stored value medium: (ii)generate, based on the risk analysis, a risk score for the stored value medium, the risk score indicating a likelihood that the stored value medium is able to be used; (iii) populate the data store with information associated with the stored value medium based on the risk score, wherein populating the data store comprises storing the information associated with the stored value medium in a table of the data store that links the information associated with the stored value medium to an entity identifier of the entity; (iv)periodically monitor, by communicating with a backend system associated with the stored value medium, a resource balance and expiration information of the stored value medium, and update or remove the information in the table based on the resource balance or expiration status; (v) receive an indication of an exchange associated with the entity identifier, wherein the exchange is associated with another medium that is distinct and separate from the stored value medium; (vi)parse the table using the entity identifier to identify the information associated with the stored value medium; and; (v) communicate, with a backend system, the identified information associated with the stored value medium to enable the exchange to be at least partially completed using an aggregated balance of resources corresponding to the information associated with the stored value medium.
In limitations of steps (i), (ii), (iii), (iv) and (vi)) the computer processor(s) is used to perform an abstract idea, as discussed above in Step 2A, Prong One, such that it amounts to no more than mere instructions to apply the exception using a generic computer. See MPEP 2106.05(f). The limitations in steps (v) receive an indication of an exchange associated with the entity identifier, wherein the exchange is associated with another medium that is distinct and separate from the stored value medium; and (vii) ) communicate, with a backend system, the identified information associated with the stored value medium to enable the exchange to be at least partially completed using an aggregated balance of resources corresponding to the information associated with the stored value medium:' are mere data gathering and outputting/transmitting recited at a high level of generality, and thus are insignificant extra-solution activity. See MPEP 2106.05(g) (“whether the limitation is significant”). In addition, all uses of the recited judicial exceptions require such data gathering and output, and, as such, these limitations do not impose any meaningful limits on the claim. These limitations amount to necessary data gathering and outputting/transmitting. See MPEP 2106.05. Further, these limitations as recited are being performed by a computer recited at a high level of generality, and the computer is used as a tool to perform the generic computer function of receiving data. See MPEP 2106.05(f).
The limitations, " to enable the exchange to be at least partially completed using an aggregated balance of resources corresponding to the information associated with the stored value medium" in step vii are an intended function to be carried out on receiving the identified information and the exchange function of completion of a transaction using balances on a stored value of medium [corresponds to amount of money available on a credit card] which does not necessitate inextricable tie to computer technology because these steps can be carried out manually and is just performing the disembodied concept on a general purpose computer.
Accordingly, even when considered individually and in combination, these additional elements in claim 1 do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. The claim 1 is directed to an abstract idea. Since the limitations of the other two independent claims 9 and 17 recite similar limitations, they are analyzed on the same basis as directed to abstract idea.
Examiner has reviewed the dependent claims 2, 4-6, 8, 10-12, 14-16, 18, 20, 24,and 25. “They recite limitations merely expanding the scope of the limitations recited in their base claims including limitations receiving data, transmitting data, making certain determinations, updating balances, identifying data/information and displaying data directed to insignificant extra-solution activities, mental processes and steps which do not recite inextricable tie to computer technology because these steps can be carried out manually. As such the limitations in these claims do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.” The dependent claims 2, 4-6, 8, 10-12, 14-16, 18, 20, and 24 are directed to an abstract idea.
Reference claim 22, the limitations are directed to removing information from stored data such as balance in gift card based on if resource balance is zero or expired which is updating the information and as already analyzed for claim1 is a mental process.
Reference claim 23, it recites using a relational database for linking data with each other presented in a tabular form which is a long-standing practice of using before the effective date of the claimed invention and the claim limitations are not directed to an improvement in functioning of a relational database, and as such does not add any meaningful limitations on practicing the abstract idea.
Even when viewed individually and in combination, these additional elements in claims 1-2, 4-6, 8, 9-12, 14-18, 20, 22-25 do not integrate the recited judicial exception into a practical application because they do not impose any meaningful limits on practicing the abstract idea (Step 2A, Prong Two: NO), and the claim is directed to the judicial exception. (Step 2A: YES). Step 2A=Yes. Claims 1-2, 4-6, 8, 9-12, 14-18, 20, 22-25 are directed to abstract ideas.
Step 2B analysis: This part of the eligibility analysis evaluates whether the claim as a whole amounts to significantly more than the recited exception i.e., whether any additional element, or combination of additional elements, adds an inventive concept to the claim. See MPEP 2106.05.
The claims 1-2, 4-6, 8, 9-12, 14-18, 20, 22-25 do not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Since all pending claims are as per Step 2A are directed to an abstract idea, they have to be analyzed per Step 2B, if they recite an inventive step, i.e., the claims recite additional elements or a combination of elements that amount to “Significantly More” than the judicial exception in the claim. As discussed above with respect to Step 2A Prong Two, the additional elements in the claims 1-2, 4-6, 8, 9-12, 14-18, 20, 22-25 amount to no more than mere instructions to apply the exception using a generic- computer components, and generally linking the judicial exception to a particular technological environment or field of use. The same analysis applies here in 2B, i.e., mere instructions to apply the exception using a generic- computer components, and generally linking the judicial exception to a particular technological environment or field of use using a generic- computer components cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B.
Additional elements directed to the limitations of communicating information on the balance of the stored value medium to conduct an exchange transaction, receiving indication of an exchange, receiving request, transmitting data, displaying data and storing data were found to be insignificant extra-solution activity in Step 2A, Prong Two, because they were determined to be insignificant limitations as necessary data gathering/transmitting/outputting/ displaying/ presenting/storing data. However, a conclusion that an additional element is insignificant extra-solution activity in Step 2A, Prong Two should be re-evaluated in Step 2B. See MPEP 2106.05, subsection I.A. At Step 2B, the evaluation of the insignificant extra-solution activity consideration takes into account whether or not the extra-solution activity is well understood, routine, and conventional in the field. See MPEP 2106.05(g). The background of the example does not provide any indication that the computer components are anything other than a generic, off the shelf computer component and the Symantec, TLI, OIP Techs, Versata court decisions cited in MPEP 2106.05(d) (ii) indicate that mere data gathering/ transmitting/ outputting/displaying /presenting/ data steps using a generic computer are well-understood, routine, conventional function when they are claimed in a merely generic manner (as it is here). Accordingly, a conclusion that the receiving, acquiring, transmitting, and displaying steps are well-understood, routine conventional activities are supported under Berkheimer Option 2. See MPEP 2106.05 (f) 2: Whether the claim invokes computers or other machinery merely as a tool to perform an existing process. Use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) or simply adding a general-purpose computer or computer components after the fact to an abstract idea (e.g., a fundamental economic practice or mathematical equation) does not integrate a judicial exception into a practical application or provide significantly more. See Affinity Labs v. DirecTV, 838 F.3d 1253, 1262, 120 USPQ2d 1201, 1207 (Fed. Cir. 2016) (cellular telephone); TLI Communications LLC v. AV Auto, LLC, 823 F.3d 607, 613, 118 USPQ2d 1744, 1748 (Fed. Cir. 2016) (computer server and telephone unit).
Even when considered individually and in combination, the additional elements in claims 1-2, 4-6, 8, 9-12, 14-18, 20, 22-25 represent mere instructions to implement an abstract idea or other exception on a computer and insignificant extra-solution activity, which do not provide an inventive concept. (Step 2B: NO).
Thus, pending claims 1-2, 4-6, 8, 9-12, 14-18, 20, 22-25 are patent ineligible.
4. Prior art discussion:
Reference independent claim 1, the best prior art cited Blackhurst et al. [US 20140101044 A1], hereinafter Blackhurst in view of Ramsey et al. [US 20060178982 A1], hereinafter Ramsey cited In the Non-Final Rejection mailed 04/14/2026, neither teaches nor renders at least the limitations, as a whole, comprising "one or more processors to generate, based on the risk analysis, a risk score for the stored value medium, the risk score indicating a likelihood that the stored value medium is able to be used, populate the data store with information associated with the stored value medium based on the risk score, wherein populating the data store comprises storing the information associated with the stored value medium in a table of the data store that links the information associated with the stored value medium to an entity identifier of the entity, receive an indication of an exchange associated with the entity identifier, wherein the exchange is associated with another medium that is distinct and separate from the stored value medium, parse the table using the entity identifier to identify the information associated with the stored value medium; and communicate, with a backend system, the identified information associated with the stored value medium to enable the exchange to be at least partially completed using an aggregated balance of resources corresponding to the identified information associated with the stored value medium". Claims 2, 4-6, 8, 22-25 depend from claim 1. The other two independent claims 9 and 17 recite similar limitations as claim 1 and based on same analysis are not subject to prior art rejection. Claims 10-12, 14-16 depend from claim 9, and claims 18 and 20 depend from claim 17.
5. The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
NPL references:
(i) . E. Turkson, E. Y. Baagyere and G. E. Wenya, "A machine learning approach for predicting bank credit worthiness," 2016 Third International Conference on Artificial Intelligence and Pattern Recognition (AIPR), Lodz, Poland, 2016, pp. 1-7 retrieved from IP. COM on 04092026 describes cited in the Non-Final Rejection mailed 04/14/2026, see page 81, banks implementing data mining to extract knowledge on data patterns of the users to evaluate risk and identify a risk score and also using the features such as occupation, age, marital status, salary range/amount of equity, credit history, etc. is an important step that banks go through before giving credit to customers.
(ii) Article, “Allowing Maximal Online Usage of Gift Cards”; publication Date 2015-Mar-24; Country Undisclosed; Publishing Source: The IP.com Journal; Publishing Venue IP.com PAD; Language English (United States) retrieved from IP. Com on 11/25/2025 cited in the Final Rejection mailed 12/02/2025 ; hereinafter Gift Cards, teaches monitoring [which can include periodically or active] of the Gift cards [[corresponds to the store value medium] describes allowing users to purchase products using gift cards and monitoring their balance and expiration information [ See the one p[age article, “ Maximal Online Usage Of Gift Cards E-commerce allows purchasing of products displayed on websites by manually selecting desired products, such that products are paid for by financial information stored on a website server and subsequently products are shipped to user preferred locations. The stores information service, based on the user’s entry of all information of a gift card including card number, total money value, card expiry date and type of the card, automatically selects an appropriate product that matches with a complete value of the user's gift card(s), or at least a nearly complete value. The store service continuously monitors continuously monitored and matched with various products that are available for sale on various websites. When a match is determined, the method and system automatically selects one or more products and processes the payment without requiring any user intervention. The method and system notify the user to minimally exceed the value of gift card(s) so that the minimally exceeded value of the gift card(s) is matched with the cost of any product available on a website, allowing complete usage of the gift card(s), without wasting any left-over money value in the card(s). The article describes that the process can be executed by an embodiment combining software and hardware aspects with a computer program product embodied in one or more computer readable medium(s) having computer readable program code embodied thereon.
(iii) Skeen et al. [US 20210174384 A1; see para 0037] describes storing stored value medium such as a gift card's data/information within a Gift Card table 302, wherein the Gift Card data can include for each Gift Card entry, for example, a Gift Card number or a digital electronic certificate (e-certificate) number, a Gift Card value, a membership or customer number of the Gift Card purchaser, a first and last name of the member that purchased the gift card, a first and last name of the individual receiving the gift card, an authorization number, a Personal Identification Number (PIN), the incentive redemption offer, the Business Partner products and services associated with the Gift Card, etc..
(iv) Nagula et al. [US 2019/0213623 A1 cited in the Non-Final Rejection mailed 04/14/2026; see para 0016 and 0070] describes analyzing a plurality of transactions related to credit/debit card data, wherein each transaction includes information of a customer ID, time periods when purchases occurred, items decryption, type of merchants, one of a plurality of spending levels, and performing sequence pattern mining on the transactions to determine a spending category of items so that coupons can be issued for that category of item at a predicted time.
(v) Clore [US 20030074290 A1 cited in the Non-Final Rejection mailed 07/30/2025; see para 0056] describes performing a risk analysis on customer’s financial history including a risk assessment on the status of the customer’s credit card account and based upon that an approval for repayment can be denied.
(vi) Wisniewski et al. [US 20110295744A1 cited the IDS filed 12/19/2023 and also in the Non-Final Rejection of the parent application 17/302,216 mailed 07/14/2023; see para 0010] discloses that balances from multiple merchant specific cards can be aggregated to the balance of the universal gift card in a similar manner to further increase the balance of the universal gift card so that the owner of the universal gift card can then use the aggregated balance to purchase an item from a participating merchant.
(vii) Glass et al. [US 10, 217, 107 B2; see claim 1] describes a gift card activation system including a kiosk comprising receiving, from the user, monetary amount information , payment information to be associated with the selected gift card from the kiosk, facilitate a financial transaction with a financial account server associated with an account of the user to provide payment for the gift card by identifying, using a lookup table, a preferred third party gift card activation server that is configured to activate the gift card for a merchant of the gift card,
Foreign reference:
(viii) GB 2406185 cited the IDS filed 12/19/2023 and also in the Non-Final Rejection of the parent application 17/302,216 mailed 07/14/2023; discloses first storage means for storing at least one value identifier associated with a monetary value; second storage means for storing at least one on-line account record, said at least one stored on-line account record including an account record identifier and an account balance; first input means for receiving a value identifier, second input means for receiving an account record identifier, and control means for transferring a monetary value associated with said at least one stored value identifier to an account balance of said at least one stored on- line account record responsive to a match between a received value identifier and said at least one stored value identifier, and a received account record identifier and said at least one stored on-line account record.
6. Note: Allowability: If the independent claims 1, 9, and 17 are amended to overcome 35 USC 101 rejection, the instant application can be placed in condition for allowance subject to reconsideration of amendments.
Response to Arguments
7.1. Rejection of pending claims under 5 USC 103:
Applicant’s arguments, see pages 20-21, filed with respect to the rejection(s) of independent claims 1, 9, and 17 have been fully considered and are persuasive in view of the current amendments to the claims 1, 9, and 17. Therefore, the rejection has been withdrawn.
7.2 Rejection under 35 USC 101:
Applicant's arguments filed 02/05/2026, see pages 11-18 have been fully considered but they are not persuasive.
Step 2A, Prong One:
Examiner disagrees with the Applicant’s arguments, see pages 14-15 that the claims do not recite a mental process and certain methods of organizing human activity groupings of abstract idea, because as per Step 2A, Prong One, the claims do “set forth” and “describe” an abstract idea. Step 2A, Prong One part of the eligibility analysis evaluates whether the claim recites a judicial exception. As explained in MPEP 2106.04, subsection II, a claim “recites” a judicial exception when the judicial exception is “set forth” or “described” in the claim. The limitations, , “ (i) perform a risk analysis associated with a stored value medium by analyzing information associated with the stored value medium, ……..: (ii)generate, based on the risk analysis, a risk score for the stored value medium, ……; (iii) populate the data store with information associated with the stored value medium based on the risk score, wherein populating the data store comprises storing the information associated with the stored value medium in a table of the data store that links the information associated with the stored value medium to an entity identifier of the entity;; (iv)periodically monitor, by communicating with a system associated with the stored value medium, …..; (vi) and parse the table using the entity identifier to identify the information associated with the stored value medium;"; under their broadest reasonable interpretation, do "set forth" the mental process groupings of abstract ideas because they cover concepts performed in the human mind, including observation, evaluation, judgment, and opinion. See MPEP 2106.04(a)(2), subsection III. As analyzed above, for example, but for the “by the one or more processors” language, the claim encompasses a person looking at data collected of a stored value medium such as of a gift card and analyzing the same to calculate a risk score based on the analysis of information of a person owning the gift card, his transaction patterns, frequency of some specific purchase/transactions, and on knowing the amount and expiry date of the gift card and add/populate/store information related to the risk to the stored data in a tabular form so that the information can be linked to an entity in the table, and further periodically monitor the stored data of the gift card by personally communicating with the issuer of the gift card to collect all the information of the gift card including the balance, expiration date, and accordingly can update or remove information from the stored data. The human operator can further parse the data in the table by reading/observing the data in the table, extract necessary information related with stored value medium [gift card] and organize into a structured format in the table. The mere nominal recitation of by a processor does not take the claim limitations out of the mental process grouping. See MPEP 2106.04(a)(2) Abstract Idea Groupings [R-07.2022] II. MENTAL PROCESSES: claims do 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).
The imitations of claim 1 comprising, “enable the exchange to be at least partially completed using an aggregated balance of resources corresponding to the identified information associated with the stored value medium, “do amount to making a payment for an exchange transaction using the available resources that is the amount available on a gift card [stored value medium] and fall within “Certain Methods of Organizing Human Activity” abstract idea. See MPEP 2106.04(a)(2), subsection II.
Therefore, claim 1 does "set forth" and "describe" Mental Processes" and Certain Methods of organizing Human Activity" groupings of abstract ideas.
Step 2A, Prong Two:
Examiner disagrees with the Applicant’s arguments, see pages 16-17, that the “The claims are integrated into a Practical Application”, because, when the additional elements in claim 1 are considered individually and in combination as per Step 2A, Prong Two, they do not integrate the abstract idea because they do not add any meaningful limits on practicing the abstract idea and as such are directed to the abstract idea. Claim 1 recites the additional elements of one or more generic processors implementing a sequence of steps steps: "(i)perform a risk analysis associated with a stored value medium … (ii)generate, based on the risk analysis, a risk score for the stored value medium, ….(iii) populate the data store with information associated with the stored value medium based on the risk score, …. (iv)periodically monitor, by communicating with a backend system associated with the stored value medium, a resource balance and expiration information of the stored value medium, and update or remove the information in the table based on the resource balance or expiration status; (vi)parse the table using the entity identifier to identify the information associated with the stored value medium, ", which are performed by one or more computer processors recited at a high level of generality used to perform abstract idea, as discussed above in Step 2A, Prong One, such that it amounts to no more than mere instructions to apply the exception using a generic computer. See MPEP 2106.05(f). The additional elements steps (v) receive an indication of an exchange associated with the entity identifier, …….; and (vii) communicate, with a backend system, the identified information …..:' are mere data gathering and outputting/transmitting recited at a high level of generality, and thus are insignificant extra-solution activity. See MPEP 2106.05(g) (“whether the limitation is significant”). These limitations as recited are being performed by a computer recited at a high level of generality, and the computer is used as a tool to perform the generic computer function of receiving data. See MPEP 2106.05(f). The limitations, " to enable the exchange to be at least partially completed using an aggregated balance of resources corresponding to the information associated with the stored value medium" in step vii are an intended function to be carried out on receiving the identified information and the exchange function of completion of a transaction using balances on a stored value of medium [corresponds to amount of money available on a credit card] which does not necessitate inextricable tie to computer technology because these steps can be carried out manually and is just performing the disembodied concept on a general purpose computer. Though all these steps are performed in sequence, they when analyzed per Step 2A, Prong Two do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea, as analyzed above. The claim 1 is directed to an abstract idea. Since the limitations of the other two independent claims 9 and 17 recite similar limitations, they are analyzed on the same basis as directed to abstract idea.
Thus, the additional elements in the independent claims 1, 9, and 17 do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea and are not indicative of any of the following meaningful limits, see “MPEP 2106.04 (d):
• An additional element reflects an improvement in the functioning of a computer, or an improvement to other technology or technical field; See MPEP 2106.05(a).
• an additional element implements a judicial exception with, or uses a judicial exception in conjunction with, a particular machine or manufacture that is integral to the claim; See MPEP 2106.05(b).
• an additional element effects a transformation or reduction of a particular article to a different state or thing; see MPEP 2106.05(c).and
• an additional element applies or uses the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort
designed to monopolize the exception.29 an additional element implements a judicial exception with, or uses a judicial exception in conjunction with, a particular machine or manufacture that is integral to the claim; See MPEP 2106.05(e) and Vanda Memo.
Step 2B:
Examiner disagrees with the Applicant’s arguments, see pages 19-20, " The amended claims recite a specific, non-conventional combination of technical operations that go beyond generic data processing and address a concrete problem in electronic data management for stored value mediums", because when they are analyzed per Step 2B. Step 2B part of the eligibility analysis evaluates whether the claim as a whole amounts to significantly more than the recited exception i.e., whether any additional element, or combination of additional elements, adds an inventive concept to the claim. See MPEP 2106.05. As explained with respect to Step 2A, Prong Two, there are seven additional elements. The five additional elements in steps (i), (ii), (iii), (iv), (vi) of “using generic computers are at best mere instructions to “apply” the abstract ideas, which cannot provide an inventive concept. See MPEP 2106.05(f). The other two additional elements in steps (v) and (vii) were both found to be insignificant extra-solution activity in Step 2A, Prong Two, because they were determined to be insignificant limitations as necessary data gathering and outputting being performed by computers recited at a high level of generality which were further analyzed well-understood, routine, conventional activity. See MPEP 2106.05(d), subsection II.
Applicant’s comparison to DDR is not persuasive. IN DDR the patent at issue dealt with a problem unique to the Internet comprising Internet users visiting one web site might be interested in viewing products sold on a different web site, but the owners of the first web site did not want to constantly redirect users away from their web site to a different web site. The claimed solution used a series of steps that created a hybrid web page incorporating “look and feel” elements from the host web site with commerce objects from the third-party web site. The patent at issue in DDR provided an Internet-based solution to solve a problem unique to the Internet that (1) did not foreclose other ways of solving the problem, and (2) recited a specific series of steps that resulted in a departure from the routine and conventional sequence of events after the click of a hyperlink advertisement. The patent claims here do not address problems unique to the Internet, and instead, as analyzed above, are focused on business handling of stored value mediums rather than on a specific technical architecture including and mere generic data maintenance and communication. So, DDR has no applicability.
In view of the foregoing, rejection of pending claims 1-2, 4-6, 8, 9-12, 14-18, 20, 22-25 under 35 USC 101 is sustainable and maintained.
Conclusion
8. Final Rejection:
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to YOGESH C GARG whose telephone number is (571)272-6756. The examiner can normally be reached Max-Flex.
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/YOGESH C GARG/Primary Examiner, Art Unit 3688
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