DETAILED ACTION
This is an office action on the merits in response to the communication filed on 12/26/2025.
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 .
Claims’ Status
Claims 2-6 and 8-12 are cancelled. Claims 1 and 7 are amended. Claims 13-23 are new claims. Claims 1, 7, and 13-23 are pending and are considered in this office action.
Response to Arguments/Comments
Examiner has carefully considered applicant’s amendment and arguments, however Examiner still respectfully disagrees. The amendment does not add any additional element that would integrate the judicial exception into a practical application nor does it amount to significantly more than the judicial exception in the claim. The amended claims are still recited at a high level of generality of processing a check; one would not find the claims are directed to any specific architecture nor the sequence of steps are unique that would integrate the judicial exception into a practical application. As such, 101 rejection is maintained.
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, 7, and 13-23 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter.
Step 1 (The Statutory Categories): Is the claim to a process, machine, manufacture or composition of matter? MPEP 2106.03
Per Step 1, Claims 1 and 13-17 are drawn to system claims; claim 7 and 18-23 are drawn to method claims; which are within the four statutory categories (i.e., a process).
Step 2A Prong 1: Does the claim recite an abstract idea, law of nature, or natural phenomenon MPEP 2106.04.
Claim 1 (claim 7 similar in scope):
(a) a client device comprising a camera, a client processor, and a non-transitory client memory; and (b) a server in network communication with the client device, the server comprising a communication interface, a server processor, and a non-transitory server memory storing instructions that, when executed by the server processor, cause the server to:
(i) provide a check image link or token for remote uploading of images of a check;
(ii) receive, via the check image link or token, at least a front image of the check uploaded from a remote device and associate the received front image with the check image link or token;
(iii) support offline capture by causing the front image to be stored in the non-transitory client memory when a network connection is unavailable and uploaded to the server when the network connection is restored, wherein the front image is encrypted with a public key prior to upload and decrypted using a private key after upload at the server;
(iv) for a mobile deposit transaction in which only the front image is captured, generate aback image of the check by detecting a check template based on check proportions and inserting endorsement text into an endorsement area; and
(v) provide check image security by, after storing images of the check and after a predetermined amount of time, performing at least one of blurring, deleting, or partially blurring or deleting a MICR line in the stored images, wherein an administrator is permitted to reversibly restore the MICR line and wherein the MICR line is made automatically available in response to an authorization event or a clearance event.
The limitations, as drafted, constitute a process that, under its broadest reasonable interpretation, covers managing, 1) Managing personal behavior or relationships or interaction between people by following rules or instructions, under the Certain methods of organizing human activity, but for the recitation of generic computer components. The abstract idea, recited above, includes: (i) provide a check image link or token for remote uploading of images of a check; (ii) receive, via the check image link or token, at least a front image of the check uploaded from a remote device and associate the received front image with the check image link or token. If a claim limitation, under its broadest reasonable interpretation, covers performance of managing relationships by following rules, but for the recitation of generic computer components, it falls within the Certain Methods of Organizing Human Activity – 1) Managing personal interactions between people by following rules or instructions, grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
Step 2A Prong 2: Does the claim recite additional elements that integrate the judicial exception into a practical application? MPEP 2106.04.
The recited computing elements (“a client device comprising a camera, a client processor, and a non-transitory client memory; and (b) a server in network ”) are recited at a high-level of generality, i.e. as generic computing element performing generic computer functions such that it amounts to no more than mere instructions to apply the exception using generic computer components (see MPEP 2106.05(f)). Simply adding a general purpose computer or computer components after the fact to an abstract idea does not integrate a judicial exception into a practical application or provide significantly more, since it amounts to no more than a recitation of the words "apply it" (or an equivalent) to implement an abstract idea or other exception on a computer, as set forth in MPEP 2106.05(f).
Other additional positive elements include: (iii) support offline capture by causing the front image to be stored in the non-transitory client memory when a network connection is unavailable and uploaded to the server when the network connection is restored, wherein the front image is encrypted with a public key prior to upload and decrypted using a private key after upload at the server; (iv) for a mobile deposit transaction in which only the front image is captured, generate aback image of the check by detecting a check template based on check proportions and inserting endorsement text into an endorsement area; and (v) provide check image security by, after storing images of the check and after a predetermined amount of time, performing at least one of blurring, deleting, or partially blurring or deleting a MICR line in the stored images, wherein an administrator is permitted to reversibly restore the MICR line and wherein the MICR line is made automatically available in response to an authorization event or a clearance event; these steps are just conventional steps that one would commonly use to implement security features into processing a check. These steps are neither unique nor functional in a way that can integrate with the computer components into processing a check. They do not reflect any technical improvement; they are simply adding incremental improvements to the business process of processing a check.
Accordingly, these additional claim elements, alone and in combination do not integrate the abstract idea into a practical application, because (1) they do not effect improvements to the functioning of a computer, or to any other technology or technical field (see MPEP 2106.05(a)); (2) they do not apply or use the abstract idea to effect a particular treatment or prophylaxis for a disease or a medical condition (see the Vanda memo); (3) they do not apply the abstract idea with, or by use of, a particular machine (see MPEP 2106.05(b)); (4) they do not effect a transformation or reduction of a particular article to a different state or thing (see MPEP 2106.05(c)); (5) they do not apply or use the abstract idea in some other meaningful way beyond generally linking the use of the identified abstract idea to a particular technological environment, such that the claim as a whole is more than a drafting effort designated to monopolize the exception (see MPEP 2106.05(e) and the Vanda memo). Therefore, per Step 2A, Prong Two, the claim is directed to an abstract idea not integrated into a practical application.
Step 2B (The Inventive Concept): Does the claim recite additional elements that amount to significantly more than the judicial exception? MPEP 2106.05.
Step 2B of the eligibility analysis concludes that the claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Examiner carries over the analysis from Step 2A related to the generic computing elements being no more than a recitation of the words "apply it" (or an equivalent) to implement an abstract idea or other exception on a computer (MPEP 2106.05(f)). The additional claim elements that are just “applying it” or “generally linking the use of the judicial exception to a particular technological environment or field of use” are mere instructions to implement an abstract idea on a computer, are carried over for further analysis in Step 2B.
When the independent claims are considered as a whole, as a combination, the claim elements noted above do not amount to any more than they amount to individually. The operations appear to merely apply the abstract concept to a technical environment in a very general sense. The most significant elements of the claims, that is the elements that really outline the inventive elements of the claims, are set forth in the elements identified as an abstract idea. Therefore, it is concluded that the elements of the independent claims are directed to one or more abstract ideas and do not amount to significantly more. (MPEP 2106.05)
Further, Step 2B of the analysis takes into consideration all dependent claims as well, both individually and as a whole, as a combination:
Claims 13-17 are further directed to additional abstract ideas because the steps performed are simply narrowing the scope of the abstract idea of claim 1 since their individual and combined significance is still not significantly more than the abstract concept at the core of the claimed invention. For example, claim 13 further describes storing EXIF metadata of the images; claim 14 describes extracting check data and encryption keys from the EXIF metadata; claim 15 detecting multiple checks within a single captured image; claim 16 describes enhancing readability of the MICR line; claim 17 on image enchantment using a convolutional neural network (high level without specificity on how to apply the convolutional neural network; etc, which all of the limitation are narrowing the steps performed in claim 1.
Now turning to independent claim 23, claim 23 is also rejected due to its limitation encompasses a combination of claim 1, 13, and 14 which were rejected for the same reasons discussed above.
Moreover, the claims in the instant application do not constitute significantly more also because the claims or claim elements only serve to implement the abstract idea using computer components to perform computing functions (Enfish, see MPEP 2106.05(a)). Specifically, the computing system encompasses general purpose hardware and software modules. The other dependent claims, claim 18-22, are similar in scope to the claim 13-17 are also rejected for the same reasons provided above.
The most significant elements of the claims, that is the elements that really outline the inventive elements of the claims, are set forth in the elements identified in the independent claims as an abstract idea. The fact that the associated computing devices are facilitating the abstract concept is not enough to confer statutory subject matter eligibility. In sum, the additional elements do not serve to confer subject matter eligibility to the invention since their individual and combined significance is still not heavier than the abstract concepts at the core of the claimed invention. Therefore, it is concluded that the dependent claims of the instant application do not amount to significantly more either. (see MPEP 2106.05)
In sum, claims 1, 7, and 13-23 are rejected under 35 USC 101 as being directed to non-statutory subject matter.
Reasons for Allowance Over the Prior Art
The following is a statement of reasons for the indication of allowable subject matter: Claim 1, 7, and 23 each contains allowable subject matter. The closest prior arts of record fail to teach or suggest, in the context of the ordered combination of the claim, “(d) generating, based on the front image and without capturing a backside of the check, a back image of the check by detecting a check template based on check proportions.”
Dependent claims 13-22 each depends on their respect independent claim 1 or 7 or 23 and is therefore allowable due to dependency of the respective independent claims.
Conclusion
THIS ACTION IS MADE FINAL, necessitated by amendment. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
Any inquiry concerning this communication or earlier communications from the examiner should be directed to YIN Y CHOI whose telephone number is (571)272-1094 or yin.choi@uspto.gov. The examiner can normally be reached on M-F 7:30 - 5:30pm EST.
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/YIN Y CHOI/Examiner, Art Unit 3699
4/22/2026
/NILESH B KHATRI/Primary Examiner, Art Unit 3699
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