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 .
DETAILED ACTION
Status of Claims
This action is in reply to the response filed on 9th of June 2026.
Claims 1-8 and 16-17 have been amended.
Claims 1-8, 16, and 17 are currently pending and have been examined.
Response to Arguments
Applicant's arguments filed 9th of June 2026 have been fully considered but they are not persuasive.
With regard to the limitations of claims 1-8, 16, and 17, Applicant argues that amended claim 1 does not recite an abstract idea because the claimed method involves “physical signaling among multiple devices” and most interactions do not require an institution member to perform any operation. The Examiner respectfully disagrees. The fact that the claimed steps are performed automatically by multiple computer devices does not remove the claim from the category of certain methods of organizing human activity. Applicant’s reliance on the absence of manual action by an institution member is not persuasive. An otherwise abstract commercial interaction does not cease to be an abstract idea merely because computers automate the steps that otherwise facilitate or administer the commercial transaction. Thus, the recitation that the electronic receipt is obtained “automatically without requiring an institution member to perform an operation” merely specifies automated implementation of the underlying reimbursement process rather than changing the character of the process itself.
With regard to the limitations of claims 1-8, 16, and 17, Applicant argues that the claim is integrated into a practical application because it involves multiple devices and represents “an improvement to the functioning of a computer, or other technology or technical field.” The Examiner respectfully disagrees. Applicant has not identified a claimed improvement to the operation of the computer or data=processing apparatus itself. The recited terminal device, data processing apparatus, electronic receipt, and application platform are used to carry out the reimbursement transaction by obtaining, matching, processing, and transmitting transaction-related information. In particular, claim 1 recites performing a binding process, determining a receipt obtaining manner, obtaining a matching electronic receipt, and returning the electronic receipt and trusted tamper-proof payment voucher to an application platform. These limitations describe what information is processed and where it is sent, but do not recite a particular improvement to computer architecture, computer operation, network operation, or another technological function. Merely implementing the reimbursement process using multiple devices does not, by itself, integrate the abstract idea into a practical application.
With regard to the limitations of claims 1-8, 16, and 17, Applicant argues that the “automatic binding process” solves the technical problem of preventing an institution member device from tampering with details of the target instructions. The Examiner respectfully disagrees. Although claim 1 states that the binding process is “to prevent tampering with a trusted tamper-proof payment voucher,” the claim does not recite a particular technical mechanism by which the alleged tampering is prevented. For example, the claim does not recite a particular authentication technique, encryption technique, cryptographic operation, security protocol, or other specific technological implementation for accomplishing the asserted tamper prevention.
With regard to the limitations of claims 1-8, 16, and 17, Applicant argues under Step 2B that the claimed binding process and automatic receipt-obtaining process amount to “significantly more” because they overcome two technical challenges and permit the process to remain “automatic/tamper-proof without involvement of the institution member.” The Examiner respectfully disagrees. The amended limitation requiring the receipt to be obtained “automatically without requiring an institution member to perform an operation” merely removes manual intervention form the process. Automation of the abstract commercial process, without a claimed technological improvement in how the computer performs the operation, does not itself provide an inventive concept. Similarly, directly returning the electronic receipt and payment voucher to the application platform “without requiring the application platform to exchange the electronic receipt with the data processing apparatus” changes the particular flow of information among the recited components, but the claim does not recite a technological improvement resulting from that arrangement beyond facilitating the reimbursement transaction itself.
With regard to the limitations of claims 1-8, 16, and 17, Applicant argues that independent claims 16 and 17 are patent eligible because they contain limitations similar to claim 1, and that dependent claims 2-8 are likewise eligible because they incorporate the limitations of their respective base claims and add additional features. The Examiner respectfully disagrees. Independent claims 16 and 17 substantially recite the same reimbursement processing limitations as claim 1. Also, the additional limitations of dependent claims 2-8 further defined the abstract idea mentioned in the rejection below. Therefore, the examiner will maintain the rejection.
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 1-8, 16, and 17 are rejected under 35 U.S.C. 101 because the claimed invention is directed to abstract idea without significantly more. The claims recite abstract idea of organizing human activities. This judicial exception is not integrated into a practical application and the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Analysis
First of all, claims are directed to one or more of the following statutory categories: a process, a machine, a manufacture, and a composition of matter. For claim 1, the claim recites an abstract idea of
“…performing a binding process between a reimbursement code and a first terminal device, the binding process being to prevent tampering with a trusted tamper-proof payment voucher during a trusted payment operation; determining a receipt obtaining manner corresponding to the trusted tamper-proof payment voucher, wherein the trusted tamper-proof payment voucher is generated after payment processing of a target transaction is performed based on a reimbursement code; obtaining, in the receipt obtaining manner…an electronic receipt that matches the trusted tamper-proof payment voucher automatically without requiring an institution member to perform an operation; and returning the electronic receipt and the trusted tamper-proof payment voucher directly to an application platform on which an institution to which the reimbursement code belongs is settled, to process the electronic receipt and the trusted tamper-proof payment voucher on the application platform without requiring the application platform to exchange the electronic receipt with the data processing apparatus.” This is an abstract idea of a certain method of organizing human activity, since it recites a commercial or legal interactions, namely processing electronic receipt and the payment voucher. Besides reciting the abstract idea, the remaining claim limitations recite generic computer components/processes (e.g., application platform, terminal device, data processing apparatus). “We conclude that claim 1 is “directed to a result or effect that itself is the abstract idea and merely invoke[s] generic processes and machinery” rather than “a specific means or method that improves the relevant technology.” Smart Sys. Innovations, LLC v. Chi. Transit Authority, 873 F.3d 1364, 1371
This recited abstract idea is not integrated into a practical application. In particular, the claim only recites generic computer components/processes (e.g., application platform, terminal device, data processing apparatus) to receive(obtain)/transmit data (extra-solution activities) and perform the abstract idea mentioned above. (See at least MPEP 2016.05(g): CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375 (Fed. Cir. 2011); buySafe, Inc. v. Google, Inc., 765 F.3d 1350, 1355 (Fed. Cir. 2014); OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015); Ultramercial, Inc. v. Hulu, LLC, 772 F.3D 709, 715 (Fed. Cir. 2014); Electric Power Group, LLC v. Alstom S.A., 830 F.3d 1350, 1354-55 (Fed. Cir. 2016); Intellectual Ventures I LLC v. Erie Indem. Co., 850 F.3d 1315, 1328-29 (Fed. Cir. 2017); Ameranth, 842 F.3d at 1245, 120 USPQ2d at 1857; Trading Technologies v. IBG LLC, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019)). The additional elements (e.g., application platform, terminal device, data processing apparatus) are recited at a high-level of generality such that they amount to no more than mere instructions to apply the exception using generic computer components or merely uses a computer as a tool to perform an abstract idea. Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Therefore, the claim is directed to an abstract idea.
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements - (e.g., application platform, terminal device, data processing apparatus) amount to no more than mere instructions to apply the abstract idea using generic computer components or merely uses a computer as a tool to perform an abstract idea. In conclusion, merely “applying” the exception using generic computer components cannot provide an inventive concept. Therefore, the claim is not patent eligible under 35 USC 101.
Again, the insignificant extra-solution activities mentioned above were re-evaluated in step 2B. The limitations do not amount to significantly more than the abstract idea because the courts found sending/receiving(obtaining) of data to be well understood, routine, and conventional activities. (See at least MPEP 2016.05(g): CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375 (Fed. Cir. 2011); buySafe, Inc. v. Google, Inc., 765 F.3d 1350, 1355 (Fed. Cir. 2014); OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015); Ultramercial, Inc. v. Hulu, LLC, 772 F.3D 709, 715 (Fed. Cir. 2014); Electric Power Group, LLC v. Alstom S.A., 830 F.3d 1350, 1354-55 (Fed. Cir. 2016); Intellectual Ventures I LLC v. Erie Indem. Co., 850 F.3d 1315, 1328-29 (Fed. Cir. 2017); Ameranth, 842 F.3d at 1245, 120 USPQ2d at 1857; Trading Technologies v. IBG LLC, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019)). Thus again, claims were not patent eligible under 35 USC 101.
Similar arguments can be extended to independent claims 16 and 17.
Dependent claims 2-8 have been given the full two-part analysis, analyzing the additional limitations both individually and in combination. The dependent claims when analyzed individually and in combination, are also held be patent ineligible under 35 U.S.C. 101.
For claim 2, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the determining a receipt obtaining manner corresponding to a payment voucher comprises: obtaining information about a transaction participant corresponding to the target transaction from the trusted tamper-proof payment voucher; determining, based on the information about the transaction participant, whether the transaction participant has activated an automatic receipt return service; and upon determining that transaction participant has activated an automatic receipt return service, determining that the receipt obtaining manner is a first obtaining manner; or upon determining that transaction participant has not activated an automatic receipt return service, determining that the receipt obtaining manner is a second obtaining manner.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 3, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the receipt obtaining manner is the first obtaining manner, and the obtaining, in the receipt obtaining manner, an electronic receipt that matches the payment voucher comprises: determining institution information of the institution to which the reimbursement code belongs; sending a first receipt obtaining request to the transaction participant based on the institution information and determined voucher identification information of the trusted tamper-proof payment voucher; receiving the electronic receipt and the voucher identification information that are sent by the transaction participant; and determining the received electronic receipt as the electronic receipt that matches the payment voucher corresponding to the voucher identification information; or receiving an electronic receipt and voucher identification information that are sent by the transaction participant of the target transaction; and determining the received electronic receipt as an electronic receipt that matches a trusted tamper-proof payment voucher corresponding to the voucher identification information, wherein the electronic receipt is generated based on a second receipt obtaining request sent by an institution member who initiates the target transaction, and the second receipt obtaining request comprises the voucher identification information.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 4, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the receipt obtaining manner is the second obtaining manner, and the obtaining, in the receipt obtaining manner, an electronic receipt that matches the trusted tamper-proof payment voucher comprises: receiving an electronic receipt sent by the transaction participant of the target transaction; performing matching processing on the electronic receipt and the payment voucher in a preset first matching manner; and upon determining that matching succeeds, determining the electronic receipt as the electronic receipt that matches the trusted tamper-proof payment voucher, wherein the electronic receipt is generated based on a third receipt obtaining request sent by an institution member who initiates the target transaction, and the third receipt obtaining request is sent by scanning an electronic receipt application code provided by the transaction participant of the target transaction.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 5, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the receipt obtaining manner is the second obtaining manner, and the obtaining, in the receipt obtaining manner, an electronic receipt that matches the payment voucher comprises: receiving a first association request sent by a first terminal device of an institution member who initiates the target transaction, wherein the first association request comprises an electronic receipt and voucher identification information, and the electronic receipt is obtained by the first terminal device from the transaction participant of the target transaction based on a receipt application operation of the institution member, or the electronic receipt is generated based on a paper receipt of the target transaction and is uploaded by the institution member; and determining the electronic receipt in the first association request as an electronic receipt that matches a trusted tamper-proof payment voucher corresponding to the voucher identification information.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 6, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the receipt obtaining manner is the second obtaining manner, and the obtaining, in the receipt obtaining manner, an electronic receipt that matches the payment voucher comprises: receiving a second association request sent by a first terminal device of an institution member who initiates the target transaction, wherein the second association request comprises an electronic receipt and voucher identification information, and the electronic receipt is not generated based on the target transaction and is uploaded by the institution member; obtaining a corresponding trusted tamper-proof payment voucher based on the voucher identification information; performing matching processing on the electronic receipt and the trusted tamper-proof payment voucher in a preset second matching manner; and upon determining that matching processing succeeds, determining the electronic receipt as the electronic receipt that matches the trusted tamper-proof payment voucher.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 7, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the returning the electronic receipt and the trusted tamper-proof payment voucher to an application platform on which an institution to which the reimbursement code belongs is settled comprises: sending, based on voucher information of the trusted tamper-proof payment voucher and receipt information of the electronic receipt, prompt information to the application platform on which the institution to which the reimbursement code belongs is settled; and upon determining that a specified request sent by the application platform is received, returning the electronic receipt and the trusted tamper-proof payment voucher to the application platform on which the institution to which the reimbursement code belongs is settled.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 8, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the sending, based on voucher information of the trusted tamper-proof payment voucher and receipt information of the electronic receipt, prompt information to the application platform on which the institution to which the reimbursement code belongs is settled comprises: establishing an association relationship between the electronic receipt and the trusted tamper-proof payment voucher at a preset first time interval based on receipt information of each electronic receipt and voucher information of a matching trusted tamper-proof payment voucher that are obtained in a corresponding first time interval; and sending, based on the association relationship, the prompt information to the application platform on which the institution to which the reimbursement code belongs is settled.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
Conclusion
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 extension fee 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 date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to EDWARD CHANG whose telephone number is (571)270-3092. The examiner can normally be reached M - F, 9-5.
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/EDWARD CHANG/Primary Examiner, Art Unit 3696 09/08/2026
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