CTFR 18/625,978 CTFR 83995 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. This office action is in response to applicant's communication of December 29, 2025. The rejections are stated below. Claims 1-20 are pending and have been examined. Response to Amendment/Arguments Applicant’s arguments concerning claims 9 and 13 rejected under 35 U.S.C. 112(a) have been considered and are persuasive so therefore the rejection has been withdrawn. Applicant’s arguments concerning claims 1-20 rejected under 35 U.S.C. 112(b) have been considered and are persuasive so therefore the rejection has been withdrawn. Applicant’s arguments concerning 35 U.S.C. 101 have been considered but are not persuasive. Examiner has considered Applicant’s Remarks filed in response to the Office Action dated October 1, 2025. Applicant has amended claims 1 and 13 and argues that the rejected claims 1 to 20 are patent eligible under 35 U.S.C. § 101. Applicant cites the Federal Circuit decision in Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016), among other authorities. Applicant requests withdrawal of the § 101 rejection. The Supreme Court’s two step framework in Alice Corp. v. CLS Bank International, 573 U.S. 208 (2014), governs the subject matter eligibility analysis. The Examiner applied Alice as the controlling precedent. Applicant’s citation to Enfish does not compel a different outcome because Enfish addressed different facts. In Enfish, the claims were directed to a specific improvement in computer database functionality, namely a self-referential table that improved the operation of a computer memory system. Here, the claims are not directed to any improvement in computer or database functionality. Instead, the claims are directed to a process for auditing electronic funds transfers to gaming devices, which falls within the category of methods of organizing human activity and fundamental economic practices. The claims recite a series of steps for auditing a financial transaction: copying data from a first database to a second database, comparing the copied data with existing data, and generating an audit report based on that comparison. These steps describe a fundamental economic practice of reconciling financial records. The concept of auditing transactions to verify that recorded transfers match meter movements is a longstanding commercial practice. The claims do not purport to improve any computer or database technology. They simply take pre audit activities such as gathering transaction data and meter data, comparing them, and reporting discrepancies. The pre audit activities are applied to specific context of gaming device funds transfers. The abstract idea remains an abstract idea regardless of the particular industry to which it is applied. The claimed system does not change how a database stores, retrieves, or processes data. It does not modify the architecture of any computer or network. The steps of copying data from one database to another, comparing that copied data with data already present, and generating a report are generic data processing operations. Performing those operations on data from an electronic funds transfer that bypassed a gaming establishment account does not convert the abstract idea into a concrete technological improvement. The claims simply apply the abstract idea of auditing to a particular type of financial transaction. Applicant argues that the claimed invention provides a solution to the problem of bypassing regulated gaming establishment accounts while retaining audit functionality. However, the eligibility inquiry does not turn on whether a solution is new or useful. An abstract idea does not become patent eligible merely because it is applied to a new problem. The claims must recite an inventive concept that is more than the abstract idea itself. Here, the claimed steps of copying, comparing, and reporting are no more than instructions to apply the abstract idea of auditing to a specific setting. That is insufficient to satisfy Step Two. Claim Rejections - 35 USC § 101 07-04-01 AIA 07-04 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 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. Claim 13 is directed to the abstract idea of “auditing funds transfer” which is grouped under “organizing human activity… fundamental economic practice” [sales activities, business relations) in prong one of step 2A (See 2019 Revised Patent Subject Matter Eligibility Guidance). Claim 13 recites “method of operating a …, the method comprising: following a completion, which occurs independent of any component of any … that maintains any gaming establishment accounts, of an … funds transfer of an amount of funds from a financial institution account maintained by a financial institution to a …: causing, by a …, first data associated with the completion of the … funds transfer of the amount of funds from the financial institution account to the … to be copied from a … to a … that maintains second data associated with the completion of the … funds transfer of the amount of funds from the financial institution account to the gaming establishment device, comparing, by the …, the copied first data associated with the completion of the … funds transfer of the amount of funds from the financial institution account to the … and the second data associated with the completion of the … funds transfer of the amount of funds from the financial institution account to the …, and generating, by the …, an audit report based on the comparison of the copied first data associated with the completion of the … funds transfer of the amount of funds from the financial institution account to the … and the second data associated with the completion of the … funds transfer of the amount of funds from the financial institution account to the …”. These limitations describe an abstract idea of auditing funds transfer and corresponds to Certain Methods of Organizing Human Activity (fundamental economic practice including sales activities and business relations). Accordingly, claim 13 recites an abstract idea ( Step 2A: Prong 1: YES ). The claim also recites as additional elements such as “gaming establishment fund management system, electronic, gaming establishment device, processor, first database, and second database” which do no more than implement the abstract idea and/or provide a particular technological environment. Therefore, claim 13 recites an abstract idea without a practical application ( Step 2A - Prong 2: NO ). Further, as the additional elements of claim 13 do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field. Thus, claim 13 is not patent eligible (Step 2B: NO ). Claims 1 and 9 also recite the abstract idea of idea of auditing funds transfer and corresponds to Certain Methods of Organizing Human Activity (fundamental economic practice including sales activities and business relations) step one of step 2A (MPEP 2106.04). Claim 1 includes the additional elements of “a system comprising: a processor; and a memory device that stores plurality of instructions that, when executed by the processor, gaming establishment fund management system, electronic, gaming establishment device, processor, first database, and second database”. Claim 9 includes the additional elements of “a system comprising: a processor; and a memory device that stores plurality of instructions that, when executed by the processor, gaming establishment fund management system, electronic, electronic gaming machine, processor, first database, and second database”. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as they do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field. Claim 2 recites “wherein the first data comprises … funds transfer meter data and the … comprises an … funds transfer meter store” which further defines the abstract idea. The claim includes “gaming establishment device electronic and first database” as an additional elements. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as they no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field. Claim 3 recites “wherein the second data comprises … funds transfer transaction data and the … comprises an electronic funds transfer transaction store” which further defines the abstract idea. The claim includes “electronic and second data” as an additional elements. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as they no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field. Claim 4 recites “wherein the first data comprises electronic funds transfer transaction data and the first database comprises an electronic funds transfer transaction store” which further defines the abstract idea. The claim includes “gaming establishment device electronic and first database” as an additional elements. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as they no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field. Claim 5 recites “wherein the second data comprises … funds transfer meter data and the … comprises an …” which further defines the abstract idea. The claim includes “gaming establishment device electronic, second database, and electronic funds transfer meter store” as an additional elements. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as they no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field. Claim 6 recites “wherein the audit report comprises any discrepancies between the copied first data and the second data” which further defines the abstract idea. Claim 7 recites “wherein the audit report is generated in associated with an audit request from an …” which further defines the abstract idea. The claim includes “operator terminal” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field. Claim 8 recites “wherein the gaming establishment device comprises an electronic gaming machine” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field. Claim 10 recites “wherein the audit report comprises any discrepancies between the … funds transfer meter data and the … funds transfer transaction data” which further defines the abstract idea. The claim includes “electronic gaming machine electronic” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field. Claim 11 recites “wherein the audit report is generated in associated with an audit request from an …” which further defines the abstract idea. The claim includes “operator terminal” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field. Claim 12 recites “wherein the … stores a … that, when …, cause the … to enable a component of an … to access at least one of the … funds transfer meter data and the … funds transfer transaction data” which further defines the abstract idea. The claim includes “memory devices stores a plurality of instructions that, when executed by the processor, external audit system, electronic gaming machine electronic” as an additional elements. The additional element do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as they no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field. Claim 14 recites “wherein the first data comprises … funds transfer meter data and the … comprises an … funds transfer meter store” which further defines the abstract idea. The claim includes “gaming establishment device electronic and first database” as an additional elements. The additional element do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as they no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field. Claim 15 recites “wherein the second data comprises electronic funds transfer transaction data and the second database comprises an electronic funds transfer transaction store” which further defines the abstract idea. The claim includes “gaming establishment device electronic and first database” as an additional elements. The additional element do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as they no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field. Claim 16 recites “wherein the first data comprises … funds transfer transaction data and the … comprises an …” which further defines the abstract idea. The claim includes “electronic, first database, and electronic funds transfer transaction store” as an additional elements. The additional element do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as they no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field. Claim 17 recites “wherein the second data comprises …funds transfer meter data and the … comprises an …” which further defines the abstract idea. The claim includes “gaming establishment device electronic and second database comprises an electronic funds transfer meter store” as additional elements. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as they do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field. Claim 18 recites “wherein the audit report comprises any discrepancies between the copied first data and the second data” which further defines the abstract idea. Claim 19 recites “wherein the audit report is generated in associated with an audit request from an …” which further defines the abstract idea. The claim includes “operator terminal” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field. Claim 20 recites “wherein the gaming establishment device comprises an electronic gaming machine” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field. Conclusion 07-96 AIA The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. The closest patent prior art, US 2014/0248941, describes generating a transfer-verification message and an audit trail for a mobile payment to a gaming machine. However, it does not disclose: causing first data associated with the completion of an electronic funds transfer to be copied from a first database to a second database that maintains second data, comparing the copied first data and the second data, and generating an audit report based on that comparison. Dependent claims 2–8, 9–12, and 14–20 add additional, non-obvious limitations, such as specifying that the first data comprises gaming establishment device EFT meter data, the second data comprises EFT transaction data, and that the audit report includes any discrepancies. None of these limitations are taught or suggested by the prior art . THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to KEVIN T POE whose telephone number is (571)272-9789. The examiner can normally be reached on Monday-Friday 9:30am through 6pm EST . Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Calvin Hewitt can be reached on 571-272-6709 . The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see https://ppair-my.uspto.gov/pair/PrivatePair. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /K.T.P/Examiner, Art Unit 3692 /KEVIN T POE/ /RYAN D DONLON/Supervisory Patent Examiner, Art Unit 3692 May 28, 2026 Application/Control Number: 18/625,978 Page 2 Art Unit: 3692 Application/Control Number: 18/625,978 Page 3 Art Unit: 3692
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