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 .
Status of Claims
This action is in reply to the amended claims filed on 1/27/2026, wherein:
Claims 1-11, 13, 16, 17, 20, 22, and 35 have been amended;
Claims 12, 18, 19, 21, 23-34, and 36 have been canceled;
Claims 14 and 15 remain as original; and
Claims 1-11, 13-17, 20, 22, and 35 are currently pending and have been examined.
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 1-11, 13-17, 20, 22, and 35 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. The claims recite a method, a system, and medium for providing proof that a further transaction is linked to an initial transaction which is considered a judicial exception because it falls under Certain Methods of Organizing Human Activity such as commercial or legal interactions, including sales activities or behaviors. This judicial exception is not integrated into a practical application as discussed below and the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception as discussed below.
This rejection follows the 2019 Revised Patent Subject Matter Eligibility Guidance, 84 Fed Reg 4, January 7, 2019, pp. 50-57 (“2019 PEG”)(MPEP 2106).
Analysis
Step 1 (Statutory Categories) – 2019 PEG pg. 53 (See MPEP 2106.03)
Claims 1-11, 13-17, 20, 22, and 35 are directed to the statutory category of a process, machine, or manufacture.
Step 2A, Prong 1 (Do the claims recite an abstract idea?) – 2019 PEG pg. 54 (See MPEP 2106.04(a)-(c))
For independent claims 1, 20, 22, and 35, the claims recite an abstract idea of: providing proof that a further transaction is linked to an initial transaction. The steps of independent claim 1 recite the abstract idea (in bold below) of: A computer implemented method of using a blockchain to prove proof of an ordered sequence of events, the method performed on a computing device and comprising: receiving a blockchain transaction; applying a cryptographic hash function to the blockchain transaction to compute an identifier of the blockchain transaction; generating a further blockchain transaction to be sent to a further computing device; generating proof data associated with the further blockchain transaction that provides proof to the further computing device that the further blockchain transaction is linked to an initial blockchain transaction in a transaction chain comprising the blockchain transaction, wherein the initial blockchain transaction relates to an initial event in the ordered sequence of events, and the proof data comprises: (i) a proof; (ii) the identifier of the blockchain transaction; and (iii) a unique identifier of the initial blockchain transaction; and sending the further blockchain transaction and the proof data to the further computing device to verify that the further blockchain transaction is linked to the initial blockchain transaction in the transaction chain without sending any intervening transactions in the transaction chain between the initial blockchain transaction and the further blockchain transaction. Independent claims 20, 22, and 35 recite similar steps that recite the abstract idea. Independent claims 1, 20, 22, and 35, as drafted, are a process that, under the broadest reasonable interpretation, covers Certain Methods of Organizing Human Activity, since they recite commercial or legal interactions, including sales activities or behaviors. If the claim limitations, under the broadest reasonable interpretation, covers methods of organizing human activity but for the recitation of additional elements including generic computer components, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Other than reciting the abstract idea, the independent claims recite additional elements including generic computer components such as “computer implemented, a computing device, a further computing device, blockchain, and applying a cryptographic hash function”, and nothing in the claims precludes the steps from being performed as a method of organizing human activity. Accordingly, the independent claims recite an abstract idea.
Dependent claims 2-11, and 13-17, recite similar limitations as independent claims 1, 20, 22, and 35; and 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. Other than reciting the abstract idea, the dependent claims recite similar additional elements including generic computer components as the independent claims, such as “the computing device, a digital asset, the further computing device, a remote device, and the blockchain”. If a claim limitation, under its broadest reasonable interpretation, covers commercial or legal interactions, but for the recitation of generic computer components, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas.
Step 2A, Prong 2 (Does the claim recite additional elements that integrate the judicial exception into a practical application?) – 2019 PEG pg. 54 (See MPEP 2106.04(d)-(c))
This judicial exception is not integrated into a practical application. In particular, independent claims 1, 20, 22, and 35 only recite the additional elements of “computer implemented, a computing device, a further computing device, blockchain, and applying a cryptographic hash function”,. A plain reading of the Figures and associated descriptions in the specification reveals that generic processors may be used to execute the claimed steps. The additional elements are recited at a high level of generality (i.e., as a generic processor performing generic computer functions) such that it amounts to no more than mere instructions to apply the exception using generic computer components (See MPEP 2106.05(f)) and limits the judicial exception to a particular environment (See MPEP 2106.05(h)). Mere instructions to apply an exception using a generic computer component and limiting the judicial exception to a particular environment doesn’t integrate the abstract idea into a practical application in Step 2A. Accordingly, these additional elements do not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Hence, independent claims 1, 20, 22, and 35 are directed to an abstract idea.
Dependent claims 2-11, and 13-17, recite similar additional elements as the independent claims including generic computer components, such as “the computing device, a digital asset, the further computing device, a remote device, and the blockchain”. The judicial exception is not integrated into a practical application because the additional elements in the dependent claims are also recited at a high-level of generality such that it amounts to more no more than mere instructions to apply the exception using generic computer components. Therefore, the additional elements do not integrate the abstract idea into a practical application because they also do not impose any meaningful limits on practicing the abstract idea. Also, the claims do not affect an improvement to another technology or technical field; the claims do not amount to an improvement of the functioning of a computer system itself; the claims do not effect 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.
Step 2B (Does the claim recite additional elements that amount to significantly more than the judicial exception?) – 2019 PEG pg. 56 (See MPEP 2106.05)
Independent claims 1, 20, 22, and 35 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, the recited additional elements amount to no more than mere instructions to apply the exception using a generic computer component (See MPEP 2106.05(f)) and limits the judicial exception to the particular environment of computers (See MPEP 2106.05(h)). The additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the function of the elements when each is taken alone. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept in Step 2B.
In addition, the dependent claims 2-11, and 13-17 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, the additional elements of the dependent claims to perform the claimed limitations, amounts to no more than mere instructions to apply the exception using a generic computer component (See MPEP 2106.05(f)). Similar to the independent claims, mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Also, for the same reasoning as the independent claims, the additional elements of the limitations of the dependent claims, when considered individually and as an ordered combination, together do not offer significantly more than the sum of the functions of the elements when each is taken alone and the dependent 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.
Subject Matter Overcoming 35 USC §102/§103
Claims 1-11, 13-17, 20, 22, and 35 would be allowable if rewritten to overcome the rejections under 35 U.S.C. 101 set forth in this Office Action.
The following is an examiner’s statement of reasons for subject matter of independent claims 1, 20, 22, and 35 overcoming the prior art rejections under 35 USC §102/§103.
The closest prior art of record is US 2022116218 to Ryou et al. (hereinafter referred to as Ryou), WO 2023/19418 to Larraia (hereinafter referred to as Larraia), and US 2019/024429 to Massacci et al. (hereinafter referred to as Massacci). Allowable subject matter is indicated because none of the prior art of record, alone or in combination, appears to teach or fairly suggest or render obvious the combination set forth in independent claims 1, 20, 22, and 35. For independent claim 1, the prior art of Ryou, Larraia, and Massacci specifically do not disclose: “A computer implemented method of using a blockchain to prove proof of an ordered sequence of events, the method performed on a computing device and comprising: receiving a blockchain transaction; applying a cryptographic hash function to the blockchain transaction to compute an identifier of the blockchain transaction; generating a further blockchain transaction to be sent to a further computing device; generating proof data associated with the further blockchain transaction that provides proof to the further computing device that the further blockchain transaction is linked to an initial blockchain transaction in a transaction chain comprising the blockchain transaction, wherein the initial blockchain transaction relates to an initial event in the ordered sequence of events, and the proof data comprises: (i) a proof; (ii) the identifier of the blockchain transaction; and (iii) a unique identifier of the initial blockchain transaction; and sending the further blockchain transaction and the proof data to the further computing device to verify that the further blockchain transaction is linked to the initial blockchain transaction in the transaction chain without sending any intervening transactions in the transaction chain between the initial blockchain transaction and the further blockchain transaction”. Similar reasoning and rationale apply to the other independent claims 20, 22, and 35. Dependent claims 2-11, and 13-17 are allowable over the prior art by virtue of their dependency on an allowed claim.
Response to Arguments
Applicant’s arguments with respect to claims 1-11, 13-17, 20, 22, and 35 have been fully considered by the Examiner. Applicant’s arguments with respect to the rejection of the claims under 35 USC 101 have been fully considered by the Examiner. However, the Examiner does not find the Applicant’s arguments persuasive, and therefore the rejections of claims 1-11, 13-17, 20, 22, and 35 under 35 USC 101 are maintained.
The Applicant argues that the claims recite a specific and practical application to enable verification that a chain of blockchain transactions related to an ordered sequence of events. Applicant further argues on page 9 of their Remarks that the claimed cryptographic hashing function cannot be performed in the human mind and cannot be considered a mental process and therefore the claimed subject matter is not directed to an abstract idea. Applicant further argues on page 10 or their Remarks that the claimed limitations are indicative of a practical application under Prong 2 of Step 2A because the claimed limitations for verifying the link between the transactions without requiring any intervening transactions is a clear technical improvement over the prior art.
Examiner respectfully disagrees with Applicant’s argument that the claimed limitations do not recite any of the groupings of abstract ideas. Under Prong 1 of the 2019 PEG, the claims do fall under the abstract idea of Certain Method of Organizing Human Activity. If a claim limitation, under its broadest reasonable interpretation, covers commercial or legal interactions, including sales activities or behaviors, but for the recitation of additional elements including generic computer components, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Under the broadest reasonable interpretation, the claims recite commercial or legal interactions, including sales activities or behaviors. Verifying a transaction is a commercial or legal interaction.
Examiner respectfully disagrees with Applicant’s argument that the claimed limitations are indicative of integration into a practical application under Prong 2 of Step 2A of the PEG. Using a computer to: receive a transaction, apply a cryptographic hash, generate a further transaction and proof data that is sent to another computer to verify the transactions are linked; is nothing more than executing instructions to apply the exception to a computer. This is interpreted by the Examiner as using a computer as a tool to perform an abstract idea (See MPEP 2106.05(f)). The additional elements of “computer implemented, a computing device, a further computing device, blockchain, and applying a cryptographic hash function” are recited at a high level of generality such that it amounts to no more than mere instructions to apply the exception using generic computer components (See MPEP 2106.05(f)). There is no improvement to the claimed computer elements, or to any other technology or technical field. The only improvements identified in the specification are generic speed and efficiency improvements inherent in applying the use of a computer to any task. Therefore, the claimed limitations do not meet the criteria or considerations as indicative of integration into a practical application. Therefore, the rejections of the claims pursuant to 35 USC 101 are maintained.
Conclusion
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 nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to Paul Schwarzenberg whose telephone number is (313) 446-6611. The examiner can normally be reached on Monday-Thursday (7:30-6:30).
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/PAUL S SCHWARZENBERG/Primary Examiner, Art Unit 3695 2/25/2026