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 (RCE) filed on February 13, 2026. Amendments to claims 1, 8, 15 and 20 have been entered. Claims 1-20 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 July 16, 2025 and hence not repeated here. The rejections and response to arguments are stated 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 and system for managing collection processing, 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 15 is directed to a system (apparatus).
Step 2A – Prong One: The limitations of “A system, comprising:
a processor; and
memory including instructions, which when executed by the processor, perform a method comprising:
obtaining, using an action optimization manager, debtor information, associated with a set of debtor devices each executing on a computing device, from a data source;
wherein the set of debtor devices and the data source is operatively connected to the action optimization manager via a network,
wherein the debtor information is obtained via the network, and
wherein the data source is a database;
generating a set of state spaces based on debtor attributes of the debtor information, wherein each of the set of state spaces is a vector comprising debtor features obtained from the debtor information;
wherein each of the set of state spaces is further based on past collector portfolio
features of a set of collection devices, and
wherein the past collector portfolio features comprise: a number of accounts managed by each of the set of collection devices, engagement efforts by each of the set of collection devices at a previous point in time, expertise of users associated with each of the set of collection devices, and complexity of cases handled by each of the set of collection devices;
applying an action-reward analysis on the set of debtor devices using the set of state spaces to generate state-action values for each of the set of debtor devices;
applying, using the state action values, a profile analysis to obtain, for each of a set of collection devices, a debtor portfolio;
implementing collection actions based on the debtor portfolio for each of the set of debtor devices,
wherein the collection actions comprise: an order for communicating with the set of debtor devices by each collecting device in the set of collection devices, and a determined time for communicating with each of the set of debtor devices,
wherein a first order is based on a first debtor portfolio of a first collection device; and
communicating, by the first collecting device and using the network, with the set of debtor devices based on the first order and based on the determined time for communicating with each of the set of debtor devices” 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.
Managing collection processing including implementing collection actions based on the debtor portfolio for each of the set of debtor devices is a fundamental economic practice such as collecting debt.
The steps of “implementing collection actions based on the debtor portfolio for each of the set of debtor devices, wherein the collection actions comprise: an order for communicating with the set of debtor devices by each collecting device in the set of collection devices, and a determined time for communicating with each of the set of debtor devices, wherein a first order is based on a first debtor portfolio of a first collection device; and communicating, by the first collecting device and using the network, with the set of debtor devices based on the first order and based on the determined time for communicating with each of the set of debtor devices” considered collectively is a form of fulfilling agreements between the creditor and the debtor. 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, a processor, memory including instructions, an action optimization manager, a set of debtor devices each executing on a computing device, a set of collection devices, a data source including a database, and a network, 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 a processor, memory including instructions, an action optimization manager, a set of debtor devices each executing on a computing device, a set of collection devices, a data source including a database, and a network to perform all the steps. A plain reading of Figures 1-5 and associated descriptions in at least paragraphs [0016] – [0031] and [0077] – [0082] reveals that the processor may be a generic processor suitably programmed to execute the claimed steps. The memory may be a generic memory suitably programmed to store the associated information. The debtor devices and the collection devices may be generic computer devices appropriately programmed to perform the corresponding functions. The data source may a generic database. The action optimization manager is broadly interpreted to include generic software components suitably programmed to execute the claimed steps. The network may be a local area network (LAN), a wide area network (WAN) such as the Internet, mobile network, or any other type of network. 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 15 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 15 is not patent eligible. Independent claims 1 and 8 are also not patent eligible based on similar reasoning and rationale.
Dependent claims 2-7, 9-14 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 “wherein applying the action-reward analysis comprises:
determining a reward for each of the set of state spaces; and
determining, based on the reward, an action for each of the set of state spaces, wherein the state-action values are associated with the action of each of the set of state spaces and the state spaces” 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 determining the reward and determining the action are based on a Markov Decision process” under the broadest reasonable interpretation, are further refinements of methods of organizing human activity because these steps describe the criterion used in the intermediate steps of the underlying process.
In claims 4-5, 11-12, and 18-19, the steps “wherein applying the profile analysis comprises:
generating debtor listings for a collection device of the set of collection devices; determining knapsack values each associated with one of the debtor listings; and selecting, for the collection device, a debtor listing with highest action-reward value, wherein the selected debtor listing is the debtor portfolio for the collection device” and “wherein determining the knapsack values is performed by solving a stochastic binary multi-knapsack problem” 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 6-7, 13-14, and 20, the steps “further comprising:
after implementing the collection actions, updating the action-reward analysis based on results of the implementing to obtain an updated action-reward analysis” and
“further comprising: obtaining, using the action optimization manager, second debtor information, associated with the set of debtor devices;
generating a second set of state spaces based on second debtor attributes of the second debtor information;
applying the updated action-reward analysis on the set of debtor devices using the second set of state spaces to generate second state-action values for each of the set of debtor devices;
applying, using the second state action values, an updated profile analysis to obtain, for each of a set of collection devices, a second debtor portfolio; and implementing new collection actions based on the second debtor portfolio for each of the set of debtor devices” 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 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 11-17 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 and system for managing collection processing, 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.
Managing collection processing including implementing collection actions based on the debtor portfolio for each of the set of debtor devices is a fundamental economic practice such as collecting debt. The steps of “implementing collection actions based on the debtor portfolio for each of the set of debtor devices, wherein the collection actions comprise: an order for communicating with the set of debtor devices by each collecting device in the set of collection devices, and a determined time for communicating with each of the set of debtor devices, wherein a first order is based on a first debtor portfolio of a first collection device; and communicating, by the first collecting device and using the network, with the set of debtor devices based on the first order and based on the determined time for communicating with each of the set of debtor devices” considered collectively is a form of fulfilling agreements between the creditor and the debtor. Hence, the steps of the claim, considered collectively as an ordered combination without the italicized portions (identified in the rejection), recite an abstract idea.
The claimed features including those recited on page 14 of the remarks such as “generating of state spaces, applying an action-reward analysis on a set of devices using the generated state spaces, applying a profile analysis to obtain a debtor portfolio, and communicating with the set of devices via a network” only further improve 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. 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 rejection) are generic computer components used to apply the abstract idea. Therefore, the Applicant’s arguments are not persuasive.
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 a processor, memory including instructions, an action optimization manager, a set of debtor devices each executing on a computing device, a set of collection devices, a data source including a database, and a network to perform all the steps. A plain reading of Figures 1-5 and associated descriptions in at least paragraphs [0016] – [0031] and [0077] – [0082] reveals that the processor may be a generic processor suitably programmed to execute the claimed steps. The memory may be a generic memory suitably programmed to store the associated information. The debtor devices and the collection devices may be generic computer devices appropriately programmed to perform the corresponding functions. The data source may a generic database. The action optimization manager is broadly interpreted to include generic software components suitably programmed to execute the claimed steps. The network may be a local area network (LAN), a wide area network (WAN) such as the Internet, mobile network, or any other type of network. 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. The claimed features including “data processing and communication between devices based on optimized ordering” may be characterized as an improvement in the abstract idea of a method and system for managing collection processing. It does not involve any improvements to another technology, technical field, or improvements to the functioning of the computer itself. Hence, the claims are directed to an abstract idea. 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.
In reference to the USPTO guidelines based in MPEP 2106.04(d) (formerly known as the Berkheimer Memo) that that an additional element (or combination of additional elements) is well-understood, routine, conventional activity, the Examiner would like to point out the MPEP 2106.04(d) states:
Appropriate forms of support that an additional element (or combination of additional elements) is well-understood, routine, conventional activity include one or more of the following:
1. A citation to an express statement in the specification or to a statement made by an applicant during prosecution that demonstrates the well-understood, routine, conventional nature of the additional element(s).
2. A citation to one or more of the court decisions discussed in MPEP § 2106.05(d)(II) as noting the well-understood, routine, conventional nature of the additional element(s).
3. A citation to a publication that demonstrates the well-understood, routine, conventional nature of the additional element(s).
4. A statement that the examiner is taking official notice of the well-understood, routine, conventional nature of the additional element(s).
The additional elements in the claims are a processor, memory including instructions, an action optimization manager, a set of debtor devices each executing on a computing device, a set of collection devices, a data source including a database, and a network to perform all the steps. A plain reading of Figures 1-5 and associated descriptions in at least paragraphs [0016] – [0031] and [0077] – [0082] reveals that the processor may be a generic processor suitably programmed to execute the claimed steps. The memory may be a generic memory suitably programmed to store the associated information. The debtor devices and the collection devices may be generic computer devices appropriately programmed to perform the corresponding functions. The data source may a generic database. The action optimization manager is broadly interpreted to include generic software components suitably programmed to execute the claimed steps. The network may be a local area network (LAN), a wide area network (WAN) such as the Internet, mobile network, or any other type of network. Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. There is no indication in Applicants’ claims that any specialized hardware or other inventive computer components are required. The fact that a general purpose computing system, suitably programmed, may be used to perform the claimed method and the fact that the claims at issue do not require any nonconventional computer, network, or other components, or even a “non-conventional and non-generic arrangement of known, conventional pieces” but merely call for performance of the claimed functions “on a set of generic computer components, satisfies the MPEP 2106 requirement that the additional elements are conventional elements (as outlined in criterion 1 of the MPEP 2106). In Summary, the computer system is merely a platform on which the abstract idea is implemented. Hence, the claims do not recite significantly more than an abstract idea. The claimed features such as “providing a collection system the most efficient method for contacting the debtors, using debtor information to calculate the optimal set of collection actions” may, at best, be characterized as a business solution, using the additional elements (identified in the rejection) as tools in their ordinary capacity, to a problem rooted in abstract idea of managing collection processing. The alleged advantages such as “improving the collection system overall” are due to improvements in the abstract idea.
The Examiner does not see the parallel between the Applicant’s claims and those in DDR Holdings, LLC. v. Hotels.com, L.P., 773 F.3d 1245, 1257, 113 USPQ2d 1097, 1105 (Fed. Cir. 2014); and/or Amdocs (Israel), Ltd. v. Openet Telecom, Inc., 841 F.3d 1288, 1300-01, 120 USPQ2d 1527, 1537 (Fed. Cir. 2016). Therefore, the Applicants’ arguments are not persuasive.
For these reasons and those discussed in the rejection, the rejections under 35 USC § 101 are maintained.
Conclusion
5. The prior art made of record and not relied upon is considered pertinent to applicant's disclosure:
(a) Shah; Vishal et al. (US Pub. 2020/0265443 A1) discloses techniques to manage and predict future events. For example, in a payment implementation, a supplier, at any given point in time, has multiple customer debtors that may owe payments (e.g., have outstanding invoices). Utilizing historical attributes for a given customer debtor payment predictions may be determined. By analyzing outstanding debts associated with this debtor customer an amount owed may be calculated and a predicted payment (e.g., a payment that has not yet been indicated by that debtor customer) created. Events may be provided to a second system to correlate predictions across multiple debtor collectors. Correlated information may be used to predict cash flow needs of an organization. Alternatively, optimization of help desk systems may be provided based on predictions from analysis of multiple events in an Event-driven feed-back system. Provided techniques may be generalized to other applications as well.
6. 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.
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.
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/Narayanswamy Subramanian/
Primary Examiner
Art Unit 3691
March 15, 2026