DETAILED ACTION
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 .
Claim Interpretation
The following is a quotation of 35 U.S.C. 112(f):
(f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.
The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) is invoked.
As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f):
(A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function;
(B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and
(C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function.
Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f). The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function.
Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f). The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function.
Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f), except as otherwise indicated in an Office action.
This application includes one or more claim limitations that do not use the word “means,” but are nonetheless being interpreted under 35 U.S.C. 112(f) because the claim limitations use a generic placeholder that is coupled with functional language without reciting sufficient structure to perform the recited function and the generic placeholder is not preceded by a structural modifier. Such claim limitations are:
“analyzing, by a device and using at least one of an optical character recognition technique or a natural language processing technique, a document, ... matching, by the device, the document with a record included in a ledger ... generating, by the device, display information associated with the ledger ... and transmitting, by the device, the display information to cause the display information to be displayed by another device” in claims 8-14.
“receiving, from an entity device associated with the record or a user device associated with the user account, an image of the document or a file of the document; or obtaining, from a database of the device, a document” in claim 12. Examiner notes that substantially similar subject matter is recited in claims 5 and 19. However, in those claims the corresponding structure is specified as the “one or more processors” of the device, unlike claim 12.
Because these claim limitations are being interpreted under 35 U.S.C. 112(f), they are being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof.
If applicant does not intend to have these limitations interpreted under 35 U.S.C. 112(f), applicant may: (1) amend the claim limitations to avoid them being interpreted under 35 U.S.C. 112(f) (e.g., by reciting sufficient structure to perform the claimed function); or (2) present a sufficient showing that the claim limitations recite sufficient structure to perform the claimed function so as to avoid them being interpreted under 35 U.S.C. 112(f).
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 (i.e., changing from AIA to pre-AIA ) 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, 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 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.
This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed inventions absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention.
Claims 1-20 are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Pat. No. 10572727 to Sachtleben et al. (hereinafter “Sachtleben”) in view of U.S. Pat. Appl. Pub. No. 20160042469 to Lochrie et al. (hereinafter “Lochrie”).
Regarding claim 1, Sachtleben teaches a device (A server that communicates to a user’s mobile device via a browser. See Sachtleben at FIG. 1A, “Account migration device(s) 132)”; col. 19, l. 63 - col. 20, l. 11, “system 1400 may be included, at least in part, in the user device 138, the account migration device(s) 132, the account management device(s) 126A, the account management device(s) 126B, and/or other device(s) described herein.”), comprising:
one or more memories (Sachtleben, col. 20, ll. 4-41, “memory 1420, one or more storage devices 1430”); and
one or more processors (Sachtleben, col. 20, ll. 4-41, “one or more processors 1410”), coupled to the one or more memories, configured to:
analyze, using at least one of an optical character recognition technique (Sachtleben, col. 17, l. 57 - col. 18, l. 4, “pattern recognition such as OCR, ICR, or some other suitable technique”) or a natural language processing technique (Sachtleben, col. 8, ll. 61-67, “The identification of recurring transactions may include categorization, classification, pattern identification, natural language processing, semantic analysis, value comparison, and/or any other suitable types of processing.”), a document (Sachtleben, col. 19, ll. 35-38, “capture the image of the bill in the frame”; col. 17, ll. 46-56, “the image(s) may have been provided to the user 140, as an electronic bill, from the biller”; col. 4, l. 6, “image(s) of a utility bill may be analyzed”), associated with a user account (The user may upload an image of a recurring bill that has been previously paid from the first account and needs to be updated with respect to the second account the user is migrating to. See Sachtleben at col. 8, ll. 7-26, “first account”. The Snap Bill feature analyzes the image of the bill to extract billing information and set up payments from the new “second account” instead of the old account (“first account”). See id. at col. 19, ll. 27-62. ), to identify one or more characteristics of the document (Sachtleben, col. 19, ll. 39-50, “The captured image(s) may be analyzed, as described above, to extract the bill information from the image(s). The UI may present the bill information an example UI 1340, as shown in FIG. 13E.”);
match the document (The image of the bill is used to determine and schedule a record (transaction), thereby matching the document to the ledger or account. See Sachtleben at col. 19, ll. 59-62, “As described above, in some implementations, the payment of the bill may be automatically scheduled based on the due date extracted from the image(s) of the bill.”; col. 18, ll. 5-23, “The bill information can also include other information, including but not limited to an amount due and a due date.”; col. 11, ll. 1-16, “In some instances, charges may be scheduled to be performed after a recurring payment (e.g., paycheck deposit) is made into the new account, to reduce the risk of overcharges against the new account.”) with a ledger (Sachtleben, col. 17, ll. 24-38, “the account history of the user’s old account.”) associated with the user account (The first (old) account includes a transaction history of credits and debits. See Sachtleben at col. 5, l. 63 - col. 5, l. 19. A “ledger” is characterized by the instant application, in one example, as a transaction history (record log) of vendors, dates, and amounts in FIG. 1C. The BRI of “ledger” is a log (record) or history of transactions (records) for an account over a period of time. Transaction history of the associated account of the debit or credit card is a “ledger”.) based on the one or more characteristics of the document (Sachtleben, col. 1, ll. 30-34, “analyzing document image(s) to identify a transaction made against a first account, such as a bill paid regularly or semi-regularly from the first account”);
generate (e.g., by the account migration device(s) 132 (remotely) and/or user device 138 (locally). See Sachtleben at col. 23, ll. 22-55) display information associated with the ledger (e.g., displaying information related to a recurring transaction that used to be paid from the old account (ledger) and has now been scheduled to be paid from the new ledger) based on matching the document (Once the recurring transaction is identified based on the analysis of the document and the old account history, and migrated to the new account, information pertaining to the transaction is generated and then displayed. See Sachtleben at FIGs. 13A-F, including the payee, due date, and amount owed under “Billers Added”); and
transmit the display information to cause the display information to be displayed (Figures 2A-2E, 3A-3F, 4A-4C, 5A-5F,6A-6F, 7A-7D, 8A-8E, 9A-9D and 13A-13F show examples of graphical user interfaces (GUIs), e.g., as a graphical user interface (GUI) of an app executing on a mobile device used to capture and upload a bill image to a web server he input image of a bill to be scheduled for a specific transaction record in the user’s old account. See Sachtleben at col. 19, ll. 1-10; 6, ll. 38-48, “In some implementations, the request for account migration may be submitted by a user (e.g., customer) using an application executing on a computing device, such as a smartphone, tablet computer, wearable computer, laptop computer, desktop computer, or any other type of computing device. The application may be a web application that executes at least partly in a browser on the user device 138, or that executes in some other container for dynamic and/or static web content. The application may also be a (e.g., native) application that executes outside a browser on the user device 138.”), but does not teach that which is explicitly taught by Lochrie.
Lochrie teaches match the document with a record included in a ledger (Lochrie, pars. 35-36, “The server will process the picture (perform OCR) to derive information regarding the transaction that the receipt contains and will further store a copy of the receipt. ... The transaction processing application may match the transaction record against the accessed data, including any imported data. The matching may be achieved by a learning process, which implements a learning algorithm or calculation. The result of the learning algorithm or calculation may be a single view of the transaction.”; par. 83, “Another view is shown in FIG. 7, wherein two separate transaction records, that are source records, are shown as merged into a single financial transaction. This may occur due to the system functioning to match a record from a bank import and a record from a receipts application.”).
Sachtleben discloses scanning and associating an image of a document, e.g., a bill, with a recurring transaction in a registered user’s account using OCR and natural language processing. Thus, Sachtleben shows that it was known in the art before the effective filing date of the claimed invention to associate related data for the same transaction, which is analogous to the claimed invention in that it is pertinent to the problem being solved by the claimed invention, matching a scanned document to a user’s history of transaction records to provide additional context to the user and/or automate future transactions. Lochrie discloses scanning and matching extracted data from an image of a receipt with data of an associated transaction record in a registered user’s account, and displaying the record data supplemented with the extracted data. Thus, Lochrie shows that it was known in the art before the effective filing date of the claimed invention to match documents of financial transactions or records with a corresponding transaction record in a user’s account or ledger, and displaying or otherwise supplementing the matching information as context to the existing data for the transaction record, which is analogous to the claimed invention in that it is pertinent to the problem being solved by the claimed invention, matching a scanned document to a user’s history of transaction records to provide additional context to the user and/or automate future transactions.
A person of ordinary skill in the art would have been motivated to combine the matching processing and GUI-based transaction grouping and consolidation disclosed by Lochrie with the OCR scanning and recurring transaction association thereof disclosed by Sachtleben, to thereby match uploaded or scanned documents to specific transaction records of recurring transactions and provide additional transaction-specific context in a consolidated view thereof to a user through a GUI used to access and manage their account. Based on the foregoing, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have made such modification according to known methods to yield the predictable results to have the benefit of providing useful contextual data to better inform a user of pertinent transaction-specific information, and enable the display of anything extracted from a provided document image alongside matching transaction information.
Regarding claim 2, Sachtleben in view of Lochrie teaches the device of claim 1, wherein the one or more processors are further configured to:
transmit an account registration (To register the first and/or second account with the system, the user may be prompted to enter their credentials, password, security information, and so forth. See Sachtleben at col. 6, ll. 49-67.), associated with the user account (Sachtleben - The data transmitted to the browser for adding bills and migrating transactions occurs after the user has logged in and registered their account(s) to permit the system to access the account(s), upload new bills, and so forth.), indicating one or more permissions associated with analyzing the document (Sachtleben - If account registration is successful, then the system is permitted to analyze the scanned bill. If not successful, then there is no permission to do so.).
Regarding claim 3, Sachtleben in view of Lochrie teaches the device of claim 1, wherein the one or more processors are further configured to:
analyze a plurality of records, including the record, associated with the user account to identify the record associated with the document (If recurring transactions are identified, there are at least two transactions. See Sachtleben at col. 8, ll. 61-67, “The identification of recurring transactions may include categorization, classification, pattern identification, natural language processing, semantic analysis, value comparison, and/or any other suitable types of processing.”).
Regarding claim 4, Sachtleben in view of Lochrie teaches the device of claim 3, wherein the one or more processors are further configured to:
receive an indication of the document (Sachtleben, col. 1, ll. 58-64, “a barcode that encodes at least a portion of the information”),
wherein the plurality of records are analyzed based on the indication of the document (Sachtleben, col. 1, ll. 58-64, “the physical document includes a barcode that encodes at least a portion of the information; analyzing the at least one image includes scanning the barcode in the at least one image to decode the encoded information; the information describes a recurring payment that is made to the payee”).
Regarding claim 5, Sachtleben in view of Lochrie teaches the device of claim 1, wherein the one or more processors are further configured to:
receive from a user device associated with the user account (Sachtleben, col. 19, ll. 1-10, “the UIs may be provided by an application (e.g., an app) executing on the user device 138.”), an image of the document or a file of the document (Sachtleben, col. 16, ll. 60-67, “In some implementations, the user 140 may identify and upload an image of a bill that is already in a digital format, such as a Portable Document Format (PDF) file of the bill provided by the biller to the user 140.”),
wherein the document is analyzed based on:
receiving the image of the document (Sachtleben, col. 3, ll. 66-67, “using a camera of a smartphone or other portable computing device”) or the file of the document (Sachtleben, col. 16, ll. 60-67, “upload an image of a bill”), or obtaining the document (Sachtleben, col. 17, ll. 46-56, “One or more images of a bill, or other type of physical (e.g., printed, paper) document, may be received (1202).”).
Regarding claim 6, Sachtleben in view of Lochrie teaches the device of claim 1, wherein the one or more characteristics comprise at least one of: segments in image data of the document, or specific text of the document (OCR recognizes image segments of text, e.g., alphanumeric characters. See Sachtleben at col. 17, l. 57 - col. 18, l. 4, “pattern recognition such as OCR, ICR, or some other suitable technique”).
Regarding claim 7, Sachtleben in view of Lochrie teaches the device of claim 1, wherein, to generate the display information, the one or more processors are configured to:
append information associated with at least one characteristic (Lochrie, par. 39, “Once a match is determined, the transaction processing application may link the accessed data and the transaction record to create a single transaction profile that may be used for financial purposes.”), of the one or more characteristics (Sachtleben, col. 19, ll. 39-50, “bill information from the image(s)”), to information associated with the record (ledger or account data).
Claims 8-14 substantially correspond to claims 1-7 by reciting method steps corresponding to the claimed device functions in claims 1-7 (Sachtleben, col. 20, ll. 4-41, “one or more processors 1410”). The rationale for obviousness is the same as provided for claim 1.
Claims 15-20 substantially correspond to claims 1-6 by reciting a non-transitory computer-readable medium (Sachtleben, col. 20, ll. 4-41, “memory 1420, one or more storage devices 1430”) storing instructions to be executed by the one or more processors (Sachtleben, col. 20, ll. 4-41, “one or more processors 1410”) to implement the claimed device functions in claims 1-6. The rationale for obviousness is the same as provided for claim 1.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure because it is analogous art to the claimed inventions and discloses relevant subject matter that a POSITA would consider when looking to improve upon the teachings of Sachtleben and/or Lochrie:
U.S. Pat. Appl. Pub. No. 20210056618 to Brown et al. is analogous art to Sachtleben and Lochrie for disclosing identification of recurring transactions when a user is switching financial institutions including use of a GUI that provides display information based on the identified recurring transactions. See Brown et al. at FIG. 2.
U.S. Pat. Appl. Pub. No. 20220245641 to Wintle et al. is analogous art to Sachtleben and Lochrie for disclosing training a machine learning (ML) model to predict future recurring transactions using historical transaction data. See Wintle et al. at pars. 32-34.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to RYAN P POTTS whose telephone number is (571)272-6351. The examiner can normally be reached M-F, 9am-5pm EST.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Sumati Lefkowitz can be reached at 571-272-3638. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/RYAN P POTTS/Examiner, Art Unit 2672
/SUMATI LEFKOWITZ/Supervisory Patent Examiner, Art Unit 2672
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