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 26, 2025 in response to the Office Action mailed on October 02, 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 1–10 are rejected under 35 U.S.C. § 101 because the claimed invention is directed to a judicial exception (i.e., an abstract idea) without reciting significantly more than the judicial exception itself.
The analysis below follows the 2024 USPTO Subject Matter Eligibility Guidance and the framework set forth in Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 573 U.S. 208 (2014), Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66 (2012), and MPEP § 2106.
Claims 1-4 are directed toward method (process) and claims 5-9 are directed towards system (apparatus) and claim 10 is directed towards product. Thus, all claims fall within one of the four statutory categories as required by Step 1.
Claim 1 is directed to a “data transfer and circulation method” involving blockchain certificates, supplier nodes, digital bills, smart contracts, transfer notifications, factoring requests, and financing operations.
Under Step 2A, Prong One, claim 1 recites certain methods of organizing human activity, business concept, including commercial or legal interactions, financial transactions, contractual relationships, credit transfers, financing arrangements, and managing interactions between suppliers and factor entities. Specifically, the claim recites obtaining blockchain certificates corresponding to supplier nodes, confirming user identities, generating completed work item digital bills, performing transfers among supplier nodes, generating credit transfer certificates, requesting factoring information, and providing financing based on enterprise situations. Such limitations describe fundamental economic practices and commercial interactions relating to supply-chain financing, credit circulation, invoice factoring, and financial risk management.
The claim additionally recites mental processes because the limitations involving verifying identities, confirming account information, determining whether transfer information is valid, generating financing decisions, and evaluating enterprise situations can practically be performed in the human mind or with pen and paper, albeit more quickly using generic computer technology. See MPEP § 2106.04(a)(2).
Accordingly, claim 1 recites abstract ideas falling within the “certain methods of organizing human activity”, “business concept” and “mental processes” groupings identified in the 2019 Revised Patent Subject Matter Eligibility Guidance.
Under Step 2A, Prong Two, the claim as a whole does not integrate the judicial exception into a practical application. The additional elements recited beyond the abstract idea include supplier nodes, a core enterprise node, a factor node, blockchain certificates, smart contracts, digital bills, and transfer notifications. However, these additional elements merely implement the abstract commercial and financing concepts using generic computer and network technology as tools.
The claim does not recite any improvement to computer functionality, blockchain architecture, cryptographic processing, database technology, or network communications. The recited “blockchain certificates,” “smart contracts,” “digital bills,” and “digital certificates” merely serve as data representations used to facilitate the underlying commercial financing activity. Likewise, the use of a “public blockchain” merely amounts to invoking a generic distributed ledger environment as a technological tool to execute the abstract business practice.
Further, the claim does not recite any particular machine integral to the claim, any transformation of an article to a different state or thing, or any technological improvement to distributed ledger systems. Instead, the claim merely uses generic computer components to automate longstanding commercial practices relating to supply-chain financing and credit assignment.
Therefore, claim 1 does not integrate the abstract idea into a practical application.
Under Step 2B, the claim does not include additional elements amounting to significantly more than the abstract idea itself. The additional elements are recited at a high level of generality and perform well-understood, routine, and conventional computer functions, such as obtaining data, sending data, verifying information, generating identifiers, processing requests, and providing financing information over a network.
The recitation of blockchain technology and smart contracts does not amount to significantly more because merely implementing an abstract business practice on a blockchain environment does not confer eligibility absent a specific technological improvement. See Alice, 573 U.S. at 223–26; see also MPEP § 2106.05(d).
Accordingly, claim 1 is directed to an abstract idea and does not include additional elements sufficient to amount to significantly more than the abstract idea itself. Therefore, claim 1 is not directed to patent-eligible subject matter.
Dependent claims 2–4 are rejected under 35 U.S.C. § 101 because the additional limitations merely further describe the abstract business and financial processes recited in claim 1 using mathematical concepts, data manipulation, encryption operations, and generic computer implementation.
Specifically, claim 2 recites generating blockchain certificates using randomly generated data, primitive root information, pseudo-anonymous identifiers, multivariate arrays, and timestamps. These limitations recite mathematical concepts and data manipulation techniques, including mathematical relationships, calculations, and cryptographic transformations. The claim merely uses these mathematical operations within the context of the abstract commercial financing process recited in claim 1.
Claim 3 similarly recites generating signature information, pseudo-anonymous identifiers, multivariate arrays, and completed work item digital bills based on smart contracts.
These limitations likewise amount to mathematical calculations, cryptographic processing, and manipulation of data structures performed in furtherance of the underlying abstract commercial financing activity.
Claim 4 recites encryption of account information, generation of protocol data, verification of transfer notifications, and generation of transfer digital certificates. These limitations similarly recite mathematical concepts and conventional cryptographic operations used to facilitate the abstract idea of financial transfers and credit circulation among supplier entities.
Under Step 2A, Prong Two, the additional cryptographic and mathematical limitations do not integrate the abstract idea into a practical application because the claims fail to recite any improvement to cryptographic technology, blockchain infrastructure, network security, or computer functionality itself. Rather, the recited encryption, pseudo-anonymous identifiers, multivariate arrays, and protocol data are merely invoked as generic mathematical tools to implement the underlying abstract financial transaction scheme.
Under Step 2B, the additional limitations amount only to well-understood, routine, and conventional computer operations involving data generation, encryption, verification, identifier generation, and transmission of information over a network. The claims do not recite any unconventional technical implementation or any specific asserted improvement in computer capabilities.
Accordingly, claims 2–4 do not amount to significantly more than the abstract idea and are therefore not directed to patent-eligible subject matter.
Independent claim 5 is rejected under 35 U.S.C. § 101 because the claim is directed to the same abstract ideas discussed above with respect to claim 1, namely certain methods of organizing human activity involving supply-chain financing, invoice processing, credit transfer management, and factoring operations.
The recited “data transfer and circulation device” merely recites generic functional modules including a first obtaining module, sending modules, obtaining modules, and processing modules configured to perform the abstract business practices previously discussed with respect to claim 1.
The recited modules merely describe desired functional results without reciting any specific technological implementation or improvement to computer functionality. The claim merely organizes generic computer functions into nominally labeled modules to automate commercial financing interactions among suppliers and financial entities.
Under Step 2A, Prong Two, the claim does not integrate the abstract idea into a practical application because the additional elements merely invoke generic computing components as tools to carry out the underlying abstract commercial activity.
Under Step 2B, the additional module limitations merely amount to generic computer implementation of abstract ideas using conventional data processing functions such as obtaining, sending, generating, verifying, and processing information.
Accordingly, claim 5 does not recite significantly more than the abstract idea itself and is therefore not directed to patent-eligible subject matter.
Dependent claims 6–8 are rejected under 35 U.S.C. § 101 because the additional “computing units,” “processing units,” “encryption units,” and “verification units” merely further limit the abstract ideas of claims 5 and 1 using generic mathematical and cryptographic operations.
The recited units merely perform conventional data generation, encryption, identifier calculation, verification, and transfer processing operations that are well-understood, routine, and conventional computer functions.
These claims do not recite any technological improvement to encryption techniques, distributed ledger operation, computer networking, or processing architecture. Rather, the claims merely use conventional cryptographic and computer operations as tools to execute the abstract financing and credit-transfer scheme.
Accordingly, claims 6–8 fail to integrate the judicial exception into a practical application and do not recite significantly more than the abstract idea itself.
Independent claim 9 is rejected under 35 U.S.C. § 101 because the claim merely recites a generic computer system comprising a memory and processor configured to execute the abstract method of claim 1.
The additional computer components are recited at a high level of generality and merely perform generic computer functions of storing and executing instructions. The claim does not recite any specific improvement to processor functionality, memory architecture, distributed computing, blockchain operation, or computer technology generally.
Accordingly, claim 9 merely implements the abstract idea of claim 1 on generic computer hardware and therefore does not amount to significantly more than the abstract idea itself.
Independent claim 10 is rejected under 35 U.S.C. § 101 because the claim merely recites a computer-readable storage medium storing instructions configured to implement the abstract method of claim 1.
The recited computer-readable storage medium merely serves as a generic storage mechanism for instructions implementing the abstract commercial financing and credit-transfer process discussed above.
The claim does not recite any improvement to computer storage technology, memory structures, distributed ledger architecture, or processing efficiency. Rather, the claim merely stores instructions for implementing the abstract idea using generic computer technology.
Accordingly, claim 10 is directed to an abstract idea and does not include additional elements amounting to significantly more than the abstract idea itself. Therefore, claim 10 is not directed to patent-eligible subject matter under 35 U.S.C. § 101.Allowable Subject Matter
Claims 1-10 are allowable over prior art of records. As allowable subject matter has been indicated, applicant's reply must either comply with all formal requirements or specifically traverse each requirement not complied with. See 37 CFR 1.111(b) and MPEP § 707.07(a).
Response to Arguments
Applicant’s arguments filed on December 26, 2025 have been fully considered but are not persuasive.
With respect to Step 2A, Prong One applicant argues that the claims are not directed to a business method or organizing human activity merely because certain data forms may be adopted in business activities. Applicant further argues that business methods are not categorically excluded from patent eligibility under 35 U.S.C. §101.
The Examiner agrees that business methods are not per se excluded from patent eligibility. However, the rejection is not based on a categorical exclusion of business methods. Rather, the rejection is based on the determination that the claims recite an abstract idea under the judicial exceptions identified in the 2019 Revised Patent Subject Matter Eligibility Guidance and subsequent USPTO eligibility guidance.
Specifically, representative claim 1 recites certain methods of organizing human activity, including commercial interactions, financial transactions, credit transfer management, invoice circulation, financing arrangements, supplier-factoring coordination, and verification of receivable transfers among supply-chain participants.
For example, claim 1 recites: obtaining blockchain certificates corresponding to supplier nodes; confirming identities of supplier nodes; generating completed work item digital bills; performing transfers among supplier nodes; generating credit transfer digital certificates; requesting factoring information; and providing financing based on enterprise situations.
These limitations collectively describe a commercial financing and receivable-transfer process involving supplier entities, core enterprises, and factoring institutions. Such activities constitute fundamental economic practices and commercial interactions, which fall squarely within the “certain methods of organizing human activity” grouping of abstract ideas identified by the USPTO eligibility guidance. See MPEP §2106.04(a)(2).
Further, the claims additionally recite mental processes because the claimed verification, confirmation, evaluation, and financing determinations can practically be performed mentally or using pen and paper, albeit more efficiently using generic computer technology.
Applicant’s argument that the claims involve “data transfer and circulation” does not overcome the rejection because merely limiting an abstract business practice to implementation using data structures or digital information does not render the claim non-abstract. See Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 573 U.S. 208, 223 (2014) (“the mere recitation of a generic computer cannot transform a patent-ineligible abstract idea into a patent-eligible invention”).
Accordingly, the Examiner maintains that claims 1–10 recite abstract ideas under Step 2A, Prong One.
With respect to Step 2A, Prong Two applicant argues that the recitations of:
“the preset smart contract is established on a public blockchain,” and
“providing, by the factor node, financing to the multi-level supplier nodes based on the factoring information and comprehensive enterprise situation of the multi-level supplier nodes”
constitute additional elements integrating the alleged abstract idea into a practical application.
Applicant further argues that the claims improve credibility, transparency, visualization, and circulation efficiency of work item accounts receivable using blockchain technology, authentication, encryption, and signing mechanisms.
These arguments have been considered but are not persuasive.
The additional limitations identified by Applicant merely use generic computer and blockchain technology as tools to implement the underlying abstract commercial financing concept. The claims do not recite any specific asserted improvement to blockchain architecture, distributed ledger functionality, cryptographic processing, network communication protocols, computer security mechanisms, or computer functionality itself.
Rather, the claims merely invoke: blockchain certificates; smart contracts; pseudo-anonymous identifiers; encryption operations; digital certificates; transfer notifications; and
verification operations, to facilitate the abstract economic practice of receivable circulation and supplier financing.
The claimed “public blockchain” is recited at a high level of generality and merely serves as a generic environment in which the abstract financing activities are performed. The claims do not recite any specialized blockchain data structure, consensus mechanism, distributed synchronization improvement, cryptographic protocol improvement, or technological enhancement to distributed ledger systems.
Similarly, the alleged improvements relating to “credibility,” “transparency,” “visualization,” and “efficiency” pertain to improvements in the underlying business process itself rather than improvements to computer technology. Improving the reliability or transparency of financial transactions or receivable circulation constitutes an improvement to an abstract commercial practice, not a technological improvement to computers or networks. See Trading Technologies Int’l, Inc. v. IBG LLC, 921 F.3d 1084, 1093 (Fed. Cir. 2019); see also SAP America, Inc. v. InvestPic, LLC, 898 F.3d 1161, 1168–69 (Fed. Cir. 2018).
Additionally, the recited authentication, encryption, signing, and verification operations are recited functionally and generically without any specific technological implementation or unconventional technical mechanism. The claims merely recite desired results rather than a specific technical solution improving computer functionality. See Interval Licensing LLC v. AOL, Inc., 896 F.3d 1335, 1346 (Fed. Cir. 2018).
Applicant’s reliance on the Specification’s discussion of business inefficiencies in receivable settlement cycles and supply-chain financing likewise does not demonstrate a technological improvement. The Specification identifies business and financial problems relating to capital transfer efficiency, credibility of receivables, and transfer visualization. Such problems are commercial in nature rather than technical computer problems.
Accordingly, the additional elements do not integrate the judicial exception into a practical application under Step 2A, Prong Two.
Under Step 2B, these claims additionally fail to recite significantly more than the abstract idea itself.
The additional elements recited in claims 1–10, including: supplier nodes; factor nodes;
core enterprise nodes; memories; processors; modules; computing units; encryption units; blockchain certificates; smart contracts; and digital certificates are recited generically and perform well-understood, routine, and conventional computer functions such as:
obtaining data; sending information; verifying information; generating identifiers; encrypting data; processing requests; storing information; and transmitting notifications.
The mere automation of a longstanding commercial financing practice using generic computing components and blockchain terminology does not amount to significantly more than the abstract idea itself. See Alice, 573 U.S. at 225–26.
Further, merely implementing an abstract idea on a blockchain platform or using smart contracts does not confer patent eligibility absent a specific technological improvement to computer functionality or distributed ledger technology. These instant claims do not recite such an improvement.
Accordingly, claims 1–10 remain directed to non-statutory subject matter under 35 U.S.C. §101, and the rejection is therefore maintained.
Conclusion
THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ROKIB MASUD whose telephone number is (571)270-5390. The examiner can normally be reached Mon-Fri 8:00-5:00.
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/ROKIB MASUD/Primary Examiner, Art Unit 3627
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