DETAILED ACTION
The following FINAL Office action is in response to Amendment filed on June 17, 2026 for application 18652116
Acknowledgements
Claims 4, 11-12 and 14 have been canceled.
Claims 21-24 have been added.
Claims 1-3, 5-10, 13, 15 and 21-24 are pending.
Claims 1-3, 5-10, 13, 15 and 21-24 have been examined.
Notice of Pre-AIA or AIA Status
The present application, filed on or after December 13, 2013, is being examined under the first inventor to file provisions of the AIA .
Response to Arguments
In response to the Applicant’s arguments under 35 USC 101 referring back to the Applicant’s interview, Applicant argues that the proposed amended claims further define practical application towards improved data security in computer networks utilizing a specialized electronic rail device tied to financial services related network.
In response to the Applicant’s arguments under 35 USC 101 and after a thorough review of the amended claims, the amended claims are still directed to the concept of validating accounts. The amended claim recites “receiving a request to validate an account; initiate a microdeposit using an electronic rail, ,wherein initiating the microdeposit comprises transmitting, to the electronic rail a message that encodes a description associated with the microdeposit, wherein the description encoded in the message includes a sequence of characters that is set off from remaining characters in the description using at least one of a leading character or a trailing character, and wherein the remaining characters in the description comprises characters that describe the microdeposit; transmit to the user and based on receiving confirmation of the microdeposit, instructions that includes at least one of the leading character or the trailing character; receive based on transmitting the instructions and from the user an indication of a code associated with the microdeposit; and validate the account based on the code matching the sequence of characters” which still falls within the “certain methods of organizing human activity” grouping of abstract ideas classified under “fundamental economic principles or practices”, specifically “mitigating risk” as part of a transaction because the claims are reciting steps for verifying accounts based on the code (received from the user) and the sequence of characters (associated with the microdeposit) by matching the code with the sequence of characters. The judicial exception is not integrated into a practical application because the additional elements of the claims such as a system comprising one or more memories and one or more processors, a user device, an electronic rail device and a specialized user interface (UI) that includes a specialized input component merely involves using a computer as a tool to perform an abstract idea. Essentially, the use of “a system comprising one or more memories and one or more processors, user device, electronic rail device and a specialized user interface (UI)” to implement the abstract idea does not render the claim patent eligible because it requires no more than a computer performing or implementing functions that correspond to acts required to carry out the abstract idea. The details regarding how the message is encoded to initiate a microdeposit might improve security of the details of the user but it’s not enough to reflect an improvement to the system comprising one or more memories and one or more processors, user device, electronic rail device and a specialized user interface (UI).
Applicant’s arguments are moot under new grounds of rejection.
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 1-3, 5-10, 13, 15 and 21-24 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
In the instant case, claims 1-8 are directed to a system and claims 9-15 are directed to a method. Therefore, these claims fall within the four statutory categories of invention.
The claims recite validating accounts which is an abstract idea. Specifically, the claim recites “receiving a request to validate an account; initiate a microdeposit using an electronic rail, ,wherein initiating the microdeposit comprises transmitting, to the electronic rail a message that encodes a description associated with the microdeposit, wherein the description encoded in the message includes a sequence of characters that is set off from remaining characters in the description using at least one of a leading character or a trailing character, and wherein the remaining characters in the description comprises characters that describe the microdeposit; transmit to the user and based on receiving confirmation of the microdeposit, instructions that includes at least one of the leading character or the trailing character; receive based on transmitting the instructions and from the user an indication of a code associated with the microdeposit; and validate the account based on the code matching the sequence of characters.” which is grouped within the “certain methods of organizing human activity” grouping of abstract ideas in prong one of step 2A of the Alice/Mayo test, classified under “fundamental economic principles or practices”, specifically “mitigating risk” as part of a transaction (See MPEP 2106, specifically 2106.04(a)) because – for example, in this case, the claims involve a series of steps for verifying accounts based on the code (received from the user device) and the sequence of characters (associated with the microdeposit) by matching the code with the sequence of characters. Accordingly, the claim recites an abstract idea (See MPEP 2106, specifically 2106.04(a)).
This judicial exception is not integrated into a practical application because, when analyzed under prong two of step 2A of the Alice/Mayo test (See MPEP 2106.04(d)), the additional elements of the claims such as a system comprising one or more memories and one or more processors, user device, electronic rail device and a specialized user interface (UI) that includes a specialized input component merely involves using a computer as a tool to perform an abstract idea and/or generally links the use of a judicial exception to a particular technological environment. The use of “a system comprising one or more memories and one or more processors, user device, electronic rail device and a specialized user interface (UI)” to implement the abstract idea and/or generally linking the use of the abstract idea to a particular technological environment] does not render the claim patent eligible because it requires no more than a computer performing functions that correspond to acts required to carry out the abstract idea. Specifically, the “receiving a request to validate an account; initiate a microdeposit using an electronic rail, ,wherein initiating the microdeposit comprises transmitting, to the electronic rail a message that encodes a description associated with the microdeposit, wherein the description encoded in the message includes a sequence of characters that is set off from remaining characters in the description using at least one of a leading character or a trailing character, and wherein the remaining characters in the description comprises characters that describe the microdeposit; transmit to the user and based on receiving confirmation of the microdeposit, instructions that includes at least one of the leading character or the trailing character; receive based on transmitting the instructions and from the user an indication of a code associated with the microdeposit; and validate the account based on the code matching the sequence of characters”. The additional claim elements are not indicative of integration into a practical application, because the claims do not involve improvements to the functioning of a computer, or to any other technology or technical field (MPEP 2106.05(a)), the claims do not apply the abstract idea with, or by use of, a particular machine (MPEP 2106.05(b)), the claims do not effect a transformation or reduction of a particular article to a different state or thing (MPEP 2106.05(c)), and the claims do not apply or use the abstract idea in some other meaningful way beyond generally linking the use of the abstract idea to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception (MPEP 2106.05(e) and Vanda Memo). Therefore, the claims do not, for example, purport to improve the functioning of a computer. Nor do they effect an improvement in any other technology or technical field. Accordingly, the additional elements do not impose any meaningful limits on practicing the abstract idea, and the claims are directed to an abstract idea.
The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when analyzed under step 2B of the Alice/Mayo test (See MPEP 2106, specifically 2106.05), the additional elements of “system comprising one or more memories and one or more processors, user device, electronic rail device and a specialized user interface (UI)” to automate and/or implement the abstract idea of validating accounts. As discussed above, taking the claim elements separately “system comprising one or more memories and one or more processors, user device, electronic rail device and a specialized user interface (UI)” perform the steps of Claim 1. These functions correspond to the actions required to perform the abstract idea. Viewed as a whole, the combination of elements recited in the claims merely recite the concept of validating accounts. Therefore, the use of these additional elements does no more than employ the computer as a tool to automate and/or implement the abstract idea. The use of “system comprising one or more memories and one or more processors, user device, electronic rail device and a specialized user interface (UI)” to merely automate and/or implement the abstract idea cannot provide significantly more than the abstract idea itself (MPEP 2106.05(I)(A)(f) & (h)). Therefore, the claim is not patent eligible.
Dependent claims further describe details of the human-readable description comprising a sequence of characters and 3-letter code being used to validate the account on an electronic rail. The dependent claims do not include additional elements that integrate the abstract idea into a practical application or that provide significantly more than the abstract idea. Therefore, the dependent claims are also not patent eligible.
Claim Rejections - 35 USC § 103
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
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 of this title, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
Claims 1-4, 6-12 and 14 are rejected under 35 35 U.S.C. 103 as being unpatentable over Bajan (US 10,282,714 B2) in view of Kolchin (US 11,321,709 B1)
Regarding Claims 1 and 9, Bajan discloses a system for account verification with microdeposits, the system comprising: one or more memories; and one or more processors, communicatively coupled to the one or more memories, configured to (Col. 6 lines 14-18):
receive, from a user device, a request to validate an account (Col. 2 lines 30-53, Col. 2 lines 61-66)
initiate a microdeposit using an electronic rail device (Col. 3 lines 1-12)
wherein initiating the microdeposit comprises transmitting, to the electronic rail device, a message that encodes a description associated with the microdeposit (Col. 3 lines 8-12 “My-eBanc then makes a nominal deposit, say $0.15, to the customer's account corresponding to the RTN using the Payment Distribution System of the ACH, and using the RCC as the reference number” and “the RCC will appear in the Transaction description column next to the credit column showing the $0.15 deposit is interpreted as the generated RCC is embedded into the column as part of the microdeposit”)
wherein the description [encoded in the message] that includes a sequence of characters that is set off from remaining characters in the description using at least one of a leading character or a trailing character (Col. 3 lines 1-12)
wherein the remaining characters in the description comprises characters that describe the microdeposit; and (Col. 3 lines 1-12)
receive, based on transmitting the instructions for the specialized UI and from the user device, an indication of a code associated with the microdeposit; and (Col. 3 lines 13-27, Col. 5 lines 29-41)
validate the account based on the code matching the sequence of characters (Col. 3 lines 28-30, Col. 5 lines 42-49)
Bajan does not specifically disclosed wherein the description [encoded in the message]; and transmit, to the user device and based on receiving confirmation of the microdeposit, instructions for a specialized user interface (UI) that includes at least one of the leading character or the trailing character, wherein the specialized UI includes a specialized input component for entering the sequence of characters that is set off from the remaining characters
Kolchin however discloses:
wherein the description [encoded in the message] (Col. 16 lines 6-18)
transmit, to the user device and based on receiving confirmation of the microdeposit, instructions for a specialized user interface (UI) that includes at least one of the leading character or the trailing character, wherein the specialized UI includes a specialized input component for entering the sequence of characters that is set off from the remaining characters (Col. 16 lines 6-27)
Therefore, it would have been obvious to one of ordinary skill in the art at the time of invention to modify the method of Bajan to include wherein the description [encoded in the message], as disclosed in Kolchin, in order to provide a system that conduct secure electronic financial transactions between a consumer and a merchant (see Kolchin abstract).
Regarding Claim 2, Bajan discloses wherein the sequence of characters includes a human-readable description (Col. 3 lines 13-21)
Regarding Claim 3, Bajan discloses wherein the sequence of characters comprises a three-letter code (Col. 3 lines 1-13)
Regarding Claim 6, Bajan discloses wherein the request to validate the account includes an identifier associated with the account (claims 9 and 10)
Regarding Claim 7, Bajan discloses wherein the request to validate the account indicates an institution associated with the account (Col. 2 lines 30-39)
Regarding Claim 8, Bajan discloses wherein the electronic rail is associated with immediate delivery (Col. 3 lines 1-12)
Regarding Claim 10, Bajan discloses transmitting, to the user device, instructions for at least one user interface (UI), wherein the request to the validate the account is received using the at least one UI (Col. 4 line 1-2)
Regarding Claim 21, Bajan discloses wherein the specialized UI includes information for discerning the sequence of characters from the remaining characters (Col. 2 lines 30-39)
Regarding Claim 22, Bajan discloses wherein the specialized UI displays the description associated with the microdeposit (Col. 2 lines 30-39)
Regarding Claim 23, Bajan discloses wherein the one or more processors are configured to: apply a machine learning model to determine a validation procedure comprising at least one of: automatic validation, validation using credentials, validation using an immediate deposit, or validation using a slower deposit (Col. 2 lines 30-39)
Regarding Claim 24, Bajan discloses wherein the specialized UI includes UI components based on an output of the machine learning model (Col. 2 lines 30-39)
Claims 5 and 13 are rejected under 35 U.S.C. 103 as being unpatentable over Bajan in view of Kolchin and in further view of Furtuna et al. (US 2021/0358249 A1).
Regarding Claims 5 and 13, the combination of Bajan and Kolchin does not disclose wherein the leading character comprises a pound symbol.
Furtuna however disclose: wherein the leading character comprises a pound symbol (¶0027).
Therefore, it would have been obvious to one of ordinary skill in the art at the time of invention to modify the method of Bajan to include wherein the leading character comprises a pound symbol, as disclosed in Furtuna, in order to provide a system that compares the data sequence input to one or more sequence templates to determine a matching sequence template (see Furtuna abstract).
Claim 15 is rejected under 35 U.S.C. 103 as being unpatentable over Bajan in view of Kolchin and in further view of GURZ et al. (US 2015/0213418 A1).
Regarding Claim 15, the combination of Bajan and Kolchin does not disclose wherein the at least one trailing character includes a space.
GURZ however discloses wherein the at least one trailing character includes a space (¶0025).
Therefore, it would have been obvious to one of ordinary skill in the art at the time of invention to modify the method of Bajan to include wherein the at least one trailing character includes a space, as disclosed in GURZ, in order to provide a system for verifying ACH data for a proposed ACH transaction (see GURZ abstract).
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.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ZEHRA RAZA whose telephone number is (571)272-8128. The examiner can normally be reached 10AM-6:30PM.
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, John W Hayes can be reached at (571) 272-6708. 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.
/ZEHRA RAZA/Examiner, Art Unit 3697
/JOHN W HAYES/Supervisory Patent Examiner, Art Unit 3697
Prosecution Insights