DETAILED ACTION
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 .
This Office Action responds to the amendment and argument filed by applicant on December 10, 2025, in response to the Office Action mailed on September 10, 2025.
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 1–13 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., an abstract idea) without significantly more.
Under the 35 U.S.C. §101 subject matter eligibility two-part analysis, Step 1 addresses whether the claim is directed to one of the four statutory categories of invention, i.e., process, machine, manufacture, or composition of matter. See MPEP §2106.03. If the claim does fall within one of the statutory categories, it must then be determined in Step 2A [prong 1] whether the claim is directed to a judicial exception (i.e., law of nature, natural phenomenon, and abstract idea). See MPEP §2106.04. If the claim is directed toward a judicial exception, it must then be determined in Step 2A [prong 2] whether the judicial exception is integrated into a practical application. See MPEP §2106.04(d). Finally, if the judicial exception is not integrated into a practical application, it must additionally be determined in Step 2B whether the claim recites "significantly more" than the abstract idea. See MPEP §2106.05.
Examiner note: The Office's 2019 Revised Patent Subject Matter Eligibility Guidance (2019 PEG) is currently found in the Ninth Edition, Revision 10.2019 (revised June 2020) of the Manual of Patent Examination Procedure (MPEP), specifically incorporated in MPEP §2106.03 through MPEP §2106.07(c).
Step 1: Statutory Category
Claims 1–10 are directed to a process, claim 12 is directed to a machine (electronic device), and claim 13 is directed to a manufacture (non-transitory storage medium).
Accordingly, the claims fall within the statutory categories. The analysis proceeds to Step 2A.
Step 2A – Prong One (Judicial Exception)
Independent claim 1 recites: receiving a bill access request, determining a request category, collecting business payment bills, querying associated tickets, configuring ticket status based on results.
These limitations describe collecting, analyzing, and organizing financial/billing information, which falls within: Certain methods of organizing human activity since they are managing financial transactions, processing bills and tickets, categorizing and organizing user account data.
Mental processes since they recite determining categories, selecting bills based on rules, associating tickets, determining status
These steps can be performed mentally or with pen and paper, and thus constitute abstract ideas.
Step 2A – Prong Two (No Practical Application)
The claims do not integrate the abstract idea into a practical application.
Although the claims recite a “server,” “circuits,” “processor,” and “memory”, these are:
generic computer components, performing routine data processing functions
The claimed invention: does not improve computer functionality, does not improve another technology, does not apply the abstract idea in a meaningful technological way
Instead, it merely: uses a generic server to automate bill processing and ticket association
Such implementation is insufficient under Alice and Electric Power Group.
Step 2B – No Inventive Concept
The additional elements include:
• server
• processor
• memory
• circuits (category determining, list obtaining, ticket querying, status configuring)
These are well-understood, routine, and conventional (WURC) components.
The claims merely perform:
• data collection
• data analysis
• data organization
• result presentation
using generic computing elements.
Thus these claims are directed to:
organizing, processing, and displaying billing and ticket information using rules
This is a fundamental economic/business practice, implemented on generic computing components, without any technological improvement.
Accordingly:
Claims 1–13 are not patent-eligible under 35 U.S.C. §101.
Claim Rejections - 35 USC § 103
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 (i.e., changing from AIA to pre-AIA ) 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.
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
Claims 1–10, 12, and 13 are rejected under 35 U.S.C. 103 as being unpatentable over KITCHEN et al (US 6289322, hereinafter KITCHEN in view of PATEL et al. (US 20120084391, hereinafter PATEL and further in view of VENKATASUBRAMANIAN et al. (US 20060095373, hereinafter Venkatasubramanian)
With respect to claims 1, 12 and 13 KITCHEN discloses a method for processing bills including:
receiving at a server … a bill access request submitted by a user (see col. 6:10–20, describing user requests for bill presentment via a server)
collecting … a business payment bill … to obtain a bill list (see col. 7:5–25, describing retrieving billing information associated with a user account)
KITCHEN does not explicitly disclose determining a request category or associating tickets/receipts.
However, PATEL discloses: determining … a request category (see ¶ [0045]–[0048], describing categorization and filtering of receipts based on user selection criteria)
querying … a ticket associated with each business payment bill (see ¶ [0056]–[0062], describing associating receipts (tickets) with transactions and retrieving them based on user queries)
Further, Venkatasubramanian) discloses: “configuring … a ticket status … based on a query result” (see ¶ [0038]–[0045], describing updating invoice/payment status and routing based on processing results)
It would have been obvious to combine these reference cause all references relate to financial transaction processing systems. It was well known to integrate: bill presentment systems, receipt/ticket tracking systems, invoice status/workflow systems. Combining them would: improve data completeness, enhance tracking and reconciliation
provide better user-facing financial management interfaces. Such combination is a predictable use of known elements according to their established functions.
With respect to Claim 2 PATEL discloses: categorizing receipts/bills using user-defined labels and grouping criteria (see ¶ [0045]–[0048])
With respect to Claim 3 US20060095373A1 discloses:
processing invoices using forms and workflows (see ¶ [0025]–[0032])
prioritizing/routing invoices based on rules (see ¶ [0038]–[0045])
Claim 4 recites mapping form inputs to bill types and US20060095373A1 discloses:
mapping input fields to invoice categories (see ¶ [0028]–[0032])
Claim 5 recites filtering bills based on conditions (time, label, status) and PATEL discloses: filtering receipts based on time period, category, and user criteria (see ¶ [0047]–[0050])
Claims 6–7 recite: receiving tickets, associating tickets with bills
PATEL discloses: storing receipts associated with user identifiers linking receipts to transaction records (see ¶ [0056]–[0062])
Claim 8 recites updating ticket status based on whether a bill is in the list.
US20060095373A1 discloses: updating invoice status based on processing results
(see ¶ [0038]–[0045])
Claim 9 recites rendering a display page. KITCHEN discloses: presenting bill information to users via interface (see col. 8:10–25)
Claim 10 recites request category identifier in a payment application.
PATEL discloses: user selection inputs defining request types (see ¶ [0045]–[0048])
Response to Arguments
Applicant’s arguments with respect to pending claim(s) have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument.
Conclusion
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/ROKIB MASUD/ Primary Examiner, Art Unit 3627
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