DETAILED ACTION
1. 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 filed on November 20, 2025. Amendments to claims 1, 6, 8, 13, 15, and 20 and cancellation of claims 7 and 14 have been entered. Claims 1-6, 8-13, and 15-20 are pending and have been examined. The statement of reasons for the indication of allowable subject matter over prior art was already discussed in the Office action mailed on August 20, 2025 and hence not repeated here. The rejections and response to arguments are discussed below.
Claim Rejections - 35 USC § 101
2. 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.
3. Claims 1-20 are rejected under 35 U.S.C. § 101 because the claimed invention is directed to an abstract idea without significantly more.
The claim(s) recite(s) a method of transmitting the pricing details data to the bot for receiving user input to conduct a transaction with respect to the derivative instrument, which is considered a judicial exception because it falls under the category of “Certain Methods of organizing human activity” such as fundamental economic practice as well as commercial or legal interactions including agreements as discussed below. This judicial exception is not integrated into a practical application as discussed below. The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception as discussed below.
Analysis
Step 1: In the instant case, exemplary claim 1 is directed to a method (process).
Step 2A – Prong One: The limitations of “A method for data processing by utilizing one or more processors along with allocated memory, the method comprising:
i) implementing an artificial intelligence (AI) powered bot system, wherein the bot system includes a user interface;
ii) establishing a communication link among the bot system, an AI and Machine Learning Natural Language Processing (AIML NLP) service, a parsing module including a post processing component and a response generation component, an automated pricing module, and an order management system;
iii) receiving, by the parsing module, via the user interface, user input from a user as text data wherein the text data indicates a Request for Quote (RFQ) for a derivative instrument, the RFQ comprising colloquial or shorthand trading terminology;
iv) transmitting the text data to the AIML NLP service from the parsing module;
v) extracting, by the parsing module, parameters associated with the RFQ utilizing machine learning entity extraction model that has been trained on derivatives-specific colloquial corpora and configured to identify ambiguous or shorthand trade attributes within
the RFQ;
vi) normalizing the extracted parameters by mapping the ambiguous or colloquial terminology into a structured, standardized tradeable format comprising trade leg information, wherein the normalization includes converting synonymous or shorthand expressions of dates, maturities, observation frequencies, strike prices, product identifiers, and other RFQ terms into canonical values and transmitting the normalized parameters to the automated pricing module;
vii) receiving pricing details data by the response generation component from the automated pricing module;
viii) implementing, by the post processing component, a feedback loop that stores an original RFQ text, predicted entities, normalized tradeable format, and user corrections, and retrains the entity extraction model using the stored information to improve accuracy and reduce parsing latency in subsequent RFQs; and
ix) transmitting the pricing details data to the bot for receiving user input via the user interface to conduct a transaction with respect to the derivative instrument”
as drafted, when considered collectively as an ordered combination without the italicized portions, is a process that, under the broadest reasonable interpretation, covers the category of “Certain Methods of organizing human activity” such as fundamental economic practice as well as commercial or legal interactions including agreements.
“Transmitting the pricing details data to the bot for receiving user input via the user interface to conduct a transaction with respect to the derivative instrument” is a fundamental economic practice such as trading. The steps of “Receiving pricing details data by the response generation component from the automated pricing module; ….. and transmitting the pricing details data to the bot for receiving user input via the user interface to conduct a transaction with respect to the derivative instrument” is also a form of fulfilling agreements to the user. Hence, the steps of the claim, considered collectively as an ordered combination without the italicized portions, covers the abstract category of “Certain Methods of organizing human activity”.
That is, other than, one or more processors along with allocated memory, an artificial intelligence (AI) powered bot system including a user interface, an AI and Machine Learning Natural Language Processing (AIML NLP) service (including an entity extraction model), a parsing module including a post processing component and a response generation component, an automated pricing module, and an order management system, nothing in the claim precludes the steps from being performed as a method of organizing human activity. If the claim limitations, under the broadest reasonable interpretation, covers methods of organizing human activity but for the recitation of generic computer components, then it falls within the “Certain methods of organizing human activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
Step 2A – Prong Two: The judicial exception is not integrated into a practical application. In particular, the claim only recites the additional elements of one or more processors along with allocated memory, an artificial intelligence (AI) powered bot system including a user interface, an AI and Machine Learning Natural Language Processing (AIML NLP) service (including an entity extraction model), a parsing module including a post processing component and a response generation component, an automated pricing module, and an order management system to perform all the steps. A plain reading of Figures 1-5 and associated descriptions in at least paragraphs [0041] – [0061] reveals that the one or more processors along with allocated memory comprises general-purpose processors suitably programmed to execute the claimed steps. The artificial intelligence (AI) powered bot system including a user interface, an AI and Machine Learning Natural Language Processing (AIML NLP) service (including an entity extraction model) and the order management system are broadly interpreted to comprise generic computer components suitably programmed to perform their respective functions. The parsing module including a post processing component and a response generation component, and the automated pricing module are broadly interpreted to comprise generic software components suitably programmed to perform their respective functions. Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. The additional elements in all the steps are recited at a high-level of generality (i.e., as generic computer components performing generic computer functions) such that it amounts no more than mere instructions to apply the exception using generic computer components. 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, claim 1 is directed to an abstract idea.
Step 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, using the additional elements (identified above) to perform the claimed steps amounts to no more than mere instructions to apply the exception using a generic computer component. The additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Hence, independent claim 1 is not patent eligible. Independent claims 8 and 15 are also not patent eligible based on similar reasoning and rationale.
Dependent claims 2-6, 9-13 and 16-20, when analyzed as a whole are held to be patent ineligible under 35 U.S.C. 101 because the additional recited limitations only refine the abstract idea further.
For instance, in claims 2, 9 and 16, the steps “further comprising:
recording the transaction and transmitting the recorded transaction to the order management system for execution; and
executing the transaction with respect to the derivative instrument” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the intermediate steps of the underlying process.
In claims 3, 10 and 17, the steps “wherein the post processing component implements Natural Language Understanding (NLU) processes for colloquial terminology expressed within derivatives RFQ structures” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the intermediate steps of the underlying process. The additional elements of Natural Language Understanding (NLU) processes are broadly interpreted to correspond to generic software suitably programmed to perform the associated functions. The additional element of the Natural Language Understanding (NLU) processes, perform their traditional functions recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using generic computer components.
In claims 4, 11 and 18, the steps “further comprising:
generating a human readable response by the response generation module from the pricing details data returned by automated pricing module by implementing a Natural Language Generation (NLG) algorithm; and
transmitting the human readable response to the user interface” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the intermediate steps of the underlying process. The additional elements of Natural Language Generation (NLG) algorithm are broadly interpreted to correspond to generic software suitably programmed to perform the associated functions. The additional element of the Natural Language Generation (NLG) algorithm, perform their traditional functions recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using generic computer components.
In claims 5, 12 and 19, the steps “wherein the entity extraction model is a machine learning model that is trained to extract entities that represent bits of information about nature of the RFQ from the user” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the intermediate steps of the underlying process.
In claims 6, 13 and 20, the steps “further comprising:
storing the pricing details data associated with the RFQ onto a database;
receiving user input to reprice the RFQ; and
repeating the steps iv) through ix) to generate a repricing of the RFQ” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the intermediate steps of the underlying process. The additional element of the database broadly interpreted to correspond to generic database suitably programmed to perform store the associated data. The additional element of the database, performs its traditional functions recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using generic computer components.
In all the dependent claims, the judicial exception is not integrated into a practical application because the limitations are recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using generic computer components. Also, the claims do not affect an improvement to another technology or technical field; the claims do not amount to an improvement to the functioning of a computer system itself; the claims do not affect a transformation or reduction of a particular article to a different state or thing; and the claims do not move beyond a general link of the use of an abstract idea to a particular technological environment. In addition, the dependent claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. The additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. The claims as a whole, do not amount to significantly more than the abstract idea itself. For these reasons, the dependent claims also are not patent eligible.
Response to Arguments
4. In response to Applicants arguments on pages 11-16 of the Applicant’s remarks that the claims are patent-eligible under 35 USC 101 when considered under MPEP 2106, the Examiner respectfully disagrees.
The fact that the claims are Patent-Ineligible when considered under the MPEP 2106 has already been addressed in the rejection and hence not all the details of the rejection are repeated here.
Response to Applicants’ arguments regarding Step 2A – Prong one:
The claim(s) recite(s) a method of transmitting the pricing details data to the bot for receiving user input to conduct a transaction with respect to the derivative instrument, which is considered a judicial exception because it falls under the category of “Certain Methods of organizing human activity” such as fundamental economic practice as well as commercial or legal interactions including agreements as discussed in the rejection.
“Transmitting the pricing details data to the bot for receiving user input via the user interface to conduct a transaction with respect to the derivative instrument” is a fundamental economic practice such as trading. The steps of “Receiving pricing details data by the response generation component from the automated pricing module; ….. and transmitting the pricing details data to the bot for receiving user input via the user interface to conduct a transaction with respect to the derivative instrument” is also a form of fulfilling agreements to the user. Hence, the steps of the claim, considered collectively as an ordered combination covers the abstract category of “Certain Methods of organizing human activity”. The additional elements in the claims are used as tools in their ordinary capacity to apply the abstract idea. The claims recite an abstract idea.
Response to Applicants’ arguments regarding Step 2A – Prong two:
According to MPEP 2106, 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 or using a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition
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).
In the instant case, the judicial exception is not integrated into a practical application, because none of the above criteria is met. The claims only recite the additional elements of one or more processors along with allocated memory, an artificial intelligence (AI) powered bot system including a user interface, an AI and Machine Learning Natural Language Processing (AIML NLP) service (including an entity extraction model), a parsing module including a post processing component and a response generation component, an automated pricing module, and an order management system to perform all the steps of the underlying process. A plain reading of Figures 1-5 and associated descriptions in at least paragraphs [0041] – [0061] reveals that the one or more processors along with allocated memory comprises general-purpose processors suitably programmed to execute the claimed steps. The artificial intelligence (AI) powered bot system including a user interface, an AI and Machine Learning Natural Language Processing (AIML NLP) service (including an entity extraction model) and the order management system are broadly interpreted to comprise generic computer components suitably programmed to perform their respective functions. The parsing module including a post processing component and a response generation component, and the automated pricing module are broadly interpreted to comprise generic software components suitably programmed to perform their respective functions. Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. The additional elements in all the steps are recited at a high-level of generality (i.e., as generic computer components performing generic computer functions) such that it amounts no more than mere instructions to apply the exception using generic computer components. 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 claims are directed to an abstract idea.
The claimed features including those discussed on pages 12-13 of the remarks such as “A machine learning entity extraction model trained on domain-specific corpora of derivatives-specific colloquial RFQ terminology;
Normalization of ambiguous or shorthand colloquial expressions into structured canonical tradeable formats;
Feedback loop with retraining of the NLP model based on user corrections, thereby continuously improving model accuracy and reducing latency” may at best be characterized as an improvement in the abstract idea of a method of transmitting the pricing details data to the bot for receiving user input to conduct a transaction with respect to the derivative instrument, using the additional as tools in their ordinary capacity to apply the abstract idea. The alleged advantages such as “processing non-standardized, colloquial trader language ….. improving machine performance in processing financial colloquial text” are due to improvements in the abstract idea.
The examiner does not see the parallel between the Applicant’s claims and those in McRO v. Bandai (837 F.3d 1299, Fed. Cir. 2016). There is no similarity between the concept of automating part of existing 3D animations of a character’s facial expressions and synchronize those expressions to the actual speech and the concept of a method of transmitting the pricing details data to the bot for receiving user input to conduct a transaction with respect to the derivative instrument. Also, in McRO the patents relate to “automating part of existing 3D animations of a character’s facial expressions and synchronize those expressions to the actual speech”, which were to be done manually before the issuance of the patent. The claims were directed to a patentable technological improvement over the existing, manual 3D animation techniques by using “limited complex set of rules specifically designed to achieve an improved technological result” thus providing "unconventional" practices than used in a conventional industry practice. Hence the claims in McRo were patent eligible because they recited significantly more than an abstract idea. Such features are not present in the Applicant’s claims. Functions such as “implementing an artificial intelligence (AI) powered bot system, establishing a communication link, receiving, transmitting, extracting and normalizing parameters, receiving, storing, and transmitting” are conventional functions of a computer system. In McRo the application of the limited complex set of rules resulted in an improvement of the 3D animation technology. On the other hand the application of the specific set of rules, in the Applicant’s invention, may at best be considered an improvement in the business solution, using computer components, to the problem of transmitting the pricing details data to the bot for receiving user input to conduct a transaction with respect to the derivative instrument. An improvement in abstract idea is still abstract (SAP America v. Investpic *2-3 (“We may assume that the techniques claimed are “groundbreaking, innovative, or even brilliant,” but that is not enough for eligibility. Association for Molecular Pathology v. Myriad Genetics, Inc., 569 U.S. 576, 591 (2013); accord buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1352 (Fed. Cir. 2014). Nor is it enough for subject-matter eligibility that claimed techniques be novel and nonobvious in light of prior art, passing muster under 35 U.S.C. §§ 102 and 103. See Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66, 89–90 (2012); Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 1151 (Fed. Cir. 2016) (“A claim for a new abstract idea is still an abstract idea). The additional elements (identified in the claim) are generic computer components used to apply the abstract idea. It does not involve any improvements to another technology, technical field, or improvements to the functioning of the computer itself. The examiner does not see the parallel between the Applicant’s claims and those in Enfish v. Microsoft (822 F.3d 1327, Fed. Cir. 2016). Therefore, the Applicants’ arguments are not persuasive.
The alleged advantages listed on page 14 of the remarks such as “normalizing multiple synonymous or ambiguous colloquial inputs into canonical forms, enabling downstream automated pricing engines to operate with accuracy and efficiency ….. the feedback loop with user correction and model retraining ensures that the NLP pipeline continuously adapts to evolving trader idioms ….. improved operation of AI/NLP systems themselves” are due to improvements in the abstract idea, using the additional as tools in their ordinary capacity to apply the abstract idea. An improvement in abstract idea is still abstract (SAP America v. Investpic *2-3 (“We may assume that the techniques claimed are “groundbreaking, innovative, or even brilliant,” but that is not enough for eligibility). It does not involve any improvements to another technology, technical field, or improvements to the functioning of the computer itself. Therefore, the Applicants’ arguments are not persuasive.
Response to Applicants’ arguments regarding Step 2B:
As discussed in the rejection, the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, using the additional elements (identified in the rejection) to perform the claimed steps, amount to no more than mere instructions to apply the exception using a generic computer component. The additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Hence, the claims are not patent eligible.
The alleged advantages listed on pages 14-15 of the remarks such as “accurately parsing and normalizing trader shorthand ….. Normalization into structured tradeable format supplies a technical transformation of unstructured, inconsistent input text into machine-usable parameters ….. feedback loop retraining creates a self-improving parsing system that reduces error rate and execution latency benefits in the field of machine learning/NLP, not just in finance” are due to improvements in the abstract idea, using the additional as tools in their ordinary capacity to apply the abstract idea. An improvement in abstract idea is still abstract (SAP America v. Investpic *2-3 (“We may assume that the techniques claimed are “groundbreaking, innovative, or even brilliant,” but that is not enough for eligibility).
The examiner does not see the parallel between the Applicant’s claims and those in DDR Holdings v. Hotels.com (773 F.3d 1245). Therefore, the Applicants’ arguments are not persuasive.
For these reasons and those discussed in the rejection, the rejections under 35 USC § 101 are maintained.
Applicant’s other arguments with respect to pending claims have been considered but are not persuasive.
Conclusion
5. The prior art made of record and not relied upon is considered pertinent to applicant's disclosure:
(a) Burrell; C. Austin et al. (US Pub. 2007/0226122 A1) discloses an electronic trading system facilitates electronic trades of fungible trading elements. Fungible trading elements are electronically displayed and the system facilitates the trading operations. A risk factor for a particular transaction may be determined and based on this risk factor, the electronic trading system may elect straight through processing (STP) operations to conclude a trade. Otherwise the risk factor may indicate avoiding the STP and allowing other settlement means. The electronic trading system also include the dematerialization of the trading elements, therefore verifying ownership prior to exchange and as such as more robust and secure trading platform.
(b) Dean; David et al. (US Pub. 2006/0265311 A1) discloses a method of investing in the stock market using the Threshold Trading Method wherein multiple stock movement trends are studied and the investor's decision to purchase stock is based primarily on the direction of the next longer trend.
6. Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). 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 extension fee 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 date of this final action.
Any inquiry concerning this communication or earlier communications from the Examiner should be directed to Narayanswamy Subramanian whose telephone number is (571) 272-6751. The examiner can normally be reached Monday-Friday from 9:00 AM to 5:00 PM. If attempts to reach the examiner by telephone are unsuccessful, the examiner's supervisor, Abhishek Vyas can be reached at (571) 270-1836. The fax number for Formal or Official faxes and Draft to the Patent Office 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.
/Narayanswamy Subramanian/
Primary Examiner
Art Unit 3691
March 6, 2026