DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Status of the Claims
Claims 1-20 are presented for examination. Applicant filed a request for continued examination (RCE) on 04/08/2026 amending claims 1, 6, 9, and 11-20. In light of Applicant’s amendments, Examiner has withdrawn the previous objection of claims 9, 11-12, 14-17, and 19-20; the previous § 101 rejection and the previous grounds of § 103 rejection of claims 1-20. Examiner has, however, established new objections for claims 1, 9, and 17-20; and new § 101 rejection for claims 1-20 in the instant Office action.
Examiner’s Remarks
Patent Eligibility under § 101:
Applicant argues that instant claims 1-20 are patent eligible under § 101. Applicant argues – similarly to the arguments filed 09/15/2025 – in pages 15-23 of Applicant’s Remarks:
Analysis Under Step 2A, Prong 2: The Claims Integrate the Alleged Judicial Exception into a Practical Application or Improvement to Technology
. . .
[A]ccording to Applicant's record of the February 4, 2026 Applicant-Initiated Examiner Interview, Examiner Kanervo indicated that the recited limitations of amended dependent claim 18, arising from paragraph [0045] related to including more than one audit trail per token and each having different information and enabling the use of fewer computing resources to audit a purpose-specific audit trail, appeared to be eligible subject matter under 35 U.S.C. §101.
Examiner respectfully disagrees. Without repeating the answers to Applicant’s arguments from September of 2025, the newly amended claims do not render instant claims patent eligible under § 101 because claims are recited in high level of abstraction and they lack details and specifics as to how a technological solution to a problem of technology has been achieved. Further, Examiner did not agree during the interview held on 02/04/2026 that the Applicant-proposed amendment rendered instant claims patent eligible under § 101 but that those proposed amendments distinguished over the cited prior art references (as is evidenced by the Examiner’s summary of that interview).
Prior Art under § 102 and § 103: The closest prior art reference located by Examiner, Mu (CN 115471227 A), does not disclose – alone or in combination with other references – the following limitations found in independent claims 1, 9, and 17, as an ordered combination of steps with other claim limitations:
retrieve the first audit trail associated with the first digital currency token associated with the first transaction, the first audit trail comprising a log of transactions configured to yield a fraud insight without compromising personal information of a wallet holder of the initial sending wallet, the intermediate wallet, or the final receiving wallet, the first transaction being a part of the chain of transactions and associated with the first digital currency token, the first audit trail being a part of the first digital currency stored on the blockchain, and the first audit trail tracing, independently of a third-party intermediary server configured to validate or sign the first digital currency token, a transaction chain of the first digital currency;
based at least on analyzing the first audit trail and the analyzing yielding at least the fraud insight, detect wallet cloning or value manipulation in the first digital currency token associated with the first transaction; and
based on designating the first transaction as the fraud transaction, block the fraud transaction in real time by declining the chain of transactions to transfer the digital currency.
Claim Objections
Claims 1, 9, and 17, are objected because of informality in the following recitation:
. . . retrieve the first audit trail associated with the first digital currency token associated with the first transaction, the first audit trail comprising a log of transactions configured to yield a fraud insight without compromising personal information of a wallet holder of the initial sending wallet, the intermediate wallet, or the final receiving wallet . . .
There should be “at least one” in front of “intermediate wallet.” Applicant could amend claims 1, 9, and 17, to recite:
. . . retrieve the first audit trail associated with the first digital currency token associated with the first transaction, the first audit trail comprising a log of transactions configured to yield a fraud insight without compromising personal information of a wallet holder of the initial sending wallet, the at least one intermediate wallet, or the final receiving wallet . . .
Claims 17-20 are objected because of informality in the following recitation:
A/The non-transitory computer storage medium . . .
There should be the word “readable” between “computer” and “storage medium.” Applicant could amend claims 17-20 to recite:
A/The non-transitory computer readable storage medium . . .
Claim 18 is objected because of informality in the following recitation:
. . . the computer-executable instructions, upon execution by a processor, further causing the processor to at least reduce a computing resource requirement for detecting the fraud transaction by processing only the first audit trail.
There should be definite article “the” in front of “processor.” Applicant could amend claim 18 to recite:
. . . the computer-executable instructions, upon execution by [[a]] the processor, further causing the processor to at least reduce a computing resource requirement for detecting the fraud transaction by processing only the first audit trail.
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 rejected under 35 USC § 101 because they are directed to non-statutory subject matter. The rationale for this finding is explained below.
The Supreme Court in Mayo laid out a framework for determining whether an applicant is seeking to patent a judicial exception itself or a patent-eligible application of the judicial exception. See Alice Corp., 134 S. Ct. at 2355,110 USPQ2d at 1981 (citing Mayo, 566 U.S. 66, 101 USPQ2d 1961). This framework, which is referred to as the Mayo test or the Alice/Mayo test (“the test”), is described in detail in Manual of Patent Examining Procedure (”MPEP”) (see MPEP § 2106(III) for further guidance). The step 1 of the test: It need to be determined whether the claims are directed to a patent eligible (i.e., statutory) subject matter under 35 USC § 101. Step 2A of the test: If the claims are found to be directed to a statutory subject matter, the next step is to determine whether the claims are directed to a judicial exception i.e., law of nature, natural phenomenon, and abstract idea (Prong 1). If the claims are found to be directed to an abstract idea, it needs to be determined whether the claims recite additional elements that integrate the judicial exception into a practical application (Prong 2). Step 2B of the test: If the claims are directed to a judicial exception, the next and final step is to determine whether the claims recite additional elements that amount to significantly more than the judicial exception.
Step 1 of the Test:
When considering subject matter eligibility under 35 USC § 101, it must be determined whether the claim is directed to one of the four statutory categories of invention, i.e., process, machine, manufacture, or composition of matter. Here, the claimed invention of claims 1-8 is a system and, thus, one of the statutory categories of invention. Further, the claimed invention of claims 9-16 is a series of steps, which is method (i.e., a process), which is also one of the statutory categories of invention. Still further, the claimed invention of claims 17-20 is a non-transitory computer-readable medium, which is also one of the statutory categories of invention.
Conclusion of Step 1 Analysis: Therefore, claims 1-20 are statutory under 35 USC § 101 in view of step 1 of the test.
Step 2A of the Test:
Prong 1: Claims 1-20, however, recite an abstract idea of chaining transactions for fraud prevention. The creation of chaining transactions for fraud prevention, as recited in the independent claims 1, 9, and 17, belongs to certain methods of organizing human activity (i.e., fundamental economic principles or practices including mitigating risk) that are found by the courts to be abstract ideas. The limitations in independent claims 1, 9, and 17, which set forth or describe the recited abstract idea, are found in the following steps:
“based at least on analyzing the first audit trail and the analyzing yielding at least the fraud insight, detect wallet cloning or value manipulation in the first digital currency token associated with the first transaction” (claim 1);
“based on detecting the wallet cloning or value manipulation, designate the first transaction as the fraud transaction” (claim 1);
“based on designating the first transaction as the fraud transaction, block the fraud transaction in real time by declining the chain of transactions to transfer the digital currency” (claim 1);
“generating one or more audit trails associated with a chain of transactions to transfer a digital currency from an initial sending wallet via at least one intermediate wallet to a final receiving wallet on a blockchain, the digital currency being divided into one or more digital currency tokens, the one or more digital currency tokens including a first digital currency token associated with a first transaction of the chain of transactions and having a first audit trail of the one or more audit trails, the initial sending wallet or the at least one intermediate wallet digitally appending an element of a digital credential of the initial sending wallet or the at least one intermediate wallet to each digital currency token of the one or more digital currency tokens and cryptographically signing the each digital currency token of the one or more digital currency tokens prior to transferring the one or more digital currency tokens to the final receiving wallet, and the each digital currency token maintaining the first audit trail of digital wallets that the each digital currency token transacted through before being received by the final receiving wallet” (claims 9 and 17);
“based at least on analyzing the first audit trail and the analyzing yielding at least the fraud insight, detecting wallet cloning or value manipulation in the first digital currency token associated with the first transaction” (claims 9 and 17);
“based on detecting the wallet cloning or value manipulation, designating the first transaction as the fraud transaction” (claims 9 and 17); and
“based on designating the first transaction as the fraud transaction, block the fraud transaction in real time by declining the chain of transactions to transfer the digital currency” (claims 9 and 17).
Prong 2: In addition to abstract steps recited above in Prong 1, independent claims 1 and 17 recite additional elements (note: claim 9 does not recite additional elements):
“a processor” (claim 1);
“a memory storing instructions that are operative upon execution by the processor” (claim 1);
“a computer storage medium storing computer-executable instructions” (claim 17); and
“a processor” (claim 17).
These additional elements are recited at a high level of generality (i.e., as a generic processor performing a generic computer functions) such that they amount to no more than mere instructions to apply the exception using a generic computer component. Also, following additional limitations recite insignificant extra solution activity (for example, data gathering):
“receive a request to identify whether a chain of transactions to transfer digital currency from an initial sending wallet via at least one intermediate wallet to a final receiving wallet on a blockchain is the fraud transaction, the digital currency comprising a first digital currency token associated with a first transaction and having a first audit trail” (claim 1);
“retrieve the first audit trail associated with the first digital currency token associated with the first transaction, the first audit trail comprising a log of transactions configured to yield a fraud insight without compromising personal information of a wallet holder of the initial sending wallet, the intermediate wallet, or the final receiving wallet, the first transaction being a part of the chain of transactions and associated with the first digital currency token, the first audit trail being a part of the first digital currency token stored on the blockchain, and the first audit trail tracing, independently of a third-party intermediary server configured to validate or sign the first digital currency token, a transaction chain of the first digital currency token comprising at least: the initial sending wallet, the at least one intermediate wallet through which the first digital currency token traveled before being received by the final receiving wallet, and the final receiving wallet” (claim 1);
“receiving a request to identify whether the first transaction is a fraud transaction” (claims 9 and 17); and
“in response to receiving the request: retrieving the first audit trail associated with the first digital currency token associated with the first transaction, the first audit trail comprising a log of transactions configured to yield a fraud insight without compromising personal information of a wallet holder of the initial sending wallet, the intermediate wallet, or the final receiving wallet, the first audit trail being a part of the first digital currency token stored on the blockchain, and the first audit trail tracing, independently of a third-party intermediary server configured to validate or sign the first digital currency token, a transaction chain of the first digital currency token comprising at least the initial sending wallet, the at least one intermediate wallet through which the first digital currency token traveled before being received by the final receiving wallet, and the final receiving wallet” (claims 9 and 17).
These additional elements/limitations do not integrate the abstract idea into a practical application because they do not impose a meaningful limit on the judicial exception. The additional limitations of independent claims 1, 9, and17, here do not render improvements to the functioning of a computer or to any other technology or technical field (see MPEP § 2106.05(a)), nor do they integrate the abstract idea into a practical application under MPEP § 2106.05(b) (particular machine); MPEP § 2106.05(c) (particular transformations); or MPEP § 2106.05(e) (other meaningful limitations). Further, the combination of these additional elements/limitations is no more than mere instructions to apply the exception using a generic device. Accordingly, even in combination, these additional elements/ limitations do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
Conclusion of Step 2A Analysis: Therefore, independent claims 1, 9, and 17, are non-statutory under 35 USC § 101 in view of step 2A of the test.
Step 2B of the Test: The additional elements of independent claims 1 and 17 (see above under Step 2A - Prong 2 are individually well-understood, routine, and conventional elements that amount to no more than implementing the abstract idea with a computerized system. The Applicant’s Specification describes these additional elements in following terms:
[0048] The present disclosure is operable with a computing apparatus according to an embodiment as a functional block diagram 600 in FIG. 6. In an example, components of a computing apparatus 618 are implemented as a part of an electronic device according to one or more embodiments described in this specification. The computing apparatus 618 comprises one or more processors 619 which may be microprocessors, controllers, or any other suitable type of processors for processing computer executable instructions to control the operation of the electronic device. Alternatively, or in addition, the processor 619 is any technology capable of executing logic or instructions, such as a hard-coded machine. In some examples, platform software comprising an operating system 620 or any other suitable platform software is provided on the apparatus 618 to enable application software 621 to be executed on the device. In some examples, detecting fraud transactions in peer-to-peer payments without an intermediary as described herein is accomplished by software, hardware, and/or firmware.
[0049] In some examples, computer executable instructions are provided using any computer-readable media that is accessible by the computing apparatus 618. Computer-readable media include, for example, computer storage media such as a memory 622 and communications media. Computer storage media, such as a memory 622, include volatile and non-volatile, removable, and non-removable media implemented in any method or technology for storage of information such as computer readable instructions, data structures, program modules or the like. Computer storage media include, but are not limited to, Random Access Memory (RAM), Read-Only Memory (ROM), Erasable Programmable Read-Only Memory (EPROM), Electrically Erasable Programmable Read-Only Memory (EEPROM), persistent memory, phase change memory, flash memory or other memory technology, Compact Disk Read-Only Memory (CD-ROM), digital versatile disks (DVD) or other optical storage, magnetic cassettes, magnetic tape, magnetic disk storage, shingled disk storage or other magnetic storage devices, or any other non-transmission medium that can be used to store information for access by a computing apparatus. In contrast, communication media may embody computer readable instructions, data structures, program modules, or the like in a modulated data signal, such as a carrier wave, or other transport mechanism. As defined herein, computer storage media does not include communication media. Therefore, a computer storage medium does not include a propagating signal. Propagated signals per se are not examples of computer storage media. Although the computer storage medium (the memory 622) is shown within the computing apparatus 618, it will be appreciated by a person skilled in the art, that, in some examples, the storage is distributed or located remotely and accessed via a network or other communication link (e.g., using a communication interface 623).
This is a description of general-purpose computer. Further, the additional limitations of “receiving” and “retrieving” information amount to no more than mere instructions to apply the exception using generic computer components. For the same reason these limitations are not sufficient to provide an inventive concept. The additional limitations of “receiving” and “retrieving” information were considered insignificant extra-solution activity in Step 2A - Prong 2. Re-evaluating here in Step 2B, they are also determined to be well-understood, routine, and conventional activity in the field. Similarly to OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1093 (Fed. Cir. 2015) (sending messages over a network), and buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014) (computer receives and sends information over a network), the additional elements of independent claims 1, 9, and 17, receive or transmit data over a network in a merely generic manner. Further, similarly to Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015) and OIP Techs., 788 F.3d at 1363, 115 USPQ2d at 1092-93, the additional elements of independent claims 1, 9, and 17, retrieve information. The courts have recognized “receiving” and “retrieving” information functions as well-understood, routine and conventional when claimed in a merely generic manner. Therefore, the additional elements/ limitations of independent claims 1, 9, and 17, are well-understood, routine, and conventional. Further, taken as combination, the additional elements/limitations add nothing more than what is present when the additional elements/limitations are considered individually. There is no indication that the combination provides any effect regarding the functioning of the computer or any improvement to another technology.
Conclusion of Step 2B Analysis: Therefore, independent claims 1, 9, and 17, are non-statutory under 35 USC § 101 in view of step 2B of the test.
Dependent Claims: Dependent claims 2-8 depend on independent claim 1; dependent claims 10-16 depend on independent claim 9; and dependent claims 18-20 depend on independent claim 17. The elements in dependent claims 2-8, 10-16, and 18-20, which set forth or describe the abstract idea, are:
“analyzing the first audit trail comprises: analyzing token value manipulation in the first digital currency token, analyzing whether the first digital currency token is a clone of a second digital currency token, or analyzing whether the first digital currency token is a counterfeit token” (claims 2 and 10: further narrowing the recited abstract idea);
“the first audit trail is encrypted and attached to the first digital currency token” (claim 3: further narrowing the recited abstract idea);
“an encryption key used to encrypt the first audit trail is issued by one or more issuer servers” (claim 4: further narrowing the recited abstract idea);
“the first audit trail is encrypted multiple times using at least two encryption keys” (claim 5: further narrowing the recited abstract idea);
“a decryption key for decrypting the first audit trail is encrypted with encryption keys of at least one audit trail decryption key holder” (claim 6: further narrowing the recited abstract idea);
“the first audit trail is stored multiple times with the first digital currency token, wherein each copy of the first audit trail is encrypted with one or more audit trail encryption keys” (claim 7: further narrowing the recited abstract idea); and
“prior to receiving the request to identify the fraud transaction, the initial sending wallet or the at least one intermediate wallet: generating the first audit trail; and storing the first audit trail as the part of the first digital currency token” (claim 8: further narrowing the recited abstract idea);
“the first audit trail associated with the each digital currency token of the one or more digital currency tokens is encrypted and attached to the each digital currency token” (claim 11: further narrowing the recited abstract idea);
“an encryption key used to encrypt the first audit trail associated with the each digital currency token of the one or more digital currency tokens is issued by one or more issuer servers” (claim 12: further narrowing the recited abstract idea);
“the first audit trail associated with the each digital currency token of the one or more digital currency tokens is encrypted multiple times using at least two encryption keys” (claim 13: further narrowing the recited abstract idea);
“a decryption key for decrypting the first audit trail associated with the each digital currency token of the one or more digital currency tokens is encrypted with encryption keys of at least one audit trail decryption key holder” (claim 14: further narrowing the recited abstract idea);
“the first audit trail associated with the each digital currency token of the one or more digital currency tokens is stored multiple times with each associated digital currency token, wherein each copy of the first audit trail associated with the each digital currency token of the one or more digital currency tokens is encrypted with one or more audit trail encryption keys” (claim 15: further narrowing the recited abstract idea);
“the first audit trail associated with the each digital currency token of the one or more digital currency tokens is stored in a different blockchain” (claim 16: further narrowing the recited abstract idea);
“analyzing the first audit trail comprises: analyzing token value manipulation in the first digital currency token, analyzing whether the first digital currency token is a clone of a second digital currency token, or analyzing whether the first digital currency token is a counterfeit token; or the first digital currency token associated with the first transaction of the chain of transactions further having a second audit trail of the one or more audit trails, the second audit trail having an other screening purpose, and the computer-executable instructions, upon execution by a processor, further causing the processor to at least reduce a computing resource requirement for detecting the fraud transaction by processing only the first audit trail” (claim 18: further narrowing the recited abstract idea);
“the first audit trail associated with the each digital currency token of the one or more digital currency tokens is encrypted and attached to the first digital currency token” (claim 19: further narrowing the recited abstract idea); and
“the first audit trail associated with the each digital currency token of the one or more digital currency tokens is stored in a different blockchain” (claim 20: further narrowing the recited abstract idea).
Conclusion of Dependent Claims Analysis: Dependent claims 2-8, 10-16, and 18-20, do not correct the deficiencies of independent claims 1, 9, and 17, and they are, thus, rejected on the same basis.
Conclusion of the 35 USC § 101 Analysis: Therefore, claims 1-20 are rejected as directed to an abstract idea without “significantly more” under 35 USC § 101.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Yamazaki (US 2022/0012727 A1) discloses: “[0166] The blockchain server 103 is configured to generate the transaction ID 1503, generate the block BL2 including the first piece of converted data (hash value 703) and the transaction ID 1503, add the block BL2 to the blockchain 500, and transmit the transaction ID 1503 to the task processing server 101. With this configuration, it is possible to add the audit trail relating to the deletion to the blockchain 500 while deleting pieces of accompanying information 702 on the user in units of types, to thereby facilitate the examination of whether or not a fraud has been committed.”
Mu (WO 2022218417 A1) discloses: “The present disclosure relates to a method, terminal and system for splitting, verifying and managing digital currency in a transaction, mainly relating to the technical field of computers. A specific embodiment of the method comprises: determining a first transaction request indicating a digital currency and first transaction information; according to the first transaction information, generating second transaction information comprising a second transaction amount; using a private key of a first terminal, respectively signing the first transaction information and the second transaction information; according to the signed first transaction information and the digital currency, generating a first trust chain, and according to the signed second transaction information and the digital currency, generating a second trust chain; and sending the first trust chain to a second terminal, so that the second terminal and the first terminal, according to the first trust chain, achieve an offline transaction corresponding to the first transaction amount included in the first transaction information. Said embodiment may improve the security of an offline transaction while facilitating the use of a digital currency in performing an offline transaction.”
Raj, Arman, et al. "Enhancing security feature in financial transactions using multichain based blockchain technology." 2023 4th International Conference on Intelligent Engineering and Management (ICIEM). IEEE, 2023.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to VIRPI H. KANERVO whose telephone number is 571-272-9818. The examiner can normally be reached on Monday – Friday, 10 am – 6 pm. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor Abhishek Vyas can be reached on 571-270-1836. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/VIRPI H KANERVO/Primary Examiner, Art Unit 3691
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