DETAILED ACTION
This Non-Final Office action is in response to Applicant’s RCE filing on 02/02/2026. Claims 1-10, 12-14, 16-17 are pending. The effective filing date of the claimed invention is 05/25/2021.
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 .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 02/02/2026 has been entered.
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 1-10, 12-14, 16, and 17 are rejected under 35 U.S.C. 101 because the claims are directed to abstract idea.
Step 1 – Claims 1-14 relate to process claims; claim 16 relate to machine claim; and, claim 17 relates to a manufacture claim. Step 1 is satisfied.
Step 2A, Prong 1 – Exemplary claim 1 (and similarly claims 16 and 17) recites the abstract idea of:
obtaining a to-be-processed electronic ticket, order data, and bill data, wherein the bill data is generated after a payment is made for the order data by using a reimbursement code, and the electronic ticket is generated based on the bill data (see e.g. MPEP 2106.04(a)(2)(III)(A) citing Electric Power Group);
creating an editable reimbursement form based on at least one of the electronic ticket, the order data, and the bill data (see MPEP 2106.04(a)(2)(III)(C)(3) citing Mortgage Grader, for web-based user interface that provides for inputting data – pen and paper);
performing, by a reimbursement system (addressed as additional limitation in Step 2A, Prong 2; Step 2B analysis), credibility verification on the editable reimbursement form in at least one verification dimension based on the electronic ticket, the order data, and the bill data, wherein the credibility verification is further based on the at least one verification dimension being pairwise matched to element information associated with the editable reimbursement form, wherein the element information refers to a specific value in the at least one verification dimension for the pairwise matching to improve an accuracy and reduce false reimbursements by the reimbursement system, wherein the at least one verification dimension comprises a consumption amount (see MPEP 2106.04(a)(2)(II)(B) citing BuySAFE; see also Smart Sys. Innovations LLC v. Chi. Transit Auth, Appeal No 2016-1233 (Fed. Cir. 10/18/2017, finding similar limitations to be abstract idea1; further, for the pairwise matching, another term for this is pairwise comparison. This is a specific form of comparing/matching data. The matching/comparing data is part of the abstract idea. See MPEP 2106.04(a)(2)(II)(C) comparing printed votes, for instance, is managing personal behavior or relationships or interactions between people. The specificity of the “pairwise” matching, and the particulars as claimed, is further limiting the abstract idea, which is still just abstract idea. See MPEP 2106.04(II)(A)(2) See, e.g., RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327, 122 USPQ2d 1377 (Fed. Cir. 2017) (“Adding one abstract idea (math) to another abstract idea (encoding and decoding) does not render the claim non-abstract”; “A claim directed to an abstract idea does not automatically become eligible merely by adding a mathematical formula. See, e.g., Clarilogic, Inc. v. FormFree Holdings Corp., __ F. App'x __, 2017 WL 992528, at *3 (Fed. Cir. Mar. 15, 2017). As we explained above, claim 1 is directed to the abstract idea of encoding and decoding. The addition of a mathematical equation that simply changes the data into other forms of data cannot save it.”)); and
wherein the performing credibility verification on the editable reimbursement form in at least one verification dimension based on the electronic ticket, the order data, and the bill data comprises:
determining that element information of the editable reimbursement form, the electronic ticket, the order data, and the bill data in the at least one verification dimension pairwise matches (see e.g. MPEP 2106.04(a)(2)(III) 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);
MPEP 2106.04(a)(2)(III) C. A Claim That Requires a Computer May Still Recite a Mental Process), comprising
determining that reimbursement amount in the editable reimbursement form is less than or equal to the consumption amount in the electronic ticket, less than or equal to the consumption amount in the order data, and less than or equal to the consumption amount in the bill data (see id.),
determining that the consumption amount in the electronic ticket is less than or equal to the consumption amount in the order data, and less than or equal to the consumption amount in the bill data (see id.), and
determining that the consumption amount in the order data is greater than or equal to the consumption amount in the bill data (see id.);
upon determining that the element information of the editable reimbursement form, the electronic ticket, the order data, and the bill data in the at least one verification dimension pairwise matches, determining that the editable reimbursement form is a credible reimbursement form (see e.g. id.; MPEP 2106.04(a)(2)(III)(C)(1) citing Voter Verified; Smart Sys.; in other words, after making a determination, make another determination).
When viewed alone and in ordered combination (as a whole), these abstract idea limitations are found to recite abstract idea.
Step 2A, Prong 2 – Exemplary claim 1 (and similarly claims 16 and 17) does not integrate the recited abstract idea with practical application. Claim 1 recites the potential additional limitations of, e.g., verifying transactions (see e.g. MPEP 2106.05(g) citing CyberSource, verifying credit card transaction based on collected/known data, as mere data gathering). Claim 1 now recites where the performing credibility verification is done “by a reimbursement system.” The examiner has reviewed Applicant’s originally-filed Specification to determine what the reimbursement system is/how it should be interpreted under BRI, and how the reimbursement system works to perform the abstract idea identified above. The examiner found throughout the Specification that the reimbursement system broadly performs the functions of the abstract idea. In [0086] Applicant discloses “In a specific embodiment, the ticket processing device [of Fig. 6, for instance] is located in the above-mentioned reimbursement system, and the ticket processing device includes a processor and a storage configured to store computer-executable instructions. When the computer-executable instructions are executed by the processor, the processor is enabled to implement the following operations.” For the reimbursement system that performs the abstract idea, the examiner refers to MPEP 2106.05(f), “For claim limitations that do not amount to more than a recitation of the words “apply it” (or an equivalent), such as mere instructions to implement an abstract idea on a computer, examiners should explain why they do not meaningfully limit the claim in an eligibility rejection. For example, an examiner could explain that implementing an abstract idea on a generic computer, does not integrate the abstract idea into a practical application in Step 2A Prong Two or add significantly more in Step 2B, similar to how the recitation of the computer in the claim in Alice amounted to mere instructions to apply the abstract idea of intermediated settlement on a generic computer.” The examiner notes that merely performing a mental process with a computer is not sufficient to integrate with practical application. See MPEP 2106.04(a)(2)(III)(C)(1-3).
Claim 1, lines 9-12, now recites “wherein the at least one verification dimension is pairwise matched to data associated with the editable reimbursement form to improve an accuracy and reduce false reimbursements by the reimbursement system, wherein the at least one verification dimension comprises a consumption amount.” (emphasis added). The emphasis added shows Applicant’s alleged improvement to the technology. The examiner has reviewed Applicant’s originally-filed Specification and there is no description of how this is a technological improvement. See MPEP 2106.04(d)(1), “In short, first the specification should be evaluated to determine if the disclosure provides sufficient details such that one of ordinary skill in the art would recognize the claimed invention as providing an improvement. The specification need not explicitly set forth the improvement, but it must describe the invention such that the improvement would be apparent to one of ordinary skill in the art. Conversely, if the specification explicitly sets forth an improvement but in a conclusory manner (i.e., a bare assertion of an improvement without the detail necessary to be apparent to a person of ordinary skill in the art), the examiner should not determine the claim improves technology. Second, if the specification sets forth an improvement in technology, the claim must be evaluated to ensure that the claim itself reflects the disclosed improvement. That is, the claim includes the components or steps of the invention that provide the improvement described in the specification. The claim itself does not need to explicitly recite the improvement described in the specification (e.g., “thereby increasing the bandwidth of the channel”).” (see bolded language, where a bare assertion of an improvement, particularly a business improvement to the accuracy of data and reducing false reimbursement, is not an improvement to the underlying technology.
Further, for the improve an accuracy aspect, see MPEP 2106.05(f)(2) “claiming the improved speed or efficiency inherent with applying the abstract idea on a computer” does not integrate a judicial exception into a practical application or provide an inventive concept. Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 1367, 115 USPQ2d 1636, 1639 (Fed. Cir. 2015). Similarly here, Applicant has claimed where the matching limitation is performed “by a reimbursement system” and then recites at the “to improve an accuracy and reduce false imbursements by the reimbursement system.”
When viewed alone and in ordered combination (as a whole), these additional limitations are not found to integrate the recited abstract idea with practical application, thereby being directed to abstract idea.
Step 2B - Exemplary claim 1 (and similarly claims 16 and 17) does not recite significantly more. The additional limitation analysis from Step 2A, Prong 2 is equally applicable to Step 2B. In accordance with MPEP 2106.05(d), “Another consideration when determining whether a claim recites significantly more than a judicial exception is whether the additional element(s) are well-understood, routine, conventional [WURC] activities previously known to the industry. This consideration is only evaluated in Step 2B of the eligibility analysis.” For the WURC analysis, the examiner refers to MPEP 2106.05(d)(II) “Because examiners should rely on what the courts have recognized, or those of ordinary skill in the art would recognize, as elements that describe well‐understood, routine activities, the following section provides examples of elements that have been recognized by the courts as well-understood, routine, conventional activity in particular fields.” As for the current claim 1 and what the courts have found to be WURC, the claim limitation relating to performing credibility verification by the reimbursement system which includes at least matching various datum together, continuously, this is similar to where the courts found performing repetitive calculations to be WURC, citing Flook. Further, the limitations of claim 1 relating to obtaining the ticket and creating an editable form relates to i. Receiving or transmitting data over a network, e.g., using the Internet to gather data, Symantec (found to be WURC) and iii. Electronic recordkeeping, Alice Corp. (found to be WURC). Again, there aren’t many additional limitations or limitations that need to be analyzed under Step 2B WURC, but the examiner mentions these portions to cover the WURC analysis, and to refer to what the courts have found to be WURC.
When viewed alone and in ordered combination, these additional limitations are not found to include significantly more than the recited abstract idea.
Dependent Claims – Claim 2 recites more abstract idea. See MPEP 2106.04(a)(2)(III). Claim 3 recites more abstract idea, and transferring data to third party system. See MPEP 2106.04(a)(2)(III) for abstract idea; and, MPEP 2106.05(d)(II) The courts have recognized the following computer functions as well‐understood, routine, and conventional functions when they are claimed in a merely generic manner (e.g., at a high level of generality) or as insignificant extra-solution activity. i. Receiving or transmitting data over a network, e.g., using the Internet to gather data, Symantec, 838 F.3d at 1321, 120 USPQ2d at 1362 (utilizing an intermediary computer to forward information); TLI Communications LLC v. AV Auto. LLC, 823 F.3d 607, 610, 118 USPQ2d 1744, 1745 (Fed. Cir. 2016) (using a telephone for image transmission); OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1093 (Fed. Cir. 2015) (sending messages over a network); buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014) (computer receives and sends information over a network); but see DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d 1245, 1258, 113 USPQ2d 1097, 1106 (Fed. Cir. 2014) (“Unlike the claims in Ultramercial, the claims at issue here specify how interactions with the Internet are manipulated to yield a desired result‐‐a result that overrides the routine and conventional sequence of events ordinarily triggered by the click of a hyperlink.” (emphasis added)). Claim 4 recites more abstract idea. See MPEP 2106.04(a)(2)(II)(B). Claims 5-8 recite more abstract idea. See e.g. MPEP 2106.04(a)(2)(III)(D) citing Content Extraction; MPEP 2106.04(a)(2)(II)(B). Claim 9 recites more abstract idea. See e.g. MPEP 2106.04(a)(2)(II)(C)(ii) citing BSG. Claim 10 recites more abstract idea. See e.g. MPEP 2106.04(a)(2)(II)(C) citing Voter Verified. Claim 12 recites more abstract idea. See MPEP 2106.04(a)(2)(III). Claims 13-14 recite more abstract idea. See MPEP 2106.04(a)(2)(II)(C) citing IV I v. Capital One Bank; see MPEP 2106.04(a)(2)(III)(C)(3) citing Mortgage Grader for prompts on user interface.
Claims 1-10, 12-14, and 16-17 Are Distinguished Over the Prior Art
To be clear, the examiner was unable to find all of the amendments in a reasonable amount of references. Therefore, the examiner finds all claims to be distinguished over the prior art.
Response to Arguments
Applicant's arguments filed 01/08/2026 have been fully considered but they are not persuasive.
Applicant argues that the claims are eligible. Applicant argues that the claims are similar to the self-referential table found eligible in Enfish. The examiner respectfully disagrees. See one of the eligible claims in Enfish:
PNG
media_image1.png
382
448
media_image1.png
Greyscale
In Enfish, the Court found that
PNG
media_image2.png
140
446
media_image2.png
Greyscale
PNG
media_image3.png
200
451
media_image3.png
Greyscale
The current claims are not directed to any self-referential table, or any other table. The current claims recite a verification dimension being pairwise matched to element information. See Applicant’s originally-filed Specification at
[0054] In this embodiment, the verification dimension includes at least one dimension, and the verification dimension can include at least one of the following: a consumption time, a consumption amount, a commodity category, a commodity quantity, and a commodity name. The element information refers to a specific value in the verification dimension.
The verification dimension is a piece of data/category, and the element information is a specific value. This data is then pairwise matched through algorithm. This is all abstract idea performed in “apply it” manner “by a reimbursement system.”
All other arguments if any are not found to be persuasive.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to Peter Ludwig whose telephone number is (571)270-5599. The examiner can normally be reached Mon-Fri 9-5.
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, Fahd Obeid can be reached at 571-270-3324. 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.
/PETER LUDWIG/Primary Examiner, Art Unit 3627
1 See page 13, “, SSI argues that, because the ’003 and ’617 patents disclose inventions that “operate in the tangible world” and satisfy a public demand for more convenient travel that did not exist in the prior art, the patents’ claims are not directed to an abstract idea. Appellant’s Br. 38; see id. at 38–40. Moreover, SSI alleges that the ’390 and ’816 patents similarly do not concern an abstract idea because their claims “overcome challenges created by the storage limitations that exist with conventional tangible bankcards.” Id. at 42; see id. at 40−42. SSI’s arguments are unavailing. The Asserted Claims of the ’003 and ’617 patents involve acquiring identification data from a bankcard, using the data to verify the validity of the bankcard, and denying access to a transit system if the bankcard is invalid. See ’003 patent col. 14 l. 58–col. 15 l. 14 (claim 1), col. 15 l. 50–col. 16 l. 6 (claim. . . “
Page 14-15 – “SSI’s argument that the Asserted Claims are patent eligible because they improve prior systems of fare collection by speeding up the process at the turnstile is unavailing. We have found “that claims purporting to improve the functioning of the computer itself, or improving an existing technological process[,] might not succumb to the abstract idea exception.” Enfish, 822 F.3d at 1335 (internal quotation marks, brackets, and citation omitted). The question in such cases is “whether the focus of the claims is on the specific asserted improvement in computer capabilities” or whether “computers are invoked merely as a tool.”
Prosecution Insights