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
This action is in reply to the amendment filed on 05/26/2026.
Claims 1-3, 5, 9-11, 13, 15 and 19 have been amended..
Claims 1-20 are pending and have been examined.
A Terminal Disclaimer was filed on 03/07/2025.
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 12/29/2025 has been entered.
Response to Arguments
With regard to the 101 rejection, the arguments have been considered but they are not persuasive. The Applicant asserted on page 11 that “[the] cellular transceiver that is ‘configured to receive location information for the first cassette from one or more nearby cellular towers’ and a ‘sensor’ that is configured to ‘detect a physical dimension of a stack of bills within the first cassette’. The cellular transceiver and the sensor, in combination with the other additional elements, are used in a set of steps that are integrated into an overall claimed process.” However, the use of a transceiver to detect a stack of bills is not rendering a practical application. Rather, it is leveraging the use of an existing technology in tracking the bills. Hence, the limitations are not indicative of integration into a practical application: Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea - see MPEP 2106.05(f). Therefore, the claim is not patent eligible and the rejection is maintained.
With regard to step 2B Prong Two, the Applicant asserted that “’additional elements’ that are sufficient to amount to significantly more than the judicial exception . . .”, the Examiner does not see the parallel between the claims of the instant application and those of DDR Holdings. In DDR Holdings an improvement in web technology was used to address the problem of retaining web customers. DDR Holdings was solving a problem introduced by technology, such that it was a technological solution to a technological problem. Whereas the Applicants’ invention is a technological solution to a problem rooted in an abstract idea. The claims of the instant case employ at least one processing circuit, one or more processors, a plurality of cassettes suitably programmed to perform the claimed functions. In light of the Alice decision and the July 2015 Update of Interim Guidance Identifying Abstract Ideas the features such as “receiving cassette data . . .”, “determining . . . a location of the first cassette . . .”, “determining . . . fill level . . .”, “transmitting a notification . . .” are not considered an improvement to another technology or technical field, or an improvement to the functioning of the computer itself. These features recited in the claim are only further refinements of the abstract idea. That does not change the fact that the claim is drawn to abstract ideas. There are no improvements to another technology or technical field, no improvements to the functioning of the computer itself, transformation or reduction of a particular article to a different state or thing or any other meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment as a result of performing the claimed method. As discussed earlier, the claimed steps of the method are all functions that are conventional for a computer system, which in the Applicant’s invention comprises at least one processing circuit, one or more processors . . .: . The claimed sequence of steps comprises only "steps, specified at a high level of generality," which is insufficient to supply an "inventive concept." Id. at 2357 (quoting Mayo, 132 S. Ct. at 1294, 1297, 1300). Also the addition of merely novel or non-routine components to the claimed idea does not necessarily turn an abstraction into something concrete (See Ultramercial, Inc. v. Hulu, LLC, _ F.3d_, 2014 WL 5904902, (Fed. Cir. Nov. 14, 2014). In Alice also the system was specifically programmed to perform the claimed functions.
Therefore, the claim is not patent eligible under both step 2A and 2B analysis.
Notes: the claim is not patent eligible because the wireless transceiver comprising a cellular transceiver is outside the scope of the claim, as the claim is from the processing circuit’s (presumably a central server perspective). If the claim was clear that the cassette was determining its own location in this manner and was within the scope of the computing system, it would help. But right now, this functionality is buried within a “determine . . .” step (which is, again, outside the scope of “determining a location”). Having some clear separate steps would help.
With regard to the 103 rejection, the arguments have been considered and they are persuasive. On page 17, the applicant asserted “[however, Li, Jones, and Warmulla either taken alone or in combination, do not cure the deficiencies of Angus . . .”.
Angus teaches: A currency container, method of managing a currency container and a cash management system are disclosed. The currency container includes a container body such as a rigid cassette or flexible bag for storing currency notes. The container includes at least one near field communication (NFC) tag for indicating information associated with the container such as an ID of the container and/or a value of currency stored in the container.
Li teaches An apparatus and method is disclosed for the retention of currency in the nature of coins and bills, within a transactional terminal, for replenishment of a change dispenser and future distribution in the form of change, as well as the storage in a secure safe of larger denomination bills for which credit may be applied to a financial account prior to the actual deposit of such bills at a financial institution. A system incorporating the apparatus and method may further provide for the overall management of cash receipts whereby a running balance is recorded and acted upon, for example when a change dispenser is empty, a change retention buffer is full, or the large-denomination bill vault is emptied.
Jones teaches A document processing device convertible between a first configuration and a second configuration includes an input receptacle, a transport mechanism, a scanner, and a convertible output area. The input receptacle is configured to receive documents including currency bills therein. The transport mechanism is configured to transport the documents along a transport path from the input receptacle. The scanner is positioned along the transport path and is configured to scan at least a portion of each of the documents transported to generate data associated therewith. The convertible output area is configured to be selectively coupled with a first output assembly and a second output assembly.
Warmulla teaches a method and a system for automatically consolidating order-picking and packing of articles (A) ready to send. An order-picking container (1), in which articles (A) are grouped, is provided. The method comprises the steps of: a) arranging the order-picking container (1) on a predetermined transfer location (10) and transferring an article (A) to the order-picking container (1), b) moving the filled order-picking container (1) to a predetermined packing station (20) and providing a transport packaging (100) with a downwardly facing opening (101) which is adapted to receive the order-picking container (1), c) arranging the order-picking container (1) through the opening (101) in the transport packaging (100), d) moving the filled order-picking container (10) which is arranged in the transport packaging (100) to a transfer and separating station (30), e) transferring the at least one article (A) from the order-picking container (1) in the transport packaging (100) by means of a vertical turning movement, f) separating the order-picking container (1) from the transport package (100) and g) closing the transport packaging (100). All method steps are carried out automatically in a machine in a continuous process.
None of the cited references, individual or in combination, establish a prima facie case to teach the claimed invention. Therefore, the art rejection is withdrawn.
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 1-20 are directed to a system, or method which are one of the statutory categories of invention. (Step 1: YES).
Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. Claims 1-20 are directed to an abstract idea, Method of Organizing Human Activity. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional computer elements, which are recited at a high level of generality, provide conventional computer functions that do not add meaningful limits to practicing the abstract idea.
Claims 1, 9 recite, in part, A computing system comprising: at least one processing circuit having one or more processors coupled to machine readable storage media having instructions stored therein that, when executed by the one or more processors, cause the at least one processing circuit to: receive cassette data from a first cassette of a plurality of cassettes, the cassette data including a fill level of the first cassette acquired by a sensor associated with the first cassette, the sensor configured to detect a physical dimension of a stack of bills within the first cassette, the fill level based on the physical dimension; determine, based on the cassette data, (i) a first location of the first cassette based on location data associated with the first cassette, the location data received by a wireless transceiver associated with the first cassette, the wireless transceiver comprising a cellular transceiver configured to receive location information for the first cassette from one or more nearby cellular towers, the first location being at a first transaction device, (ii) that the fill level of the first cassette does not satisfy a threshold, and (iii) one or more denominations of bills contained within the first cassette; establish a geo-fence based on the first location of the first cassette; identify a second cassette for replacing the first cassette based on a second location of the second cassette being at a second transaction device different than the first transaction device and within the geo-fence, and the one or more denominations of bills contained within the first cassette such that the second cassette is configured to receive and dispense bills of a similar denomination to the first cassette; and transmit a notification to a remote computing device, the notification indicating that the fill level of the first cassette does not satisfy the threshold and identifying the second cassette.
Claim 15 recites, in part, A system comprising: at least one processing circuit having one or more processors coupled to machine readable storage media having instructions stored therein that, when executed by the one or more processors, cause the at least one processing circuit to: receive cassette data from a first cassette of a plurality of cassettes, the cassette data including a fill level of the first cassette acquired by a sensor associated with the first cassette, the sensor configured to detect a physical dimension of a stack of bills within the first cassette, the fill level based on the physical dimension; determine, based on the cassette data, (i) a first location of the first cassette based on location data associated with the first cassette, the location data received by a wireless transceiver including a cellular transceiver associated with the first cassette, the cellular transceiver configured to receive location information for the first cassette from one or more nearby cellular towers, the first location being at a first transaction device, and (ii) that the fill level of the first cassette does not satisfy a threshold, and (iii) one or more denominations of bills contained within the first cassette; establish a geo-fence based on the first location of the first cassette; identify a second cassette for replacing the first cassette based on a second location of the second cassette being at a second transaction device different than the first transaction device and within the geo-fence of the first cassette and the one or more denominations of bills contained within the first cassette; and transmit a notification to a remote computing device, the notification indicating that the fill level of the first cassette does not satisfy the threshold and identifying the second cassette. These limitations are directed to concept of determining amounts/levels of bills available for transactions. Hence, it is directed to commercial interactions which falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
This judicial exception is not integrated into a practical application. In particular, the claim only recites additional elements such as a cassette, a sensor, a memory, a processing circuit, a processor, non-transitory computer readable medium, a remote computing device, one of a global positioning systems recited at a high-level of generality (receiving, identifying and transmitting) such that it amounts no more than mere instructions to apply the exception using a generic computer component. Accordingly, the additional elements such as cassettes (ATMs TRC, TCD,, etc.) do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. They are generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h).The claim is directed to an abstract idea
Next the claim as a whole is analyzed to determine whether any element, or combination of elements, is sufficient to ensure the claim amounts to significantly more than an abstract idea. Claims 1, 9 and 15 do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements are Generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h). There is no improvement to computer technology or computer functionality MPEP 2106.05(a) nor a particular machine MPEP 2106.05(b) nor a particular transformation MPEP 2106.05(c). Given the above reasons, a generic processing device helps for managing currency cassettes is not an Inventive Concept. Thus, the claim is not patent eligible.
The dependent claims have been given the full two part analysis (Step 2A – 2-prong tests and step 2B) including analyzing the additional limitations both individually and in combination. The dependent claim(s) when analyzed both individually and in combination are also held to be patent ineligible under 35 U.S.C. 101 because for the same reasoning as above and the additional recited limitation(s) fail(s) to establish that the claim(s) is/are not directed to an abstract idea. The additional limitations of the dependent claim(s) when considered individually and as ordered combination do not amount to significantly more than the abstract idea.
The dependent claim 2, 7, 8, 10 has been given the full two part analysis (Step 2A – 2-prong tests and step 2B) including analyzing the additional limitations both individually and in combination. The dependent claim(s) recite an abstract idea of storing the location, determining a threshold levels, and determining fill level fail(s) to establish that the claim(s) is/are not directed to an abstract idea. The additional limitations of the dependent claim(s) when considered individually and as ordered combination do not amount to significantly more than the abstract idea because the claims recite generic components such as store level of cassette and fill level and first and second location. Furthermore, the claims do not include additional elements (one or more processors, processing circuit, cassette, a database) that are sufficient to amount to significantly more than the judicial exception because the additional elements are generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h).Therefore, the claims are not patent eligible.
The dependent claims 3,11 have been given the full two part analysis (Step 2A – 2-prong tests and step 2B) including analyzing the additional limitations both individually and in combination. The dependent claim(s) recite additional elements such as location and time intervals of refilling the cassette fail(s) to establish that the claim(s) is/are not directed to an abstract idea. The additional limitations of the dependent claim(s) when considered individually and as ordered combination do not amount to significantly more than the abstract idea because the claims recite generic components such as time intervals. Furthermore, the claims do not include additional elements (cassette, a database) that are sufficient to amount to significantly more than the judicial exception because the additional elements are Generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h)Therefore, the claims are not patent eligible.
The dependent claims 4, 12 have been given the full two part analysis (Step 2A – 2-prong tests and step 2B) including analyzing the additional limitations both individually and in combination. The dependent claim(s) recite generating an audit log which comprises data regarding manipulation fail(s) to establish that the claim(s) is/are not directed to an abstract idea. The additional limitations of the dependent claim(s) when considered individually and as ordered combination do not amount to significantly more than the abstract idea because the claims recite generic components such as audit log. Furthermore, the claims do not include additional elements (processing circuit, cassette, a database) that are sufficient to amount to significantly more than the judicial exception because the additional elements are generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h)Therefore, the claims are not patent eligible.
The dependent claim 13 have been given the full two part analysis (Step 2A – 2-prong tests and step 2B) including analyzing the additional limitations both individually and in combination. The dependent claim(s) recite identifying a second cassette fail(s) to establish that the claim(s) is/are not directed to an abstract idea. The additional limitations of the dependent claim(s) when considered individually and as ordered combination do not amount to significantly more than the abstract idea because the claims recite generic components such as audit log. Furthermore, the claims do not include additional elements (processing circuit, cassette, a database) that are sufficient to amount to significantly more than the judicial exception because the additional elements are generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h)Therefore, the claims are not patent eligible.
The dependent claims 5, 10, 17, 19 have been given the full two part analysis (Step 2A – 2-prong tests and step 2B) including analyzing the additional limitations both individually and in combination. The dependent claim(s) recite additional elements such as universal cassette, second cassette with second location, cassettes at different locations fail(s) to establish that the claim(s) is/are not directed to an abstract idea. The additional limitations of the dependent claim(s) when considered individually and as ordered combination do not amount to significantly more than the abstract idea because the claims recite generic components such as location of cassettes. Furthermore, the claims do not include additional elements (cassette, a database, an ATM, a teller station) that are sufficient to amount to significantly more than the judicial exception because the additional elements are generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h). Therefore, the claims are not patent eligible.
The dependent claims 6, 14, 20 have been given the full two part analysis (Step 2A – 2-prong tests and step 2B) including analyzing the additional limitations both individually and in combination. The dependent claim(s) when analyzed both individually and in combination are also held to be patent ineligible under 35 U.S.C. 101 because for the same reasoning as above and the additional recited limitation(s) fail(s) to establish that the claim(s) is/are not directed to an abstract idea. The additional limitations of the dependent claim(s) when considered individually and as ordered combination do not amount to significantly more than the abstract idea because the claims recite generic components such as a teller location. Furthermore, the claims do not include additional elements (cassette, a database, an ATM, a teller station) that are sufficient to amount to significantly more than the judicial exception because the additional elements are generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h). Therefore, the claims are not patent eligible.
The dependent claim 16 have been given the full two part analysis (Step 2A – 2-prong tests and step 2B) including analyzing the additional limitations both individually and in combination. The dependent claim(s) when analyzed both individually and in combination are also held to be patent ineligible under 35 U.S.C. 101 because for the same reasoning as above and the additional recited limitation(s) fail(s) to establish that the claim(s) is/are not directed to an abstract idea. The additional limitations of the dependent claim(s) when considered individually and as ordered combination do not amount to significantly more than the abstract idea because the claims recite generic components such as wireless transceiver or RFID transmitter. Furthermore, the claims do not include additional elements (cassette, a database, wireless transceiver or RFID) that are sufficient to amount to significantly more than the judicial exception because the additional elements are generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h). Therefore, the claims are not patent eligible.
Therefore, Claims 1-20 are not drawn to eligible subject matter as they are directed to an abstract idea without significantly more.
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 TOAN DUC BUI whose telephone number is (571)272-0833. The examiner can normally be reached M-F 8-5:00 PM.
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, Mike W. Anderson can be reached on (571) 270-0508. 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.
/TOAN DUC BUI/ Examiner, Art Unit 3693
/BRUCE I EBERSMAN/ Primary Examiner, Art Unit 3693
Prosecution Insights