DETAILED ACTION
This action is in reply to the amendment filed on 03/12/2026.
Claims 1,8 and 15 have been amended.
Claims 1-20 are pending.
Claims 1-20 have been examined.
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Response to Arguments
With regard to the 101 rejection, the arguments have been considered but they are not persuasive. The applicant asserted in page 10 that “[the] blockchain payment network described in the Specification and recited in the claims practically incorporates privacy into transactions conducted on the network”. However, the blockchain technology already provides such security via the use of both public and private keys. The claim only leverages such existing technology rather than meaningfully provides a technical improvement. The Limitations that are not indicative of integration into a practical application: Generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h).
Furthermore, the claims is not significantly more than any alleged judicial exception. Limitations that are not indicative of an inventive concept (aka “significantly more”): Generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h).
Therefore, the claim is not patent eligible.
With regard to the 103 rejection, the arguments have been considered but they are not persuasive. The applicant asserted that “Groarke does not cure the deficiencies of Collins, nor does the Office so allege . . .”. However, per reviewing the cited reference in light of the amended independent claims, Groarke teaches the amended limitations. It would have been obvious to one of ordinary skill in the art before the effective filing date to modify Collins by recording the transaction by new blocks on the blockchain as taught by Groarke, because using these elements helps to facilitate transactions on the blockchain (Groarke, par. [0005]) . Therefore, the claimed invention is obvious in view of the cited references.
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1-20 are directed to a method, a product, and a system which are one of the statutory categories of invention. (Step 1: YES).
Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional computer elements, which are recited at a high level of generality, provide conventional computer functions that do not add meaningful limits to practicing the abstract idea.
Claims 1, 8 and 15 are grouped together. Claim 1, for instance, recites, in part, a computer-implemented method for anonymous, persistent, and permissioned network-based payments, comprising: receiving a request from a device, wherein the request includes an amount of funds, a payor identifier, and a payee identifier, wherein the payor identifier and the payee identifier respectively mask an identity of a payor and an identity of a payee; obtaining permission for the request using the payor identifier; in response to obtaining the permission, performing a first transfer, wherein the amount of funds is transferred from an account associated with the payor identifier to an account associated with a centralized server system; in response to the first transfer, recording the amount of funds to a first node on a blockchain managed by the centralized server system, wherein the centralized server system has access to the entirety of the blockchain, and wherein the first node has access restricted to a first subset of the blockchain and is associated with the payor identifier; performing a second transfer, wherein the amount of funds is transferred from the account associated with the centralized server system to an account associated with the payee identifier; and in response to the second transfer, recording the amount of funds to a second node on the blockchain, wherein the second node has access restricted to a second subset of the blockchain and is associated with the payee identifier. The concept here is similar to the concept of performing funds transfers. Such concept is directed to business relations (commercial interactions). Hence, they fall within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas.
This judicial exception is not integrated into a practical application. In particular, the claim only recites additional elements such as a non-transitory computer readable device, at least one processor, a memory, a device, a centralized server system, a blockchain and other generic computer components to perform requesting, identifying, validating, transferring, and recording. The generic computer components are recited at a high-level of generality (requesting, identifying, transferring and recording) such that it amounts no more than mere instructions to apply the exception using a generic computer component. In addition, the ledgers and crypto are generally linking to the technology of cryptocurrency on a blockchain. Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Hence, the claim is directed to an abstract idea
Next the claim as a whole is analyzed to determine whether any element, or combination of elements, is sufficient to ensure the claim amounts to significantly more than an abstract idea. Claims 1, 21 and 26 do not include additional elements that are sufficient to amount to significantly more than the judicial exception because they are generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h). There is no improvement to computer technology or computer functionality MPEP 2106.05(a) nor a particular machine MPEP 2106.05(b) nor a particular transformation MPEP 2106.05(c). Additionally, the limitation of sending a request or message over network is recognized as well-understood, routine, conventional activity. Receiving or transmitting data over a network, e.g., using the Internet to gather data, Symantec, 838 F.3d at 1321, 120 USPQ2d at 1362 (utilizing an intermediary computer to forward information); TLI Communications LLC v. AV Auto. LLC, 823 F.3d 607, 610, 118 USPQ2d 1744, 1745 (Fed. Cir. 2016) (using a telephone for image transmission); OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1093 (Fed. Cir. 2015) see MPEP 2106.05(d). Given the above reasons, a generic processing device associated with the managing and conducting transactions between accounts is not an Inventive Concept. Thus, the claim is not patent eligible.
The dependent claims have been given the full two part analysis (Step 2A – 2-prong tests and step 2B) including analyzing the additional limitations both individually and in combination. The Dependent claim(s) when analyzed both individually and in combination are also held to be patent ineligible under 35 U.S.C. 101 because for the same reasoning as above and the additional recited limitation(s) fail(s) to establish that the claim(s) is/are not directed to an abstract idea. The additional limitations of the dependent claim(s) when considered individually and as ordered combination do not amount to significantly more than the abstract idea.
Claims 2, 9 and 16 are rejected under 35 U.S.C. 101 because the claimed invention is directed to judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. The claim(s) recite(s) recording transfer on a smart contract. This judicial exception is not integrated into a practical application because the limitations are Generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h). The claim(s) does/do not include additional elements (such as a smart contract, a processor, a non-transitory readable computer device) that are sufficient to amount to significantly more than the judicial exception because the limitations are generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h).
Claims 3, 10 and 17 are rejected under 35 U.S.C. 101 because the claimed invention is directed to judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. The claim(s) recite(s) obtaining permission request for transfer. This judicial exception is not integrated into a practical application because the limitations are Generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h). The claim(s) does/do not include additional elements (such as, a processor, a non-transitory readable computer device) that are sufficient to amount to significantly more than the judicial exception because the limitations are generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h).
Claims 4, 11 and 18 are rejected under 35 U.S.C. 101 because the claimed invention is directed to judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. The claim(s) recite(s) obtaining permission request for transfer. This judicial exception is not integrated into a practical application because the limitations are Generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h). The claim(s) does/do not include additional elements (such as, a processor, a non-transitory readable computer device, a node) that are sufficient to amount to significantly more than the judicial exception because the limitations are generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h).
Claims 5 and 12 are rejected under 35 U.S.C. 101 because the claimed invention is directed to judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. The claim(s) recite(s) a permission list. This judicial exception is not integrated into a practical application because the limitations are Generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h). The claim(s) does/do not include additional elements (such as, a processor, a non-transitory readable computer device, a node) that are sufficient to amount to significantly more than the judicial exception because the limitations are generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h).
Claims 6, 13 and 19 are rejected under 35 U.S.C. 101 because the claimed invention is directed to judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. The claim(s) recite(s) calculating a hash function. This judicial exception is not integrated into a practical application because the limitations are Generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h). The claim(s) does/do not include additional elements (such as, a processor, a non-transitory readable computer device, a node) that are sufficient to amount to significantly more than the judicial exception because the limitations are generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h).
Claims 7, 14 and 20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. The claim(s) recite(s) one-way cryptographic hash function. This judicial exception is not integrated into a practical application because the limitations are Generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h). The claim(s) does/do not include additional elements (such as, a processor, a non-transitory readable computer device, a node) that are sufficient to amount to significantly more than the judicial exception because the limitations are generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h).
Therefore, claims 1-20 are not drawn to eligible subject matter as they are directed to an abstract idea 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.
The factual inquiries set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
1. Determining the scope and contents of the prior art.
2. Ascertaining the differences between the prior art and the claims at issue.
3. Resolving the level of ordinary skill in the pertinent art.
4. Considering objective evidence present in the application indicating obviousness or nonobviousness.
Claims 1, 3-4, 8, 10-11, 15, 17-18 are rejected under 35 U.S.C. 103 as being unpatentable over Collins et al. (US 2023/0186300 A1) in view of Groarke et al. (US 2020/0027084 A1).
Claims 1, 8 and 15 are grouped together. Collins discloses: A computer-implemented method for anonymous, persistent, and permissioned network-based payments, comprising: receiving a request from a device, wherein the request includes an amount of funds (see at least par. [0022] “. . . receiving transaction account, the sender device 104 may electronically transmit a payment request to the processing server 102 using a suitable communication network and method, such as via a web page or application program executed by the sender device 104 that submits the payment request . . . the payment request may also include the transaction account numbers, at least one currency amount (e.g., used by the first payment network 108) . . .”), a payor identifier, and a payee identifier, wherein the payor identifier and the payee identifier respectively mask an identity of a payor and an identity of a payee (Collins et al. (US 2023/0186300 A1), see at least par. [0007] “. . . identifying, by a processor of the processing server, a first network profile associated with a first payment network based on the first payment network identifier and a second network profile associated with a second payment network based on the second payment network identifier . . .”) First payment network identifier corresponds to payor identifier and second network identifier corresponds to payee identifier;
obtaining permission for the request using the payor identifier (see at least par. [0018] “. . . The process for processing such a payment transaction may include at least one of authorization, batching, clearing, settlement, and funding. Authorization may include the furnishing of payment details by the consumer to a merchant, the submitting of transaction details (e.g., including the payment details) from the merchant to their acquirer, and the verification of payment details with the issuer of the consumer’s payment account used to fund the transaction . . .”) Authorizing corresponds to obtaining permission for the request;
in response to obtaining the permission, performing a first transfer, wherein the amount of funds is transferred from an account associated with the payor identifier to an account associated with a centralized server system (see at least par. [0024] “The processing server 102 can also identify a transaction account associated with the processing server 102 that is configured for use with the first payment network 108. In an exemplary embodiment, the processing server 102 can have access to a transaction account for every payment network that the processing server 102 is configured to facilitate transactions for, where each such transaction account may utilize the currency associated with the corresponding payment network and may be in compliance with the standards of the payment network as required . . .”) The processing server corresponds to a centralized server system which performs the first transfer request from the sender (or sender’s device);
performing a second transfer, wherein the amount of funds is transferred from the account associated with the centralized server system to an account associated with the payee identifier (Collins, see at least par. [0030] “. . . the processing server 102 can initiate a second payment transaction. The second payment transaction may be a transaction for payment of the currency amount, or a different amount based thereon, from a transaction account used by the processing server 102 using the second payment network 110 to the transaction account selected by the payee as a user of the recipient device 106 . . .”) The processing server performs a second transfer from the processing server, or centralized server, to the recipient device;
Collins does not disclose the following; however, Groarke teaches:
in response to the first transfer, recording the amount of funds to a first node on a blockchain managed by the centralized server system, wherein the centralized server system has access to the entirety of the blockchain (par. [0047]) the processing server corresponds to the centralized server and has access to the entirety of the blockchain, and wherein the first node has access restricted to a first subset of the blockchain and is associated with the payor identifier (Groarke, see at least par. [0015] “. . . Once a block is completed, the block is added to the blockchain and the transaction record thereby updated. In many instances, the blockchain may be a ledger of transactions in chronological order, or may be presented in any other order that may be suitable for use by the blockchain network. In some configurations, transactions recorded in the blockchain may include a destination address and a currency amount, such that the blockchain records how much currency is attributable to a specific address . . .” & par. [0048] “An account profile 212 may include, for example, the account number issued to the consumer 104 for hybrid payment authorization, the PAN for the fiat currency transaction account mapped thereto, the private key for the consumer's blockchain wallet (e.g., if applicable), communication data for communicating with the computing device 110, or any other data as discussed herein, such as an available balance of blockchain currency, a supplied digital signature from the computing device 110, etc.”) The consumer PAN corresponds to payor identifier and is restricted to the access of the blockchain via private key.
and in response to the second transfer, recording the amount of funds to a second node on the blockchain, wherein the second node has access restricted to a second subset of the blockchain and is associated with the payee identifier (Groarke, see at least par. [0028] “. . . For the processing of a blockchain transaction, such data may be provided to a node in the blockchain network 114, either by the sender (e.g., via the computing device 110) or the recipient (e.g., by the merchant system 106). The node may verify the digital signature and the sender's access to the funds, and then include the blockchain transaction in a new block. The new block may be validated by other nodes in the blockchain network 114 before being added to the blockchain and distributed to all of the nodes in the blockchain network 114 . . .” & see at least par. [0047] “. . . Each merchant profile 208 may be a structured data set configured to store data related to a merchant system 106. Each merchant profile 208 may include data related to the registration of the merchant for receipt of funding for payment transactions via blockchain currency. Such data may include a public key of the related merchant's blockchain wallet, criteria for the funding of a payment transaction via blockchain currency, etc . . .”) Interpretation: The payee corresponds to the merchant profile and is restricted based on public key.
It would have been obvious to one of ordinary skill in the art before the effective filing date to modify Collins by recording the transaction by new blocks on the blockchain as taught by Groarke, because using these elements helps to facilitate transactions on the blockchain (Groarke, par. [0005]) . Therefore, the claimed invention is obvious in view of the cited references.
Claims 3, 10 and 17 are grouped together. Collins in view of Groarke discloses: the computer-implemented method of claim 1. Collins further teaches: wherein obtaining permission for the request further comprises receiving approval from a payor device associated with the payor identifier (Collins, see at least [0018] “. . . Clearing may include the sending of batched transactions from the acquirer to a payment network for processing. Settlement may include the debiting of the issuer by the payment network for transactions involving beneficiaries of the issuer . . .”) Clearing corresponds to approving the transaction.
Claims 4, 11 and 18 are grouped together. Collins in view of Groarke discloses: the computer-implemented method of claim 1. Collins further teaches: wherein obtaining permission for the request further comprises comparing the request to the first node, wherein the first node includes an entry indicating preapproval of the request (Collins, see at least claim 9 “. . . a processor identifying a first network profile associated with the first payment network based on the first payment network identifier and a second network profile associated with the second payment network based on the second payment network identifier, and determining one or more incremental data values required for the second payment network based on a comparison of the first network profile with the second network profile, and a transmitter transmitting the one or more incremental data values to the first computing device.”)
Claims 2, 6-7, 9, 13-14, 16, 19-20 are rejected under 35 U.S.C. 103 as being unpatentable over Collins et al. (US 2023/0186300 A1) in view of Groarke et al. (US 2020/0027084 A1) in further view of Le Callonnec et al. (US 2023/0068301 A1).
Claims 2, 9, 16 are grouped together. Collins in view of Groarke discloses: the computer-implemented method of claim 1. However, Le Collonnec teaches: wherein recording the first transfer is performed by executing a smart contract configured to execute when the first transfer is complete (Le Callonnec, see at least par. [0033] “ In the system 100, the smart contract may receive a transaction notification from a sender system 104, which may initiate the validation of the proposed transaction, initiate the proposed transaction, generate the blockchain data value for the transfer, generate the hash of the blockchain data value, and publish the appropriate data to the public blockchain 108 and private blockchain 110 . . .”), and wherein recording the second transfer is performed by executing a smart contract configured to execute when the second transfer is complete (see at least par. [0033] “. . . In some cases, the smart contract may only perform a portion of the above steps, or each of the above steps may be performed by a combination of multiple smart contracts. The smart contract may be stored in the private blockchain 110 as a blockchain data value therein or may be stored in other memory or storage of the processing server 102 . . .”).
It would have been obvious to one of ordinary skill in the art before the effective filing date to modify Collins in view of Groarke by executing a smart contract on the transactions as taught by Le Collonnec, because using these elements helps to facilitate transactions on the blockchain using a smart contract. Therefore, the claimed invention is obvious in view of the cited references.
Claims 6, 13, 19 are grouped together. Collins in view of Groarke discloses: the computer-implemented method of claim 1. However, Le Collonnec teaches: further comprising verifying the first transfer and the second transfer, the verifying comprising: calculating a first hash value of the first node; calculating a second hash value of the second node; and determining that the first hash value equals the second hash value (Le Callonnec, see at least par. [0032] “The processing server 102 may also generate a hash value for the transfer. To generate the hash value, the processing server 102 may apply a cryptographic function to the blockchain data value for the transfer stored in the private blockchain 110. In an exemplary embodiment, the cryptographic function may be a one-way hashing function that generates hash values of sufficient complexity to be collision-resistant, such as the Secure Hash Algorithm 256 (SHA-256). The hash value may be included in a new blockchain data value that is generated by the processing server 102 and included in a new block that is generated and added to the public blockchain 108. In some embodiments, the processing server 102 may electronically transmit a notification message to at least the sender system 104 that includes the hash value or a notification that a hash value for the transfer was successfully added to the public blockchain 108. In some cases, the notification message and the approval message may be the same message. In some instances, the processing server 102 may also electronically transmit a notification message to the recipient system 106, such as may be identified using the recipient identifier included in the transfer notification. In other cases, the sender system 104 may communicate information regarding the successful transfer to the recipient system 106. Once the hash value has been published to the public blockchain 108, the sender system 104 and recipient system 106 may update their own internal blockchains accordingly . . .”) .
It would have been obvious to one of ordinary skill in the art before the effective filing date to modify Collins in view of Groarke by executing a smart contract on the transactions as taught by Le Collonnec, because using these elements helps to facilitate transactions on the blockchain using a smart contract. Therefore, the claimed invention is obvious in view of the cited references.
Claims 7, 14, 20 are grouped together. Collins in view of Groarke discloses: the computer-implemented method of claim 6. However, Le Collonnec teaches: wherein the first hash value and the second hash value are calculated using a one-way, cryptographic hash function (Le Callonnec, see at least par. [0032] “The processing server 102 may also generate a hash value for the transfer. To generate the hash value, the processing server 102 may apply a cryptographic function to the blockchain data value for the transfer stored in the private blockchain 110. In an exemplary embodiment, the cryptographic function may be a one-way hashing function that generates hash values of sufficient complexity to be collision-resistant . . .”).
It would have been obvious to one of ordinary skill in the art before the effective filing date to modify Collins in view of Groarke by executing a smart contract on the transactions as taught by Le Collonnec, because using these elements helps to facilitate transactions on the blockchain using a smart contract. Therefore, the claimed invention is obvious in view of the cited references.
Claims 5 and 12 are rejected under 35 U.S.C. 103 as being unpatentable over Collins et al. (US 2023/0186300 A1) in view of Groarke et al. (US 2020/0027084 A1) in further view of Vilmont, (US 2017/0200137 A1).
Claims 5 and 12 are grouped together. Collins in view of Groarke teaches: the computer-implemented method of claim 1. However, Vilmont teaches: wherein the first node includes a permission list, the permission list including the payor identifier and the payee identifier, wherein the permission list provides access to view and edit the first node (Vilmont, see at least par. [0095] “. . . the request received in step 801 may identify any of these types of transfers, along with the associated sender(s) and receiver(s), and the items/amounts to be transferred. Accordingly, the granter systems 716 in such embodiments need not be financial institutions or lender systems, but instead may correspond to user authentication systems, data access/permission systems, subscription monitor systems, network access providers, and/or any other servers that may be used to monitor, permit and deny access, and/or enable the requested transfers . . .”) the list of authorized payers and payees correspond to permission list.
It would have been obvious to one of ordinary skill in the art before the effective filing date to modify Collins in view of Groarke by having a permission list as taught by Vilmont because using these elements helps to expedite the transferring process between authorized users. Therefore, the claimed invention is obvious in view of the cited references.
Conclusion
THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
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/TOAN DUC BUI/Examiner, Art Unit 3693
/ELIZABETH H ROSEN/Primary Examiner, Art Unit 3693
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