DETAILED ACTION
Status of Claims
1. This office action is in response to RCE filed 3/2/2026.
2. Claims 1-20 are pending.
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 3/2/2026 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 1-9 are directed to a method; claims 10-18 are directed to a system, claims 19-20 are directed to a non-transitory computer readable medium – each of which is one of the statutory categories of inventions.
Step 2A: A claim is eligible at revised Step 2A unless it recites a judicial exception and the exception is not integrated into a practical application of the application.
Prong 1: Prong One of Step 2A evaluates whether the claim recites a judicial exception (an abstract idea enumerated in the 2019 PEG, a law of nature, or a natural phenomenon).
Groupings of Abstract Ideas:
I. MATHEMATICAL CONCEPTS
A. Mathematical Relationships
B. Mathematical Formulas or Equations
C. Mathematical Calculations
II. CERTAIN METHODS OF ORGANIZING HUMAN ACTIVITY
A. Fundamental Economic Practices or Principles (including hedging, insurance, mitigating risk)
B. Commercial or Legal Interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations)
C. Managing Personal Behavior or Relationships or Interactions between People (including social activities, teaching, and following rules or instructions)
III. MENTAL PROCESSES.
Concepts performed in the human mind (including an observation, evaluation, judgment, opinion).
See MPEP 2106.04 (a) (2) Abstract Idea Groupings [R-10.2019]
The limitations recited in the independent claim 1, 10 and 19 –
[activating a camera on the client device to generate a raw live stream of image data of a field of view of the camera], wherein the raw live stream includes a first portion corresponding to first imagery of a physical financial instrument while the camera is positioned over the first portion at a first time and includes a second portion corresponding to second imagery of the physical financial instrument while the camera is positioned over the second portion at a second time;
in response to a first frame refresh signal from an active-pixel sensor of the camera, [converting, by the client device in real time, the first portion of the raw live stream to a first byte array object;
in response to a second frame refresh signal from the active-pixel sensor, [converting, by the client device in real time, the second portion of the raw live stream to a second byte array object];
extracting, [by the client device], from the first byte array object and the second byte array object and by an [optical character recognition (OCR) program resident on the client device], a plurality of data fields of the financial document;
accumulating, at the client device, the plurality of data fields until a first subset of the OCR extracted data fields has been accumulated, wherein the first subset includes a first portion of data fields from the physical financial document usable in an Electronic Funds Transfer (EFT) transaction;
pausing the extracting of the plurality of data fields of the financial document when the first portion of data fields have been accumulated;
generating, at the client device, a schedule of recurring EFT transactions, based at least in part, on the first portion of data fields; and
generating, at the client device and based on the schedule of recurring EFT transactions, a series of pending EFT transactions.
– that constitute Fundamental Economic Practices or Principles and/or Commercial/Legal Interactions and hence fall under the abstract idea grouping of Certain Methods of Organizing Human Activity.
The dependent claims further limit the abstract idea to – schedule dates; communicating request for recurring EFT transactions to an originator of a payor’s document and receiving an indication of acceptance; financial data included in data fields; terminating the accumulating of OCR extracted data fields based on first occurrence of the EFT series; terminating recurring EFT schedule on not receiving indication of acceptance or not receiving acceptance withing a selectable time period; accumulating, based on not receiving acceptance, OCR extracted data fields until a second data fields has been accumulated; complete remote deposit from OCR extracted data fields from first and second subset – 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 client device; a system comprising a memory and at least one processor; a non-transitory computer-readable device; activating a camera on the client device to generate a live stream of image data of physical financial instrument; converting live stream to byte arrays; extracting fields from byte arrays using OCR; pausing the extracting.
MPEP 2106.05(f) Mere Instructions To Apply An Exception [R-10.2019]:
(1) Whether the claim recites only the idea of a solution or outcome i.e., the claim fails to recite details of how a solution to a problem is accomplished. The recitation of claim limitations that attempt to cover any solution to an identified problem with no restriction on how the result is accomplished and no description of the mechanism for accomplishing the result, does not integrate a judicial exception into a practical application or provide significantly more because this type of recitation is equivalent to the words “apply it”. See Electric Power Group, LLC v. Alstom, S.A., 830 F.3d 1350, 1356, 119 USPQ2d 1739, 1743-44 (Fed. Cir. 2016); Intellectual Ventures I v. Symantec, 838 F.3d 1307, 1327, 120 USPQ2d 1353, 1366 (Fed. Cir. 2016); Internet Patents Corp. v. Active Network, Inc., 790 F.3d 1343, 1348, 115 USPQ2d 1414, 1417 (Fed. Cir. 2015). In contrast, claiming a particular solution to a problem or a particular way to achieve a desired outcome may integrate the judicial exception into a practical application or provide significantly more. See Electric Power, 830 F.3d at 1356, 119 USPQ2d at 1743.
By way of example, in Intellectual Ventures I v. Capital One Fin. Corp., 850 F.3d 1332, 121 USPQ2d 1940 (Fed. Cir. 2017), the steps in the claims described “the creation of a dynamic document based upon ‘management record types’ and ‘primary record types.’” 850 F.3d at 1339-40; 121 USPQ2d at 1945-46. The claims were found to be directed to the abstract idea of "collecting, displaying, and manipulating data." 850 F.3d at 1340; 121 USPQ2d at 1946. In addition to the abstract idea, the claims also recited the additional element of modifying the underlying XML document in response to modifications made in the dynamic document. 850 F.3d at 1342; 121 USPQ2d at 1947-48. Although the claims purported to modify the underlying XML document in response to modifications made in the dynamic document, nothing in the claims indicated what specific steps were undertaken other than merely using the abstract idea in the context of XML documents. The court thus held the claims ineligible, because the additional limitations provided only a result-oriented solution and lacked details as to how the computer performed the modifications, which was equivalent to the words “apply it”. 850 F.3d at 1341-42; 121 USPQ2d at 1947-48 (citing Electric Power Group., 830 F.3d at 1356, 1356, USPQ2d at 1743-44 (cautioning against claims “so result focused, so functional, as to effectively cover any solution to an identified problem”)).
The limitation –
“activating a camera on the client device to generate a raw live stream of image data of a field of view of the camera, wherein the raw live stream includes a first portion corresponding to first imagery of a physical financial instrument while the camera is positioned over the first portion at a first time and includes a second portion corresponding to second imagery of the physical financial instrument while the camera is positioned over the second portion at a second time”
– is merely using a camera to automate the process of taking pictures of portions of a financial instrument and hence constitute insignificant data gathering activity.
Next, the following limitations –
in response to a first frame refresh signal from an active-pixel sensor of the camera, converting, by the client device in real time, the first portion of the raw live stream to a first byte array object
in response to a second frame refresh signal from the active-pixel sensor, converting, by the client device in real time, the second portion of the raw live stream to a second byte array object;
extracting, by the client device, from the first byte array object and the second byte array object and by an optical character recognition (OCR) program resident on the client device, a plurality of data fields of the financial document;
pausing the extracting of the plurality of data fields of the financial document when the first portion of data fields have been accumulated;
accumulating, at the client device, the plurality of data fields until a first subset of the OCR extracted data fields has been accumulated, wherein the first subset includes a first portion of data fields from the physical financial document usable in an Electronic Funds Transfer (EFT) transaction;
– constitute data conversion (convert from live stream to byte array) or data gathering (extracting by OCR, accumulating) activities.
Each of the above limitations merely instruct a client device (e.g., mobile computing device) to convert a first and second portion of live stream to a first byte array object and a second byte array object; to extract a plurality of data fields from the first byte array object and the second byte array object by OCR; to accumulate the plurality of data fields until a first subset of OCR extracted fields has been accumulated and then pausing.
The remaining limitations –
generating, at the client device, a schedule of recurring EFT transactions, based at least in part, on the first portion of data fields; and
generating, at the client device and based on the schedule of recurring EFT transactions, a series of pending EFT transactions
– merely instruct the client to device to generate a schedule of recurring transactions and pending transactions which amounts to implementing Mental Process and/or Certain Methods of Organizing Human Activity.
Examiner thus 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 data gathering activities (MPEP 2106.05(g)).
All purported inventive concepts reside in how the ‘activating,’ ‘converting,’ ‘extracting,’ ‘accumulating,’ and ‘generating’ are technically accomplished and not in how the processing technologically achieves the result which neither the specification or the drawings shed any light on.
See also Two-Way Media Ltd. v. Comcast Cable Commc’n, LLC, 874 F.3d 1329, 1337 (Fed. Cir. 2017) (“The claim [before the court] requires the functional results of ‘converting,’ ‘routing,’ ‘controlling,’ ‘monitoring,’ and ‘accumulating records,’ but does not sufficiently describe how to achieve these results in a non-abstract way.”); see Intellectual. Ventures I LLC v. Capital One Fin. Corp., 850 F.3d 1332, 1342 (Fed. Cir. 2017) (“Indeed, the claim language here provides only a result-oriented solution, with insufficient detail for how a computer accomplishes it. Our law demands more.”); see Affinity Labs of Texas, LLC v. Amazon.com Inc., 838 F.3d 1266, 1269 (Fed. Cir. 2016) (“At that level of generality, the claims do no more than describe a desired function or outcome, without providing any limiting detail that confines the claim to a particular solution to an identified problem. The purely functional nature of the claim confirms that it is directed to an abstract idea, not to a concrete embodiment of that idea.”); see Move, Inc. v. Real Estate Alliance Ltd., 721 F. App’x 950, 952-53, 954-56 (Fed. Cir. 2018) (non-precedential) (“Instead of focusing on the technical implementation details of the zooming functionality, for example, claim 1 recites nothing more than the result of the zoom.”).
The combination of additional elements – activating, converting, extracting, accumulating, pausing, generating – 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 – generating a schedule of recurring EFT transactions by extracting and accumulating a data fields captured via OCR from live stream of images of physical financial documents – that merely uses 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).
Therefore, 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 – generating a schedule of recurring EFT transactions by extracting and accumulating a data fields captured via OCR from live stream of images of physical financial documents – 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.
Prior Art
Relevant Prior Art not relied upon but made of record:
US20210027394 Crowdsourced annotation and tagging system for digital transactions and transaction prediction system
US20210366055 Systems and methods for generating accurate transaction data and manipulation
US20210279720 Anomaly detection in a recurring transaction set
US10572727 Image data extraction for transaction management
US20070086642 Method for remote check capture
NPL Java.io.InputStream Class in Java, GeeksforGeeks
Response to Arguments
Applicant's arguments filed 3/2/2026 have been fully considered but they are not persuasive.
101
Applicant argues that in contrast with OCR, the present claims are performed on a raw live stream where the user does not take a picture but instead simply activates the camera in live mode and moves the camera across various portions of the financial instrument. The generation of the byte array objects and OCR operations occur in real time as the user moves the camera over the financial instrument. Applicant also states that the claims further recite specific conditions for generating byte array objects which are based on refresh signals received from an active-pixel sensor of the camera.
Examiner finds this unpersuasive.
As set forth in Prong 2 above, the limitations of the independent claims together constitute – using a camera to automate the process of taking pictures of portions of a financial instrument which is an insignificant data gathering activity; merely instructing a client device (e.g., mobile computing device) to convert a first and second portion of live stream to a first byte array object and a second byte array object; to extract a plurality of data fields from the first byte array object and the second byte array object by OCR; to accumulate the plurality of data fields until a first subset of OCR extracted fields has been accumulated and then pausing – which is little more than data conversion and data gathering activities; and instructing the client to device to generate a schedule of recurring transactions and pending transactions which amounts to implementing Mental Process and/or Certain Methods of Organizing Human Activity. The applicant’s argument – that the user does not take the picture but that the OCR operations are performed on a raw live stream – does not change the analysis that this is mere data conversion and data gathering activity regardless of whether a user is recording live stream or the live stream is automatically recorded. Activating a camera to generate a raw live stream is not technical improvement. Converting, in response to frame refresh signal from camera sensor, from live stream to by array is data conversion. As noted previously, converting live stream to byte array is data processing that has been described at a high level of generality. The applicant does not contend to have invented converting real time image live stream to byte array. Instead, the claims merely use this feature as a tool to digitize data from a financial instrument.
Finally, in response to the applicant’s assertion that the claimed steps conserve network bandwidth, the examiner notes this is completely unpersuasive because a) OCR has already been invented and widely used and therefore the applicant cannot credibly rely on improvements made decades ago, b) there is no mention of conserving bandwidth in the specification. Neither the camera, nor the client device has been improved by the present invention. See Customedia Techs., LLC v. Dish Network Corp., 951 F.3d 1359, 1364 (Fed. Cir. 2020) (“To be a patent-eligible improvement to computer functionality, we have required the claims to be directed to an improvement in the functionality of the computer or network platform itself.”).
MPEP 2106.05(a) Improvements to the Functioning of a Computer or To Any Other Technology or Technical Field
II. IMPROVEMENTS TO ANY OTHER TECHNOLOGY OR TECHNICAL FIELD
Consideration of improvements is relevant to the integration analysis regardless of the technology of the claimed invention. Notably, the court did not distinguish between the types of technology when determining that the invention improved technology. However, it is important to keep in mind that an improvement in the judicial exception itself (e.g., a recited fundamental economic concept) is not an improvement in technology. For example, in Trading Technologies Int’l v. IBG LLC, the court determined that the claim simply provided a trader with more information to facilitate market trades, which improved the trader but did not improve computers or technology.
Similarly, in the present invention, using a camera to record a live stream of financial instrument, convert live stream to byte array, and then obtain data fields from byte array via OCR – may help a user or a financial institution to identify a schedule of recurring EFT transactions, but it does not improve computers or technology.
As in Trading Technologies, the series of steps recited in the claims does not improve the user interface. Indeed, nothing in the claims improves the functioning of a computer, makes it operate more efficiently, or solves any technological problem.
See Trading Techs. Int’l, Inc. v. IBG LLC, 921 F.3d 1084 (Fed. Cir. Apr. 18, 2019) (“This invention makes the trader faster and more efficient, not the computer. This is not a technical solution to a technical problem.”) (“The claims of the ‘999 patent do not improve the functioning of the computer, make it operate more efficiently, or solve any technological problem. Instead, they recite a purportedly new arrangement of generic information that assists traders in processing information more quickly”); See Trading Techs. Int’l, Inc. v. IBG LLC, 921 F.3d 1378, 1384 (Fed. Cir. Apr 30, 2019) (“The claims are focused on providing information to traders in a way that helps them process information more quickly, ’556 patent at 2:26–39, not on improving computers or technology.”). The mere fact that the claims utilize live stream recording and conversion from live stream to byte array – does not change the analysis that the claims are directed to determining information from financial instruments. The invention is directed to information gathering and process. It has nothing to do with improvement of computers or technology. The computing system is not the subject of the invention, nor the focus of claims, but rather a tool used in the service of displaying digital currency volatility information. But, a “purportedly new arrangement of generic information that assists [users] in processing information more quickly” does not confer patent-eligibility. Trading Techs. Int’l, 921 F.3d at 1093. For the above reasons, the applicant’s arguments are found unpersuasive.
Previously Addressed
Applicant argues citing para [0015], [0016], [018], [0030], [0033], [0034], [0060] of the specification, that the claimed steps improve the operation of the client device by providing a mechanism for extracting a limited subset of data fields without the user having to capture and transmit imagery to a backend computing system.
Applicant argues citing para [0090]. [0091] of the specification to argue that normal processing of OCR is paused thus reducing processing time or a requirement to send imagery to a backend system for additional processing allowing the client to reduce the number of operations thus saving processing power and computing resources.
Examiner finds the above arguments unpersuasive.
Use of optical character recognition (OCR) in check processing is decades old technology. Converting streaming data to byte array is mere data processing that can be accomplished using high level programming language libraries. For example, the method Java.io.InputStream.read (byte[] arg) reads number of bytes of arg.length from the input stream to the buffer array arg. See NPL GeeksforGeeks. Activating a camera to generate a live stream and pausing the extraction – are mere pre or post extra solution activities.
More importantly, Examiner notes that the limitations “activating a camera … to generate a live stream of image data of a field of view of the camera,” “converting … live stream to a plurality of byte arrays,” “extracting … from the plurality of byte arrays and by … (OCR) program … a plurality of data fields” – have been expressed purely in terms of results, devoid of implementation details. All purported inventive concepts reside in how the ‘generate,’ ‘converting,’ and ‘extracting’ are technically accomplished and not in how the processing technologically achieves the result which neither the specification or the drawings shed any light on.
See also Two-Way Media Ltd. v. Comcast Cable Commc’n, LLC, 874 F.3d 1329, 1337 (Fed. Cir. 2017) (“The claim [before the court] requires the functional results of ‘converting,’ ‘routing,’ ‘controlling,’ ‘monitoring,’ and ‘accumulating records,’ but does not sufficiently describe how to achieve these results in a non-abstract way.”); see Intellectual. Ventures I LLC v. Capital One Fin. Corp., 850 F.3d 1332, 1342 (Fed. Cir. 2017) (“Indeed, the claim language here provides only a result-oriented solution, with insufficient detail for how a computer accomplishes it. Our law demands more.”); see Affinity Labs of Texas, LLC v. Amazon.com Inc., 838 F.3d 1266, 1269 (Fed. Cir. 2016) (“At that level of generality, the claims do no more than describe a desired function or outcome, without providing any limiting detail that confines the claim to a particular solution to an identified problem. The purely functional nature of the claim confirms that it is directed to an abstract idea, not to a concrete embodiment of that idea.”); see Move, Inc. v. Real Estate Alliance Ltd., 721 F. App’x 950, 952-53, 954-56 (Fed. Cir. 2018) (non-precedential) (“Instead of focusing on the technical implementation details of the zooming functionality, for example, claim 1 recites nothing more than the result of the zoom.”).
Examiner argument that the claimed recitation improves the operation of the client device by providing a mechanism for extracting a limited subset of data fields without the user having to capture and transmit imagery to a backend computing system – is unpersuasive because, regardless of whether imagery is transmitted to a backend system, it is completely unclear how the claimed steps improve the operation of the client device. The limitation “without the user having to capture and transmit imagery to a backend system” has been recited in a result-oriented manner without any explanation of when the user has to capture and transmit imagery to a backend system and the ramifications thereof. Capturing and transmitting imagery to a backend system is, at best, insignificant extra solution activity that is not enough to integrate an abstract idea into a practical application.
With respect to applicant’s argument that the “normal processing of OCR is paused thus reducing processing time or a requirement to send imagery to a backend system for additional processing allowing the client to reduce the number of operations thus saving processing power and computing resources” in claims 1, 10 and 19, a) merely reflect an effect or result, b) is speculative and may never materialize, and c) does not provide a meaningful limitation because it argues for an intended or desired result as merely a byproduct of the application of the abstract idea. See MPEP 2106.05(f) (1) (cautioning against claims “so result focused, so functional, as to effectively cover any solution to an identified problem”), (3) (“describes “the effect or result dissociated from any method by which maintaining the state is accomplished” and does not provide a meaningful limitation because it merely states that the abstract idea should be applied to achieve a desired result”).
More importantly, any reduction of processing is attributed exclusively to the application of the abstract idea on generic computers and therefore not sufficient to demonstrate patent eligibility. Courts have consistently held that improved speed or efficiency inherent with applying an abstract idea on a computer are not sufficient to demonstrate an inventive concept. See OIP Techs v. Amazon.com (Fed. Cir. 2015) (“relying on a computer to perform routine tasks more quickly or more accurately is insufficient to render a claim patent eligible.”); Intellectual Ventures I LLC v. Capital One Bank (Fed. Cir. 2017), (“claiming the improved speed or efficiency inherent with applying the abstract idea on a computer does not provide a sufficient inventive concept.”); Intellectual Ventures I LLC v. Capital One Bank (USA) (Fed. Cir. 2015) (“[M]erely adding computer functionality to increase the speed or efficiency of the process does not confer patent eligibility on an otherwise abstract idea.”); Intellectual Ventures I LLC v. Erie Indemnity (Fed. Cir. 2017) (“Though the claims purport to accelerate the process of finding errant files and to reduce error, we have held that speed and accuracy increases stemming from the ordinary capabilities of a general-purpose computer do not materially alter the patent eligibility of the claimed subject matter.”).
As per MPEP 2106.05(a) (“To show that the involvement of a computer assists in improving the technology, the claims must recite the details regarding how a computer aids the method, the extent to which the computer aids the method, or the significance of a computer to the performance of the method. Merely adding generic computer components to perform the method is not sufficient. Thus, the claim must include more than mere instructions to perform the method on a generic component or machinery to qualify as an improvement to an existing technology.”). Here, the claims merely use client device and OCR as a tool to extract byte arrays of data fields of a financial instrument and determine a schedule of recurring EFT transactions. This is merely automating the human activity of reading financial instrument and determining EFT transactions from data fields inside the financial document. See Credit Acceptance Corp. v. Westlake Servs., 859 F.3d 1044, 1056 (Fed. Cir. 2017) (“But merely ‘configur[ing]’ generic computers in order to ‘supplant and enhance’ an otherwise abstract manual process is precisely the sort of invention that the Alice Court deemed ineligible for patenting.”) (“Our prior cases have made clear that mere automation of manual processes using generic computers does not constitute a patentable improvement in computer technology.”).
The combination of limitations 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 abstract idea into a practical application or provide significantly more. See MPEP 2106.05(f).
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.
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, Ryan Donlon can be reached at 571-270-3602. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000.
/ARUNAVA CHAKRAVARTI/Primary Examiner, Art Unit 3692
Prosecution Insights