DETAILED ACTION
Status of Claims
1. This office action is in response to RCE filed 12/29/2025.
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 .
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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.
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]
Independent claims 1 and 12 recite the limitations – determining if the transfer of funds from financial institution to gaming establishment complies with transfer limit, disable modification of gaming account balance, and notify for failing to comply with transfer limit – that constitute Fundamental Economic Practices and/or Commercial/Legal Interactions.
Independent clam 10 recites – 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; responsive to a determination that a user associated with the financial institution account is associated with a gaming establishment account maintained by a gaming establishment fund management system, independent of imposing a transfer limit distinct from any transfer limit imposed by the gaming establishment fund management system, activate a wagering account transfer funding pathway comprising: causing a first transfer of the amount of funds to the gaming establishment account, and causing a second transfer of the amount of funds from the gaming establishment account to a balance of a gaming establishment device, and responsive to a determination that the user associated with the financial institution account is not associated with any gaming establishment accounts maintained by the gaming establishment fund management system, activate a funds transfer funding pathway comprising causing, independent of any wagering account transfers associated with the gaming establishment device, a transfer of the amount of funds to the balance of the gaming establishment device, wherein the funds transfer funding pathway is associated with a transfer limit imposed independent of the gaming establishment fund management system – that constitutes Fundamental Economic Practices and/or Commercial/Legal Interactions.
Hence the independent claims fall under the abstract idea category Certain Methods of Organizing Human Activity.
The dependent claims further limit the abstract idea to – 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 – that 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; gaming establishment device; 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 – if the transfer of funds from financial institution to gaming establishment complies with transfer limit, then transfer funds to gaming establishment account and then to gaming device account balance; if transfer fails to comply with transfer limit, disable modification of gaming device account balance, then notify for failing to comply with transfer limit – 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, which is insufficient to provide an inventive concept.
When considered individually or as an ordered combination, the additional elements fail to transform the abstract idea of – if the transfer of funds from financial institution to gaming establishment complies with transfer limit, then transfer funds to gaming establishment account and then to gaming device account balance; if transfer fails to comply with transfer limit, then disable gaming device account balance, and notify for failing to comply with transfer limit – 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 Sommer (US 2008/0113776 A1) over Shepherd et al. (US 2021/0225125 A1).
Claim 1:
A 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, cause the processor to:
responsive to a determination to employ an electronic funds transfer funding pathway, determine, 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 occurs independent of any component of a gaming establishment fund management system, and independent of any gaming establishment account maintained by any component of the gaming establishment fund management system, and
(See Sommer: Para
[0039] (“Financial transactions between the gaming establishment and the financial institution may be processed by a third party financial transaction provider, also known as an agent or an intermediary.”)
[0046] (“the player issues a single request to withdraw funds from multiple accounts at 3 different financial institutions by identifying Citibank $100, Chase $200, Wells Fargo $300 and entering a single password associated with the identifier issued by the gaming establishment at the gaming device”)
[0050] (“the intermediary looks up the account numbers associated with Citibank, Chase, and Wells Fargo based on the identifier issued by the intermediary;”)
[0052] (“the intermediary transfers the funds to the gaming server”)
[0092] (“When a player attempts to withdraw funds from an account, the system may need to verify that the transaction request amount may not exceed configured limits.”)
[0101] (“E.g. Acct #### — Total Withdrawn: $300 within the past 24 hours. Total Deposited: $500 within the past 24 hours, Deposit Request of $1000.”)
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 Shepherd: 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, in accordance with the employed electronic funds transfer funding pathway, any modification of a balance of a gaming establishment device occurring independent of any transfer of funds involving a gaming establishment account maintained by the gaming establishment fund management system, and
(See Shepherd: 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.
(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.”)
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 Sommer as it relates to cashless gaming to include the above noted disclosure of Shepherd as it relates to gaming device fund transfer. The motivation for combining the references would have been to earn credits by enabling fund transfer using virtual ticket vouchers
.
Claim 12 is 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 gaming establishment device.
(See Shepherd: 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 complies with the transfer limit, cause the processor to cause a modification of the balance of the gaming establishment device, wherein the transfer occurs independent of any transfer of funds to a gaming establishment account maintained by the gaming establishment fund management system.
(See Shepherd: Para [0055])
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 Shepherd: 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 Shepherd: 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 Shepherd: 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 Shepherd: 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 gaming establishment account maintained by the gaming establishment fund management system.
(See Sommer: Para [0046])
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 Sommer: Para [0028])
Claim 20 is similar to claim 9 and hence rejected on similar grounds.
Claim 10:
A 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, cause the processor to:
(See Sommer: Para [0035] (“Assuming the financial institutions approve the transactions of step 112, the funds are transferred to the gaming server, more specifically into the player account.”)
responsive to a determination that a user associated with the financial institution account is associated with a gaming establishment account maintained by a gaming establishment fund management system, independent of imposing a transfer limit distinct from any transfer limit imposed by the gaming establishment fund management system, activate a wagering account transfer funding pathway comprising:
(See Shepherd: Para [0128] (“After a player appropriately funds the EGM and places a wager, the EGM activates the game play activation device to enable the player to actuate the game play activation device to initiate a play of a game on the EGM”)
causing a first transfer of the amount of funds to the gaming establishment account, and
(See Sommer: Para [0035] (“By following an industry standard protocol, the gaming establishment enables a variety of transaction types including credit, EFT, and other transactions. Assuming the financial institutions approve the transactions of step 112, the funds are transferred to the gaming server, more specifically into the player account”)
causing a second transfer of the amount of funds from the gaming establishment account to a balance of a gaming establishment device, and
(See Sommer: Para [0035] (“The funds transferred to the player account are then converted to credits (step 116) and transferred as credits to the gaming device (step 118) for game play. However, some embodiments may allow currency equivalents to be wagered directly at the gaming device.”)
responsive to a determination that the user associated with the financial institution account is not associated with any gaming establishment accounts maintained by the gaming establishment fund management system, activate an electronic funds transfer funding pathway comprising causing, independent of any wagering account transfers associated with the gaming establishment device, a transfer of the amount of funds to the balance of the gaming establishment device, wherein the activated electronic funds transfer funding pathway is associated with a transfer limit imposed independent of the gaming establishment fund management system.
system, and independent of any gaming establishment accounts, and a determination of whether the transfer limit is reached is at least partially based on data associated with prior activated electronic funds transfer funding pathways published to a service bus.
(See Shepherd: 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.”)
[0061] (“In certain embodiments, the credit meter monitoring component (whether or not the credit meter monitoring component receives fund transfer data independent of the cashless wagering system) determines, based on the amount of the credit meter, the designated amount of the credit meter and the amount to be added to the credit meter in association with a credit meter increase event, to automatically initiate a transfer of funds from a credit meter of an EGM to a cashless wagering system account associated with a player of the EGM.”)
Claim 11:
wherein the transfer limit comprises a responsible gaming limit.
(See Sommer: Para [0092])
Response to Arguments
Applicant's arguments filed 12/29/2025 have been fully considered but they are not persuasive.
101
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 12/29/2025 have been considered but they are moot in view of the new grounds for rejection.
Previously Addressed
Applicant argues that Sommer does not invoke transfer limits independent of any component of the gaming establishment system.
Examiner finds this unpersuasive because the financial institutions disclosed in Summer – Citibank, Chase and Wells Fargo – are all independent of the gaming establishment. All three are independent global financial institutions that involve an intermediary (Summer: Para [0039]) to lookup account numbers for the player and performs the task of transferring funds to the player account associated with the player identifier (Summer: Para [0052]). For the above reasons, applicant’s arguments are not persuasive.
Conclusion
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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