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 .
Response to Amendment
Examiner acknowledges receipt of Applicant’s amendments and arguments filed 05/11/2026. The arguments set forth are addressed below.
The rejection of Claims 1-20 under 35 U.S.C. 101 is maintained.
The rejection of Claims 1-20 under 35 U.S.C. 102(a)(2) over Higgins is withdrawn.
Claims 1-20 are now pending.
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 to 20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter. The claimed invention is directed to non-statutory subject matter because the claim(s) as a whole, considering all claim elements both individually and in combination, do not amount to significantly more than an abstract idea. Each of Claims 1 to 20 has been analyzed to determine whether it is directed to any judicial exceptions.
The examiner follows the two step-analysis, as described in MPEP 2106 (available at https://www.uspto.gov/web/offices/pac/mpep/s2106.html). The following diagram is an overview of the steps involved.
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Step 1
Step 1 of the two step-analysis considers whether the claims fall into one of the four statutory categories of invention such as a process, machine, manufacture, or composition of matter. The instant invention claims a system in Claims 1-11 and a method in Claims 12-20. As such, the claimed invention falls into the broad statutory categories of invention. However, claims that fall within one of the four statutory categories may nevertheless be ineligible if they encompass laws of nature, physical phenomena, or abstract ideas.
Step 2A
Step 2A has been further divided into two prongs as shown in the following diagram.
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Step 2A, Prong 1
Under prong 1 of step 2A, the examiner considers whether the claim recites an abstract idea, law of nature or natural phenomenon. The term “abstract idea” is not interpreted as a layperson might. Instead, the term “abstract idea” is interpreted as described in legal opinions by courts.
According to MPEP 2106.04(a):
the Office has set forth an approach to identifying abstract ideas that distills the relevant case law into enumerated groupings of abstract ideas. The enumerated groupings are firmly rooted in Supreme Court precedent as well as Federal Circuit decisions interpreting that precedent, as is explained in MPEP § 2106.04(a)(2). This approach represents a shift from the former case-comparison approach that required examiners to rely on individual judicial cases when determining whether a claim recites an abstract idea. By grouping the abstract ideas, the examiners’ focus has been shifted from relying on individual cases to generally applying the wide body of case law spanning all technologies and claim types.
The enumerated groupings of abstract ideas are defined as:
1) Mathematical concepts – mathematical relationships, mathematical formulas or equations, mathematical calculations (see MPEP § 2106.04(a)(2), subsection I);
2) Certain methods of organizing human activity – fundamental economic principles or practices (including hedging, insurance, mitigating risk); commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations); managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions) (see MPEP § 2106.04(a)(2), subsection II); and
3) Mental processes – concepts performed in the human mind (including an observation, evaluation, judgment, opinion) (see MPEP § 2106.04(a)(2), subsection III).
The limitations of each claim recite a series of steps that, but for the generic computer recitations generally encompass a certain method of organizing human activity, specifically a fundamental economic practice and a commercial interaction in the nature of sales activity, and customer-loyalty incentives. In addition, limitations such as “…. tracking, by a processor (additional element), a quantity of occurrences of an activity associated with the gaming establishment device, and responsive to the tracked quantity of occurrences of the activity at least reaching a threshold quantity of occurrences …” recite a mental process: keeping a count of how many times something occurs, comparing that count to a threshold, and evaluating how much money to give back are acts of observation, evaluation, and judgment such that a casino cage attendant could perform it with pencil and paper. The recitation of a generic processor does not remove a limitation from the mental process grouping. The limitations includes the following below in italicized claim language:
Independent Claim 12 recites: “Claim 12 (original): A method of operating a system, the method comprising:
following a transfer of an amount of funds from a financial institution account maintained in association with a financial institution to a gaming establishment device (additional element) and following a fee amount being assessed in association with the transfer of the amount of funds from the financial institution account to the gaming establishment device:
tracking, by a processor (additional element), a quantity of occurrences of an activity associated with the gaming establishment device (abstract ideas: mental process including observation; and/or certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction), and
responsive to the tracked quantity of occurrences of the activity at least reaching a threshold quantity of occurrences:
determining, by the processor (additional element), a refund amount of the fee amount assessed (abstract ideas: mental process including observation; and/or certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction), and
communicating data associated with the determined refund amount of the fee to a component of a ticket voucher system, wherein responsive to an occurrence of a refund realization event, the component of the ticket voucher system causes a ticket voucher associated with at least the determined refund amount of the fee to be issued (abstract ideas: mental process including observation; and/or certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction).”
Independent Claim 1 recites: “1. (original) A system comprising:
a processor (additional element); and
a memory device (additional element) that stores a plurality of instructions that, when executed by the processor (additional) following a transfer of an amount of funds from a financial institution account maintained in association with a financial institution to a gaming establishment device and
following a fee amount being assessed in association with the transfer of the amount of funds from the financial institution account to the gaming establishment device (abstract ideas: mental process including observation; and/or certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction), cause the processor to:
track a quantity of occurrences of an activity associated with the gaming establishment device (abstract ideas: mental process including observation; and/or certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction), and
responsive to the tracked quantity of occurrences of the activity at least reaching a threshold quantity of occurrences:
determine a refund amount of the fee amount assessed (abstract ideas: mental process including observation; and/or certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction), and
communicate data associated with the determined refund amount of the fee to a component of a ticket voucher system, wherein responsive to an occurrence of a refund realization event, the component of the ticket voucher system causes a ticket voucher associated with at least the determined refund amount of the fee to be issued (abstract ideas: mental process including observation; and/or certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction).”
Independent Claim 10 recites: “Claim 10 (original): A system comprising:
a processor (additional element); and
a memory device (additional element) that stores a plurality of instructions that, when executed by the processor following a transfer of an amount of funds from a financial institution account maintained in association with a financial institution to an electronic gaming machine and following a fee amount being assessed in association with the transfer of the amount of funds from the financial institution account to the electronic gaming machine, cause the processor to:
responsive to a refund triggering activity event occurring in association with the electronic gaming machine, determine a refund amount of the fee amount assessed (abstract ideas: mental process including observation; and/or certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction), and
responsive to a refund realization event subsequently occurring in association with the electronic gaming machine, cause at least the determined refund amount to be made available in association with a ticket voucher issued by a component of a ticket voucher system (abstract ideas: mental process including observation; and/or certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction).
Each dependent claim incorporates the abstract idea of the claim from which it depends. Dependent claims 3-11, and 14-20 further recite the abstract idea groupings identified above:
wherein the refund realization event comprises a cashout input received by the electronic gaming machine (certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction);
wherein the issued ticket voucher is associated with the determined refund amount of the fee and a credit balance of the electronic gaming machine (certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction);
wherein the activity comprises at least one of an amount of games played, an amount wagered, an amount won, an amount lost, a game outcome obtained, and an amount of time spent playing a game (certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction);
wherein the refund realization event comprises a ticket voucher request received by the gaming establishment device and the issued ticket voucher is associated with the determined refund amount of the fee (certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction);
wherein the determined refund amount comprises a portion of the fee amount assessed (certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction);
wherein the transfer of the amount of funds from the financial institution account to the gaming establishment device comprises the amount of funds being transferred from the financial institution account to a gaming establishment account and at least a portion of the amount of funds being transferred from the gaming establishment account to the gaming establishment device (certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction);
wherein the transfer of the amount of funds from the financial institution account to the gaming establishment device occurs, independent of any gaming establishment account, in association with an electronic funds transfer (certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction);
wherein the refund realization event comprises a cashout input received by the electronic gaming machine (certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction);
wherein the refund realization event comprises a cashout input received by the electronic gaming machine (certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction);
wherein the issued ticket voucher is associated with the determined refund amount of the fee and a credit balance of the electronic gaming machine (certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction);
wherein the activity comprises at least one of an amount of games played, an amount wagered, an amount won, an amount lost, a game outcome obtained, and an amount of time spent playing a game (certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction);
wherein the refund realization event comprises a ticket voucher request received by the gaming establishment device and the issued ticket voucher is associated with the determined refund amount of the fee (certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction);
wherein the determined refund amount comprises a portion of the fee amount assessed (certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction);
wherein the transfer of the amount of funds from the financial institution account to the gaming establishment device comprises the amount of funds being transferred from the financial institution account to a gaming establishment account and at least a portion of the amount of funds being transferred from the gaming establishment account to the gaming establishment device (certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction); and
wherein the transfer of the amount of funds from the financial institution account to the gaming establishment device occurs, independent of any gaming establishment account, in association with an electronic funds transfer (certain methods of organizing human activity – specifically a fundamental economic practice and a commercial interaction).
Therefore, the claims recites an abstract idea.
Step 2A, Prong 2
Under prong 2 of step 2A, the examiner considers whether the additional elements in the claims integrate the abstract idea into a practical application. The abstract idea is not integrated into a practical application. According to 2019 PEG, a consideration indicative of integration into a practical application includes improvements to the functioning of a computer or to any other technology or technical field (MPEP 2106.05(a)) or adding a specific limitation other than what is well-understood, routine, conventional activity, or adding unconventional steps that confine the claim to a particular application (a non-conventional and non-generic arrangement of various computer components for filtering Internet content, as discussed in BASCOM Global Internet v. AT&T Mobility LLC, 827 F.3d 1341, 1350-51, 119 USPQ2d 1236, 1243 (Fed. Cir. 2016) (MPEP § 2106.05(d)). Conversely, considerations not indicative of integration include adding words “apply it” (or equivalent) with the judicial exception or mere instructions to implement the abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea. (MPEP 2106.05(f)); adding insignificant extra-solution activity (MPEP 2106.05(g)), or generally linking the use of the abstract idea to a particular technological environment or field of use (MPEP 2106.05(h)).
Here, the additional elements of the claims are a processor, a memory device that stores a plurality of instructions, a gaming establishment device, financial institutional account, electronic gaming machine (as recited in Claims 2 and 13), and a component of a ticket voucher system. These elements are recited so generically (no details whatsoever are provided other than in name only) that they represent no more than mere instructions to apply the judicial exception on a computer. Applicant’s Specification does not disclose that the processor, memory device, set of instructions or display are directed to a technological solution to a technological problem that “overcome some sort of technical difficulty.” citing ChargePoint, Inc. v. SemaConnect, Inc., 920 F.3d 759, 768 (Fed. Cir. 2019).
According to Applicant’s specification discloses “[t]hese computer program instructions may be provided to a processor of a general purpose computer” [0070] and memory not limited to one memory device, which includes: (1) volatile memory (e.g., RAM which can include non-volatile RAM, magnetic RAM, ferroelectric RAM, and any other suitable forms); (2) non-volatile memory (e.g., disk memory, FLASH memory, EPROMs, EEPROMs, memristor-based non-volatile solid-state memory, etc.);” [0072]. Consequently, these devices and programming are viewed as nothing more than an attempt to generally link the use of the judicial exception to the technological environment of a computer or as a means to automate the steps. It should be noted that because the courts have made it clear that mere physicality or tangibility of an additional element or elements is not a relevant consideration in the eligibility analysis, the physical nature of these computer components does not affect this analysis. See MPEP 2106.05(I) for more information on this point, including explanations from judicial decisions including Alice Corp. Pty. Ltd. v. CLS Bank Int'l, 573 U.S. 208, 224-26 (2014).
The gaming establishment device, the financial institution account, and the ticket voucher system component are recited only as the fields of use and the locations at which the recited fee, tracking and refund operations occur, which does no more than limit the abstract idea to a particular technological environment. MPEP 2106.05(h). Communicating the refund data and issuing the voucher is the output step of the fee-rebate determination and constitutes insignificant extra-solution (post-solution) activity. MPEP 2106.05(g). The claims recite no improvement to the functioning of ta computer, no improvement to any other technology or technical field, no particular machine beyond generic computing hardware, and no transformation of an article to a different state or thing. The additional element accordingly do not integrate the judicial exception into a practical application. Thus, Claim 1, and similarly Claims 10 and 12, and their dependent claims lack the eligibility requirements of Step 2 Prong II.
Step 2B
Finally, under step 2B, the examiner evaluates whether the additional elements:
add a specific limitation or combination of limitations that are not well-understood, routine, conventional activity in the field, which is indicative that an inventive concept may be present (MPEP 2106.05(d)); or
simply appends well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception, which is indicative that an inventive concept may not be present (MPEP 2106.05(d) and Berkheimer Memo, April 20, 2018). Thus, the additional elements evaluated under Step 2A are re-evaluated in Step 2B to determine if they are more than what is well-understood, routine, conventional activity in the field.
According to the 2019 PEG, in addition to the considerations discussed in Step 2A, an additional consideration indicative of an inventive concept (aka “significantly more”) is the addition of a specific limitation other than what is well-understood, routine, conventional activity in the field (MPEP 2106.05(d)). Conversely, an additional consideration not indicative of an inventive concept is simply appending well-understood, conventional activities previously known to the industry, specified at a high level of generality, to the abstract idea (MPEP 2106.05(d) and Berkheimer Memo, April 20, 2018). Thus, the additional elements evaluated under Step 2A are re-evaluated in Step 2B to determine if they are more than what is well-understood, routine, conventional activity in the field.
Here, the abstract idea is not integrated into a practical application. The additional elements in the claims are a processor, a memory device that stores a plurality of instructions, a gaming establishment device, financial institutional account, electronic gaming machine (as recited in Claims 2 and 13), and a component of a ticket voucher system. The additional elements of the processor and memory device are recited at the highest level of generality and are so generically claimed that they represent no more than mere instructions to apply the judicial exception on a computer. The gaming establishment device and the electronic gaming machine are also generically recited and used in its ordinary capacity. The ticket voucher system is a generic component performing its ordinary function. A ticket voucher system issues ticket vouchers. Nothing in the claims causes it to operate differently, faster, or in any manner other than the manner in which such systems already operate.
The tracking, determining, and communicating steps of the claims are deemed to be data gathering and data presentation extra-solution activity. Court decisions cited in MPEP 2106.05(d)(II) indicate that these limitations are well-understood, routine, and conventional function when it is claimed in a merely generic manner (as they are here). See storing and retrieving information in memory (MPEP 2106.05(d)(II)(iv) and then to present or display said information is well known as in presenting offers and gathering statistics (MPEP 2106.05(d)(II)(iii). Issuing a ticket voucher associated with an amount of funds in connection with playing at an electronic gaming machine is likewise well-understood, routine, and conventional in the gaming art. Warner, US Patent, 8,979,642, Col. 8:51-58 recites “… the player receives a cash equivalent ticket in the amount of the requested transfer, or the gaming device is credited with the approved amount. This effectively emulates every step that an ordinary ATM does except the output is a ticket or credited credits to a specific gaming device instead of cash. The cash equivalent ticket is redeemable for cash through a ticket redemption machine, cashier station, or kiosk…”
Furthermore, taking the additional elements individually and in combination, the additional elements do not provide significantly more. Specifically, when viewed individually, the above-identified additional elements in the claims do not add significantly more because they are simply an attempt to limit the abstract idea to a particular technological environment. That is, neither the general computer elements nor any other additional element adds meaningful limitations to the abstract idea because these additional elements represent insignificant extra-solution activity. The above-identified additional elements, when viewed as whole, do not provide meaningful limitations to transform the abstract idea into a patent eligible application of the abstract idea such that the claims amount to significantly more than the abstract idea itself.
Therefore, the claims are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter.
AIA Notice
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.
Regarding the Prior Art
Upon conducting an updated search, the closest prior art appears to be U.S. Patent 8,979,642 to Warner, 8,595,137 to Sears et al., 7,410,422 to Fine and U.S. Patent Application Publication 2019/0197526 to Higgins et al. Higgins generally discloses a plurality of cashless wallets, including sports/mobile gaming wallet, a retail wallet, and a casino gaming wallet, according to an embodiment. The resort wallet system, which may be embodied in hardware, software, or a combination thereof, includes a resort wallet that serves as a combined wallet for a number of other cashless wallets and/or other financial accounts. In the example of FIG. 1B, the server may be communicatively coupled to a database directly and/or via a wired or wireless network, for example. The server may also be communicatively coupled to a plurality of devices configured to interact with and/or manage certain aspects and/or features of the resort wallet system. For example, the server may be coupled to one or more slot machines and/or other gaming devices located on a casino floor. The slot machines may be configured to access the casino gaming wallet of a player for placing wagers for and paying out winnings to the player and may also be configured to access the retail wallet for providing additional non-gaming features to the player. In some embodiments, it may be necessary to reverse and/or refund a purchase transaction. Warner generally discloses electronic fund transfer (EFT) systems and methods are disclosed for managing and transferring electronic funds from a patron's financial account to provide gaming or amusement credit in physical or electronic form. The systems comprise an electronic fund transfer (EFT) device, a secure payment gateway configured to connect to the patron's financial accounts via a financial network, a host system, and a funds management portal connected to the host system and to the secure payment gateway. Fine generally discloses In a casino enterprise, players earn reward credits from their betting activity at gaming machines, tables and devices. Base credits are earned by players at a fixed rate according to their coin-in; bonus credits are earned at a variable rate as a function of their worth as players to the casino or the property at which they are gaming. Sears generally discloses a method for processing cash advance transactions in a casino having an authorized MCD processor and, in particular, for processing non-service fee/surcharge transactions as Manual Cash Disbursements by the system.
However, Higgins, Warner, Fine, and/or Sears in combination or taken alone, fails to disclose, teach, or reasonably suggest ….. “responsive to the tracked quantity of occurrences of the activity at least reaching a threshold quantity of occurrences: … determine a refund amount of the fee amount assessed, …, the component of the ticket voucher system causes a ticket voucher associated with at least the determined refund amount of the fee to be issued.”. As such, for at least these reasons, Examiner have found these limitations in combination with the other limitations of the claim are neither anticipated by nor obvious over the closest prior art.
Response to Arguments/Remarks
Applicant’s arguments filed 05/11/2026 have been fully considered.
Applicant’s addresses the rejection of Claims 1-20 under 35 U.S.C. 101 on pages 7-8. The arguments have been fully considered but they are not persuasive. The Examiner respectfully disagrees for the following reason below.
On page 7, Applicant argues that “… that software-type claims in particular are not "inherently abstract." Enfish, LLC v. Microsoft Corp., 822 F.3d 1327, 1335 (Fed. Cir. 2016) ("[A] substantial class of claims are not directed to a patent-ineligible concept."). The Federal Circuit has specifically cautioned against describing the claims at a "high level of abstraction and untethered from the language of the claims all but ensures that the exceptions to § 101 swallow the rule." Id. at 1337.”
While the Examiner agrees with the legal proposition stated by Applicant, the rejection does not rest on the premise that software claims are inherently abstract; it rests on specific limitations recited in Claim 1, identified individually in the 101 rejections above. The Enfish case here is distinguishable on the facts of that case. The claims there recited a specific data structure – a self-referential table in which all entity types are modeled in a single table with column definitions provided by rows – and the improvement was to the way a computer stores and retrieves data. Here, Claim 1 does not recite any change to how any computer operates or any improvements intended to improve the performance of a computer system, similar to Enfish. It recites a rule for when money is returned and a conventional instruction to print the returned amount on a ticket.
Applicant also argues that “under the second prong, all additional elements recited in a claim should be given equal weight because Step 2A specifically excludes consideration of whether the additional elements represent well-understood, routine, and/or conventional activity. Thus, a claim that includes conventional elements may still integrate a judicial exception into a practical application, thereby satisfying the subject matter eligibility requirement of Section 101.”
The Prong Two analysis does not rely on conventionality. The additional elements fail Prong Two for reasons independent of conventionality: they are recited at a high level of generality, they are used as tools to apply the exception, they perform data gathering and data transmission that is extra-solution to the determination, and they confine the exception to a field of use. That conventional elements may integrate an exception does not establish that the elements of this case does. Applicant has not identified any additional element, or any ordered arrangement of additional elements, that applies or uses the exception in a manner imposing a meaningful limit.
On page 8, Applicant argues “the particular manner in which the system of representative independent Claim 1 operates provides a solution to the recognized problems associated with the employment of cash within a gaming establishment ... This reduction in the employment of cash in a gaming establishment results in diminishing associated safety risks (e.g., risk of theft or loss of such cash) and health concerns (e.g., risk of transmission of contagions via cash-based transactions). In addition to these advances, the claimed systems additionally reduce the amount of cash transactions in a gaming establishment and in doing so, reduce the employment of resources otherwise dedicated to the processing of cash (e.g., use of computing components of a gaming establishment count room) as well as the wear and tear of certain cash-handling devices (e.g., kiosks that accept cash) to prolong the operational life of such devices.”
The Examiner respectfully disagrees. First, the improvement does not appear in the claims. MPEP 2106.05(a) requires that … “After the examiner has consulted the specification and determined that the disclosed invention improves technology, the claim must be evaluated to ensure the claim itself reflects the disclosed improvement in technology.” Here, Claim 1 does not recite the reduction in the employment of cash, a kiosk that accepts cash, or cash. A benefit described only in the specification and argued only in the remarks cannot integrate the exception into a practical application. Additionally, the recited improvement is done through human behavior and not through technology. Applicant’ recites “.. by incentivizing a user to transfer an amount of funds from an external account for access on a gaming establishment device via providing certain benefits (e.g., a refund amount), the systems provide a more secure environment for the user…” (page 8). That is the improvement of a commercial transaction/business practice using a computer as tool. Lastly, the reduced risk of theft and reduced health concerns are consequences of users/patrons carrying less cash/currency. They are not effected by any recited operation of the processor, the memory, or the ticket voucher system and they do not make the claim less abstract.
Therefore, it is the Examiner’s conclusion that the arguments under 35 U.S.C. 101 are not persuasive and the rejection of Claims 1-20 are hereby maintained.
Applicant’s arguments on pages 9-10 that Higgins does not appear to assess a fee amount in association with the transfer of funds from the casino gaming wallet to the second retail wallet, does not appear to include any refund associated with a fee amount, and does not appear to cause any issuance of a paper ticket associated with a determined refund amount of a fee amount, are persuasive as to anticipation. The rejection of Claims 1-20 under 35 U.S.C. 102(a)(2) is hereby withdrawn.
Conclusion
Claims 1-20 are examined above.
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/S.N.H/Examiner, Art Unit 3715
/JAMES B HULL/Primary Examiner, Art Unit 3715