DETAILED ACTION
Status of Claims
1. This office action is in response to amendment filed 7/13/2026.
2. Claims 1-20 are pending.
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 .
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
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.
Step 1: Claims 1-11 are directed to a system; claims 12-20 are directed to a method – each of which is one of the statutory categories of inventions.
Step 2A: A claim is eligible at revised Step 2A unless it recites a judicial exception and the exception is not integrated into a practical application of the application.
Prong 1: Prong One of Step 2A evaluates whether the claim recites a judicial exception (an abstract idea enumerated in the 2019 PEG, a law of nature, or a natural phenomenon).
Groupings of Abstract Ideas:
I. MATHEMATICAL CONCEPTS
A. Mathematical Relationships
B. Mathematical Formulas or Equations
C. Mathematical Calculations
II. CERTAIN METHODS OF ORGANIZING HUMAN ACTIVITY
A. Fundamental Economic Practices or Principles (including hedging, insurance, mitigating risk)
B. Commercial or Legal Interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations)
C. Managing Personal Behavior or Relationships or Interactions between People (including social activities, teaching, and following rules or instructions)
III. MENTAL PROCESSES.
Concepts performed in the human mind (including an observation, evaluation, judgment, opinion).
See MPEP 2106.04 (a) (2) Abstract Idea Groupings [R-10.2019]
The limitations recited in the independent claims 1, 10 and 12 –
responsive to a receipt of data associated with an approval of an amount of funds transferred from a financial institution account maintained, independent of any gaming establishment, in association with a financial institution and responsive to a determination to employ an [electronic funds transfer funding pathway]:
determining, [by a processor] and at least partially based on data associated with prior electronic funds transfers published to a service bus, if the transfer of the amount of funds from the financial institution account complies with a transfer limit, the determination occurs independent of a [server of a gaming establishment cashless wagering system] and independent of any gaming establishment cashless wagering account maintained by the server of the gaming establishment cashless wagering system, and responsive to the determination being that the transfer of the amount of funds from the financial institution account fails to comply with the transfer limit:
disabling, [by the processor] and in accordance with the employed electronic funds transfer funding pathway, any modification of a balance of an electronic gaming machine, and
displaying, [by a display device], a notification associated with the transfer failing to comply with the transfer limit, and
responsive to the determination being that the transfer of the amount of funds from the financial institution account complies with the transfer limit, employing, by the processor, the electronic funds transfer funding pathway to cause a modification of the balance of the [electronic gaming machine], wherein the employment of the [electronic funds transfer funding pathway] comprises a transfer of the amount of the funds from the financial institution account to the balance of the electronic gaming machine independent of any transfer of funds to any gaming establishment cashless wagering account maintained by [the server of the gaming establishment cashless wagering system] and responsive to the transfer to the balance of the [electronic gaming machine], a [master gaming controller of the electronic gaming machine] modifies a first tracked meter based on that transfer
– constitute Fundamental Economic Practices and/or Commercial/Legal Interactions and hence fall under the abstract idea category Certain Methods of Organizing Human Activity.
The limitations of the dependent claims –
(claims 2, 13) responsive to the determination being that the transfer of the amount of funds from the financial institution account fails to comply with the transfer limit, cause the processor prevent a subsequent transfer of any amount of funds from the financial institution account to the electronic gaming machine.
(claims 3, 14) responsive to the determination being that the transfer of the amount of funds from the financial institution account fails to comply with the transfer limit, cause the processor to enable an employment of a wagering account transfer funding pathway comprising a first transfer of the amount of funds from the financial institution account to the gaming establishment cashless wagering account, followed by a second transfer of the amount of funds from the gaming establishment cashless wagering account to the balance of the electronic gaming machine which modifies a second, different tracked meter based on that transfer
(claims 4, 15) responsive to the determination being that the transfer of the amount of funds from the financial institution account complies with the transfer limit, cause the processor to publish, to the service bus, data associated with the transfer of the amount of funds from the financial institution account
(claims 5, 16) wherein the transfer limit is associated with at least one of an amount transferrable from the financial institution account over a period of time and an amount transferrable in association with a user over a period of time.
(claims 6, 17) responsive to the determination being that the transfer of the amount of funds from the financial institution account fails to comply with the transfer limit, cause the processor to modify the transfer limit based on an action undertaken by a user
(claims 7, 18) responsive to the determination being that the transfer of the amount of funds from the financial institution account fails to comply with the transfer limit, cause the processor to modify the transfer limit based on an action undertaken by a user
Claim 7 (currently amended): The gaming establishment external funding system of Claim 6, wherein the action comprises at least one of: the user authorizing a know-your-customer check, the user signing up for a gaming establishment patron management system account, and the user engaging with gaming establishment personnel
(claims 8, 19) responsive to the determination being that the transfer of the amount of funds from the financial institution account fails to comply with the transfer limit, cause the processor to modify the transfer limit based on an action undertaken by a user.
(Claim 7): the user authorizing a know-your-customer check, the user signing up for a gaming establishment patron management system account, and the user engaging with gaming establishment personnel
(Claim 8) wherein the determination to employ the electronic funds transfer funding pathway is based on a user associated with the financial institution account not being associated with the any gaming establishment cashless wagering account maintained by the server of the gaming establishment cashless wagering system
(claims 9, 20) wherein the determination of if the transfer of the amount of funds from the financial institution account complies with the transfer limit is based on if the transfer of the amount of funds is associated with any potential money laundering activities.
(claim 11) wherein the transfer limit comprises a responsible gaming limit.
upon determining that the transfer fails to comply with transfer limit preventing subsequent transfer from the account; upon determining that the transfer complies with transfer limit modifying gaming establishment device balance; upon determining that the transfer complies with transfer limit modifying transfer limit based on type of user action; transfer over a period of time; determination to employ fund pathway based in user not being associated with gaming establishment; determine it transfer is associated with potential money laundering
– also constitute Certain Methods of Organizing Human Activity.
Hence under Prong One of Step 2A, claims 1-20 recite a judicial exception.
Prong 2: Prong Two of Step 2A evaluates whether the claim recites additional elements that integrate the judicial exception into a practical application of the exception.
Limitations that are indicative of integration into a practical application include:
Improvements to the functioning of a computer or to any other technology or technical field – see MPEP 2106.05(a)
Applying the judicial exception with, or by use of, a particular machine – see MPEP 2106.05(b)
Effecting a transformation or reduction of a particular article to a different state or thing – see MPEP 2106.05(c)
Applying or using the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception – see MPEP 2106.05(e)
Limitations that are not indicative of integration into a practical application include:
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)
Adding insignificant extra-solution activity to the judicial exception – see MPEP 2106.05(g)
Generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h)
Additional elements recited by the claims, beyond the abstract idea, include: a system comprising a processor, and memory device; display device; electronic gaming machine; server of a gaming establishment cashless wagering system; electronic fund transfer; display notification; publish to a service bus. Examiner finds that any additional element(s), beyond the judicial exception, has been recited at a high level of generality such that the claim limitations amount to no more than mere instructions to apply the exception using generic components (MPEP 2106.05(f)) or insignificant extra solution activities (MPEP 2106.05 (g)).
The combination of additional elements does not purport to improve the functioning of a computer or effect an improvement in any other technology or technical field. Instead, the additional elements do no more than “use the computer as a tool” and/or “link the use of the judicial exception to a particular technological environment or field of use.” The focus of the claims is not on improvement in computers, but on certain independently abstract ideas – responsive to a receipt of data associated with an approval of an amount of funds transferred from a financial institution account maintained, independent of any gaming establishment, in association with a financial institution and responsive to a determination to employ an [electronic funds transfer funding pathway]: determining, [by a processor] and at least partially based on data associated with prior electronic funds transfers published to a service bus, if the transfer of the amount of funds from the financial institution account complies with a transfer limit, the determination occurs independent of a [server of a gaming establishment cashless wagering system] and independent of any gaming establishment cashless wagering account maintained by the server of the gaming establishment cashless wagering system, and responsive to the determination being that the transfer of the amount of funds from the financial institution account fails to comply with the transfer limit: disabling, [by the processor] and in accordance with the employed electronic funds transfer funding pathway, any modification of a balance of an electronic gaming machine, and displaying, [by a display device], a notification associated with the transfer failing to comply with the transfer limit, and responsive to the determination being that the transfer of the amount of funds from the financial institution account complies with the transfer limit, employing, by the processor, the electronic funds transfer funding pathway to cause a modification of the balance of the [electronic gaming machine], wherein the employment of the [electronic funds transfer funding pathway] comprises a transfer of the amount of the funds from the financial institution account to the balance of the electronic gaming machine independent of any transfer of funds to any gaming establishment cashless wagering account maintained by [the server of the gaming establishment cashless wagering system] and responsive to the transfer to the balance of the [electronic gaming machine], a [master gaming controller of the electronic gaming machine] modifies a first tracked meter based on that transfer – that merely use generic computers as tools. Steps that do no more than spell out what it means to “apply it on a computer” cannot confer patent eligibility. “Indeed, nothing in claim 1 improves the functioning of the computer, makes it operate more efficiently, or solves any technological problem.” See Trading Techs. Int’l, Inc. v. IBG LLC, 921 F.3d 1378, 1384-85 (Fed. Cir. 2019). Hence, under Prong Two of Step 2A, the additional elements, individually or in combination, do not integrate the judicial exception into a practical application.
Hence, the claims are ineligible under Step 2A.
Step 2B: In Step 2B, the evaluation consists of whether the claim recites additional elements that amount to an inventive concept (aka “significantly more”) than the recited judicial exception.
As discussed in Prong Two, the additional elements in the claims amount to no more than mere instructions to apply the exception using generic components. When considered individually or as an ordered combination, the additional elements fail to transform the abstract idea of – responsive to a receipt of data associated with an approval of an amount of funds transferred from a financial institution account maintained, independent of any gaming establishment, in association with a financial institution and responsive to a determination to employ an [electronic funds transfer funding pathway]: determining, [by a processor] and at least partially based on data associated with prior electronic funds transfers published to a service bus, if the transfer of the amount of funds from the financial institution account complies with a transfer limit, the determination occurs independent of a [server of a gaming establishment cashless wagering system] and independent of any gaming establishment cashless wagering account maintained by the server of the gaming establishment cashless wagering system, and responsive to the determination being that the transfer of the amount of funds from the financial institution account fails to comply with the transfer limit: disabling, [by the processor] and in accordance with the employed electronic funds transfer funding pathway, any modification of a balance of an electronic gaming machine, and displaying, [by a display device], a notification associated with the transfer failing to comply with the transfer limit, and responsive to the determination being that the transfer of the amount of funds from the financial institution account complies with the transfer limit, employing, by the processor, the electronic funds transfer funding pathway to cause a modification of the balance of the [electronic gaming machine], wherein the employment of the [electronic funds transfer funding pathway] comprises a transfer of the amount of the funds from the financial institution account to the balance of the electronic gaming machine independent of any transfer of funds to any gaming establishment cashless wagering account maintained by [the server of the gaming establishment cashless wagering system] and responsive to the transfer to the balance of the [electronic gaming machine], a [master gaming controller of the electronic gaming machine] modifies a first tracked meter based on that transfer – into significantly more.
See MPEP 2106.05(f) Mere Instructions To Apply An Exception [R-10.2019].
(2) Whether the claim invokes computers or other machinery merely as a tool to perform an existing process. Use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) or simply adding a general purpose computer or computer components after the fact to an abstract idea (e.g., a fundamental economic practice or mathematical equation) does not integrate a judicial exception into a practical application or provide significantly more.
Hence, the claims are ineligible under Step 2B.
Therefore, the claim(s) are rejected under 35 U.S.C. 101 as being directed to a judicial exception without significantly more.
Claim Rejections - 35 USC § 103
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
Claims 1-20
Claims 1-20 are rejected under 35 U.S.C. 103 as being unpatentable over Shepherd et al. (US 2021/0225125 A1) in view of Shepherd et al. (US 2024/0203203 A1).
Claim 1:
A gaming establishment external funding system comprising:
a processor; and
a memory device that stores a plurality of instructions that, when executed by the processor responsive to a receipt of data associated with an approval of an amount of funds transferred from a financial institution account maintained, independent of any gaming establishment, in association with a financial institution and responsive to a determination to employ an electronic funds transfer funding pathway, cause the processor to:
determine, at least partially based on data associated with prior electronic funds transfers published to a service bus, if the transfer of the amount of funds from the financial institution account complies with a transfer limit, the determination occurring independent of a server of a gaming establishment cashless wagering system, and independent of any gaming establishment cashless wagering account maintained by the server of the gaming establishment cashless wagering system,
(See Shepherd2024: Para [0029] (“In certain embodiments (not shown), the gaming establishment fund management system includes a debit card issuer system. In certain other embodiments, the gaming establishment fund management system is additionally or alternatively in communication with an external debit card issuer system. In these embodiments, the debit card issuer system issues one or more debit cards for a user. For example, the gaming establishment fund management system that maintains the enterprise wallet is in communication with a debit card issuer system to facilitate the access of an amount of funds held in one or more gaming establishment accounts via a debit card provided to the user. In this example, the network of one or more banks or other financial institutions is in communication with the debit card issuer system to facilitate at least the settlement of funds held in one or more gaming establishment accounts accessed via a debit card provided to the user. In certain embodiments, the debit card is independent of any underlying account maintained at any financial institution. Rather, such a debit card operates as an interface to enable a user access to funds held in one or more gaming establishment accounts of the gaming establishment fund management system at one or more channels of commerce associated with the gaming establishment and/or independent of the gaming establishment. In certain other embodiments, the debit card is associated with an account that operates to enable a user just-in-time access to funds held in one or more gaming establishment accounts of the gaming establishment fund management system at one or more channels of commerce associated with the gaming establishment and/or independent of the gaming establishment. It should be appreciated that while illustrated as the gaming establishment fund management system being in communication with one or more debit card issuer systems, in different embodiments, any system or sub-system of the present disclosure can be in communication with one or more debit card issuer systems. It should be further appreciated that in different embodiments, the system utilizes a mobile device running a mobile device application, a kiosk or terminal, a gaming device (e.g., an interface of an EGM or gaming table component), a service window displayed by a gaming device (e.g., a remote host controlled service window displayed by an EGM), a component of a gaming establishment patron management system, such as a player tracking unit, and/or a gaming establishment interface to interface with the debit card issuer system.”)
responsive to the determination being that the transfer of the amount of funds from the financial institution account fails to comply with the transfer limit,
(See Shepherd2021: Para [0013] (“In certain embodiments, if the system determines that the transfer of the amount of funds would cause the balance of funds of the gaming establishment device to reach or exceed a threshold amount, the system interrupts the attempted fund transfer to preempt any potential negative ramifications of such a fund transfer.”)
disable any modification of a balance of an electronic gaming machine employing the electronic funds transfer funding pathway, and
(See Shepherd2021: Para [027] (“In a second example, if the current balance of the credit meter of an EGM is $1450, a maximum credit meter amount of the EGM is $2500 and credit meter restrictions placed on the EGM prevent any transfer of funds to the EGM that result in the balance of the credit meter exceeding $2000 (i.e., the threshold amount of this example), upon the EGM receiving data of a requested amount of $800 to be transferred from the cashless wagering account to the EGM, the component of the gaming establishment management system determines that the resulting $2250 balance of the credit meter of the EGM (if such a transfer would proceed as requested) would exceed the $2000 restricted balance of the credit meter. As such, in this example, the requested fund transfer cannot be completed in its current form as that would cause the EGM to be too close to the $2500 maximum credit meter amount (which may be reached or exceeded upon one or more wins at the EGM).”)
communicate data that results in a display, by a display device, of a notification associated with the transfer failing to comply with the transfer limit, and
(See Shepherd: Para [0035] (“If the cashless wagering system determines not to authorize the determined (or modified) amount of funds, the cashless wagering system communicates a denial to the EGM and/or the mobile device application, wherein the EGM and/or mobile device application (if applicable) display a denial of funds transfer to the player.”)
and responsive to the determination being that the transfer of the amount of funds from the financial institution account complies with the transfer limit, employ the electronic funds transfer funding pathway to cause a modification of the balance of the electronic gaming machine, wherein the employment of the electronic funds transfer funding pathway comprises a transfer of the amount of the funds from the financial institution account to the balance of the electronic gaming machine independent of any transfer of funds to any gaming establishment cashless wagering account maintained by the server of the gaming establishment cashless wagering system and responsive to the transfer to the balance of the electronic gaming machine, a master gaming controller of the electronic gaming machine modifies a first tracked meter based on that transfer.
(See Shepherd2024: Para [0029] (“In certain embodiments (not shown), the gaming establishment fund management system includes a debit card issuer system. In certain other embodiments, the gaming establishment fund management system is additionally or alternatively in communication with an external debit card issuer system. In these embodiments, the debit card issuer system issues one or more debit cards for a user. For example, the gaming establishment fund management system that maintains the enterprise wallet is in communication with a debit card issuer system to facilitate the access of an amount of funds held in one or more gaming establishment accounts via a debit card provided to the user. In this example, the network of one or more banks or other financial institutions is in communication with the debit card issuer system to facilitate at least the settlement of funds held in one or more gaming establishment accounts accessed via a debit card provided to the user. In certain embodiments, the debit card is independent of any underlying account maintained at any financial institution. Rather, such a debit card operates as an interface to enable a user access to funds held in one or more gaming establishment accounts of the gaming establishment fund management system at one or more channels of commerce associated with the gaming establishment and/or independent of the gaming establishment. In certain other embodiments, the debit card is associated with an account that operates to enable a user just-in-time access to funds held in one or more gaming establishment accounts of the gaming establishment fund management system at one or more channels of commerce associated with the gaming establishment and/or independent of the gaming establishment. It should be appreciated that while illustrated as the gaming establishment fund management system being in communication with one or more debit card issuer systems, in different embodiments, any system or sub-system of the present disclosure can be in communication with one or more debit card issuer systems. It should be further appreciated that in different embodiments, the system utilizes a mobile device running a mobile device application, a kiosk or terminal, a gaming device (e.g., an interface of an EGM or gaming table component), a service window displayed by a gaming device (e.g., a remote host controlled service window displayed by an EGM), a component of a gaming establishment patron management system, such as a player tracking unit, and/or a gaming establishment interface to interface with the debit card issuer system.”)
(See also Shepherd2021: Para [0026] (“That is, rather than the EGM determining the ramifications of the potential fund transfer, one or more components of a gaming establishment management system, such as a slot machine interface board (“SMIB”) supported by an EGM cabinet which is in communication with the EGM and monitoring the balance of the credit meter of the EGM, determines, based on the current balance of the credit meter of the EGM, the threshold balance of the credit meter of the EGM and the determined amount of funds to be transferred, whether the completed transfer of funds would result in the balance of the credit meter of the EGM reaching or exceeding the threshold balance of the credit meter. For example, as seen in FIG. 1A, the system of the present disclosure utilizes, for each individual EGM 102, a SMIB 104 (i.e., a component of a gaming establishment management system 106) in communication with the gaming establishment management system and that EGM to be aware of the balance of a credit meter 108 of that EGM and function as a gatekeeper regarding fund transfers to the EGM from a cashless wagering system 110.”)
Therefore, it would have been obvious to a person having ordinary skills in the art before the effective filing date of the invention to modify the above noted disclosure of Shepherd2021 as it relates to gaming device fund transfer to include the above noted disclosure of Shepherd2024 as it relates to funding gaming establishment with external account payment instrument. The motivation for combining the references would have been to employ enhanced security measures to prevent fraud during fund transfer to gaming device.
Claims 10 and 12 are similar to claim 1 and hence rejected on similar grounds.
Claim 2:
responsive to the determination being that the transfer of the amount of funds from the financial institution account fails to comply with the transfer limit, cause the processor prevent a subsequent transfer of any amount of funds from the financial institution account to the electronic gaming machine.
(See Shepherd2021: Para [0057])
Claim 13 is similar to claim 2 and hence rejected on similar grounds.
Claim 3:
responsive to the determination being that the transfer of the amount of funds from the financial institution account fails to comply with the transfer limit, cause the processor to enable an employment of a wagering account transfer funding pathway comprising a first transfer of the amount of funds from the financial institution account to the gaming establishment cashless wagering account, followed by a second transfer of the amount of funds from the gaming establishment cashless wagering account to the balance of the electronic gaming machine which modifies a second, different tracked meter based on that transfer
(See Shepherd2021: Para [0060], [0061])
Claim 14 is similar to claim 3 and hence rejected on similar grounds.
Claim 4:
responsive to the determination being that the transfer of the amount of funds from the financial institution account complies with the transfer limit, cause the processor to publish, to the service bus, data associated with the transfer of the amount of funds from the financial institution account.
(See Shepherd2021: Para [0075])
Claim 15 is similar to claim 4 and hence rejected on similar grounds.
Claim 5:
wherein the transfer limit is associated with at least one of an amount transferrable from the financial institution account over a period of time and an amount transferrable in association with a user over a period of time.
(See Shepherd2021: Para [0086])
Claim 16 is similar to claim 5 and hence rejected on similar grounds.
Claim 6:
responsive to the determination being that the transfer of the amount of funds from the financial institution account fails to comply with the transfer limit, cause the processor to modify the transfer limit based on an action undertaken by a user.
(See Shepherd2021: Para [0029])
Claim 17 is similar to claim 6 and hence rejected on similar grounds.
Claim 7:
wherein the action comprises at least one of: the user authorizing a know-your-customer check, the user signing up for a gaming establishment patron management system account, and the user engaging with gaming establishment personnel.
(See Shepherd2021: Para [0065])
Claim 18 is similar to claim 7 and hence rejected on similar grounds.
Claim 8:
wherein the determination to employ the electronic funds transfer funding pathway is based on a user associated with the financial institution account not being associated with the any gaming establishment cashless wagering account maintained by the server of the gaming establishment cashless wagering system
(See Shepherd2024: Para [0039])
Claim 19 is similar to claim 8 and hence rejected on similar grounds.
Claim 9:
wherein the determination of if the transfer of the amount of funds from the financial institution account complies with the transfer limit is based on if the transfer of the amount of funds is associated with any potential money laundering activities.
(See Shepherd2024: Para [0056])
Claim 20 is similar to claim 9 and hence rejected on similar grounds.
Claim 11:
wherein the transfer limit comprises a responsible gaming limit.
(See Shepherd2024: Para [0057])
Response to Arguments
Applicant's arguments filed 7/13/2026 have been fully considered but they are not persuasive.
101
Applicant argues that the existing configuration of desperate [sic] systems performing defined roles (e.g., gaming establishment cashless wagering systems determine compliance with transfer limits on funds from financial institution accounts) creates a technical problem when such fund transfers occur independent of certain systems (e.g., transfer limits still need to be adhered to even if a transfer bypasses such gaming establishment cashless wagering systems).
Examiner finds this unpersuasive because managing compliance with disparate systems is not a technical problem but a mere legal and administrative function. The fact that a funding pathway that bypasses any gaming establishment cashless wagering accounts maintained by a gaming establishment cashless wagering system is otherwise incapable of enforcing transfer limits on funds transferred from a financial institution account – is a fund transfer feature or loophole that is endemic in all fund transfers in the world. This is not a technical problem in need of technical solutions because enforcing limit on fund transfer is a legal and financial activity not a technical one. Courts have held that enforcing spending restrictions is nothing more than a financial or budgetary restriction on commerce and hence falls under the Commercial/Legal Interactions category of abstract ideas. See MPEP II. CERTAIN METHODS OF ORGANIZING HUMAN ACTIVITY (“An example of a claim reciting managing personal behavior is Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 115 USPQ2d 1636 (Fed. Cir. 2015). The patentee in this case claimed methods comprising storing user-selected pre-set limits on spending in a database, and when one of the limits is reached, communicating a notification to the user via a device. 792 F.3d. at 1367, 115 USPQ2d at 1639-40. The Federal Circuit determined that the claims were directed to the abstract idea of “tracking financial transactions to determine whether they exceed a pre-set spending limit (i.e., budgeting)”, which “is not meaningfully different from the ideas found to be abstract in other cases before the Supreme Court and our court involving methods of organizing human activity.” 792 F.3d. at 1367-68, 115 USPQ2d at 1640.”).
For the above reasons, the applicant’s arguments are not persuasive.
Previously Addressed Arguments
Applicant argues that claim 1 provides a solution to the recognized problems associated with bypassing regulated gaming establishment account to transfer funds to gaming establishment devices in violation of regulatory transfer limits and anti-money laundering limits. Applicant argues that non-cash and non-ticket based option reduce cash and human errors.
Examiner find the above arguments unpersuasive because they further confirm that the claims are directed to Certain Methods of Organizing Human Activity as opposed to improving computers or technology. The purported advantages of the invention mentioned by the Applicant such as reduction in use of cash at gaming establishment are in the human realm rather than the technological realm. Transferring funds from financial institution to a gaming establishment account is a Fundamental Economic Practice and/or Commercial/Legal Interaction as opposed to technical improvement. See SAP Am., Inc. v. InvestPic, LLC, 898 F.3d 1161, 1170 (Fed. Cir. 2018) (“[P]atent law does not protect such claims[, i.e., claims to an asserted advance in the realm of abstract ideas], without more, no matter how groundbreaking the advance.”). But “[n]o matter how much of an advance in the … field the claims recite, the advance lies entirely in the realm of abstract ideas, with no plausibly alleged innovation in the non-abstract application realm.” SAP Am., Inc. v. Investpic, LLC 898 F.3d 1161, 1163 (Fed. Cir. 2018). Eliminating gaming establishment personnel from distributing cash and issuing ticket vouchers in exchange for cash may reduce instances of fraud or corruption but it does not achieve an improved technological result. The combination of additional elements does not bring about (i) an improvement to the functionality of a computer or other technology or technical field; (ii) a “particular machine” to apply or use the judicial exception; (iii) a particular transformation of an article to a different thing or state; or (iv) any other meaningful limitation. See MPEP 2106.05(a)-(c), (e)-(h). Hence, the additional elements fail to integrate the recited combination of abstract idea(s) into a practical application or provide significantly more. See MPEP 2106.05(f).
With respect to the argument that the elements are not generic, conventional or well-known, Examiner notes that the limitation that the limitation identified by the Applicant “responsive to a determination to employ a funds transfer funding pathway … if the transfer of the amount of funds from the financial institution account complies with a transfer limit” is part of the abstract idea and not additional elements. As explained in Prong 2 and Step 2B, the additional elements have been described at a high level of generality so that, when considered as a whole, the claim limitations amount to no more than mere instructions to apply the exception using generic computer components, which is insufficient to provide an inventive concept or provide significantly more.
For the above reasons, Applicant’s arguments are not persuasive.
103
Applicant’s arguments filed 7/13/2026 have been considered but they are moot in view of the new grounds for rejection.
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, 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 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 ARUNAVA CHAKRAVARTI whose telephone number is (571)270-1646. The examiner can normally be reached 9 AM - 5 PM ET.
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/ARUNAVA CHAKRAVARTI/Primary Examiner, Art Unit 3692
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