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 . This office action is in response to applicant's communication of February 4, 2026. The rejections are stated below. Claims 2-21 are pending and have been examined.
Response to Amendment/Arguments
Applicant’s arguments concerning claims 2-21 rejected under 35 U.S.C. 101 have been considered but are not persuasive The claims recite a method of allocating a funding amount to a user based on a virtual account number. This concept is a fundamental economic practice. The USPTO’s guidance, including the 2019 Revised Patent Subject Matter Eligibility Guidance, identifies that methods of organizing financial transactions and allocating funds are within the abstract idea exception. Applicant argues that the claims integrate the abstract idea into a practical application by enabling electronic wallet funding via the ACH network. Examiner disagrees as the additional elements recited in the claims, such as “routing number,” “virtual account number,” “financial transaction network,” “receiving second information,” and “determining that the funds transfer is associated with the user,” are data processing steps performed by a computer system. These elements do not change the fundamental operation of the financial transaction network. They merely apply the abstract idea using the ACH network as it existed at the time of the alleged invention.
The 2019 PEG instructs that a claim integrates a judicial exception into a practical application when the claim adds a specific limitation or combination of limitations that are not merely what is well understood or present in the prior art. Here, the use of a routing number to direct funds to a payment service provider’s financial account is a standard function of the ACH network. The use of an identifier such as a virtual account number to associate a transfer with a particular user is a standard data processing operation. The specification acknowledges that the ACH network is an existing infrastructure. Therefore, the claimed combination does not transform the abstract idea into a patent eligible application.
Applicant’s analogy to Example 42 of the 2019 PEG is not persuasive. Example 42 involved a specific technological improvement to a network based patient management system that allowed real time sharing of data regardless of input format. That example required a particular architecture of converting data into a standardized format and transmitting notifications upon update. The claims here do not recite any similar technological improvement to the ACH network or to computer functionality. They recite a result allocating funds to a user achieved through steps that are expected of a payment intermediary operating in the ACH network. The additional elements, considered individually and as an ordered combination, do not add significantly more to the abstract idea. The recited operations of “receiving a request,” “associating a virtual account number,” “providing first information,” “receiving second information,” “determining” based on a stored association, and “allocating a funding amount” are steps that a payment service provider would perform when acting as an intermediary for a funds transfer. The use of a routing number and a virtual account number are standard identifiers in electronic payment systems. The fact that the funds “remain in a financial account of the payment service provider” after allocation is a natural consequence of allocating funds without immediately transferring them out. It does not constitute an additional technological feature.
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 2-21 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea of using a virtual identifier (account number) to route a payment, which is a fundamental economic practice and a method of organizing human activity. The concepts utilizes a temporary number to mask a payee's identity and correctly allocate funds, which is a form of record-keeping and transaction routing without significantly more.
Claims 2-21 are directed to an apparatus, method, and a non-transitory computer-readable storage medium system which are one of the four statutory categories of invention (Step 1: YES).
Claim 9 recites “a method , comprising:
receiving, by a …, a request to transfer funds from an account associated with a payer to a user of a payment service provider, the request including user information associated with the user;
linking, by …, a … account number to the user of the payment service provider;
providing, to the device, first information usable to initiate a funds transfer, the
first information comprising (i) a routing number usable to route funds from the account associated with the payer to the payment service provider via a payment network and (ii) a virtual account number that is linked to the user;
receiving, by …, second information associated with the funds transfer;
determining, by …, that the funds transfer is associated with the
user based on a stored association between the virtual account number and the user; and
allocating, by …, a funding amount indicated in the second
information to the user while the funds remain in a financial account of the payment service provider”.
These limitations describe an abstract idea of using a virtual identifier (account number) to route a payment, which is a fundamental economic practice and a method of organizing human activity. Accordingly, claim 9 recites an abstract idea (Step 2A: Prong 1: YES).
The claim also recites as additional elements such as “computer system, device, virtual, payment network” which do no more than implement the abstract idea and/or provide a particular technological environment. Therefore, claim 9 recites an abstract idea without a practical application (Step 2A - Prong 2: NO).
Further, as the additional elements of claim 9 do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field. Thus, claim 9 is not patent eligible (Step 2B: NO).
Claims 2 and 15 also recite the abstract idea of idea of using a virtual identifier (account number) to route a payment, which is a fundamental economic practice and a method of organizing human activity, step one of step 2A (MPEP 2106.04). Claim 2 includes the additional elements of “system, comprising a non-transitory memory, and one or more hardware processors coupled to the non-transitory memory and configured to read instructions from the non-transitory memory to cause the system …, device, virtual, financial transaction network”. Claim 15 includes the additional elements of “a non-transitory machine-readable medium having instructions stored thereon that are executed by a computer system …, device, virtual, financial transaction network. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as they do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field.
Claim 3 recites “wherein the operations further comprise: generating the …account number for the request” which further define the abstract idea. The claim includes “virtual” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field.
Claim 4 recites “wherein the operations further comprise: selecting, from a plurality of … account numbers, … account number for the user” which further describe the abstract idea which further describe the abstract idea. The claim includes “virtual” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field.
Claim 5 recites “wherein the operations further comprise: in response to allocating the funding amount to the user, disassociating the … account number from the user” as additional elements. The claim includes “virtual” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field.
Claim 6 recites “wherein the second information indicates that the funds associated with the funds transfer have been transferred to the financial account of the payment service provider” which further describe the abstract idea.
Claim 7 recites “wherein the second information comprises the routing number, the … account number, and the funding amount” which further describe the abstract idea. The claim includes “virtual” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field.
Claim 8 recites “wherein the funds transfer is determined to be associated with the user further based on the second information and a stored association between the … account number and the user” which further describe the abstract idea. The claim includes “virtual” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field.
Claim 10 recites “ selecting, from a plurality of … account numbers, the … account number for the request” which further describe the abstract idea. The claim includes “virtual” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field.
Claim 11 recites “subsequent to allocating the funding amount to the user, unlinking the … account number from the user” which further describe the abstract idea. The claim includes “virtual” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field.
Claim 12 recites “wherein the second information indicates that the funds associated with the funds transfer have been transferred to the financial account of the payment service provider” which further describe the abstract idea.
Claim 13 recites “wherein the second information comprises the routing number, the …account number, and the funding amount” which further describe the abstract idea. The claim includes “virtual” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field.
Claim 14 recites “wherein the funds transfer is determined to be associated with the user further based on the second information a” which further describe the abstract idea. The claim includes “virtual” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field.
Claim 16 recites “wherein the operations further comprise: generating the … account number for the request” which further describe the abstract idea. The claim includes “NFC-enabled mobile device” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field.
Claim 17 recites “wherein the operations further comprise: selecting. From a plurality of … account numbers. the …account number for the payee” which further describe the abstract idea. The claim includes “virtual” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field.
Claim 18 recites “wherein the operations further comprise: subsequent to allocating the funding amount to the payee, disassociating the … account number from the payee” which further describe the abstract idea. The claim includes “virtual” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field.
Claim 19 recites “wherein the second information indicates that the funds associated with the funds transfer have been transferred to the financial account of the payment service provider” which further describe the abstract idea.
Claim 20 recites “wherein the second information comprises the routing number, the … account number, and the funding amount” which further describe the abstract idea. The claim includes “virtual” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field.
Claim 21 recites “wherein the funds transfer is determined to be associated with the payee further based on the second information” which further describe the abstract idea. The claim includes “virtual” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. And, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field.
Conclusion
THIS ACTION IS MADE FINAL. 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 KEVIN T POE whose telephone number is (571)272-9789. The examiner can normally be reached Monday-Friday 9:30am through 6pm est.
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/K.T.P/Examiner, Art Unit 3692 /KEVIN T POE/
/RYAN D DONLON/Supervisory Patent Examiner, Art Unit 3692
June 29, 2026
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