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
The examiner acknowledges applicant’s arguments in the Response dated October 21, 2025 directed to the Non-Final Office Action dated July 22, 2025. Claims 1-20 are pending in the application and subject to examination as part of this office action.
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 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
The determination of subject matter eligibility under 35 USC 101, relies on the Mayo/Alice two-step analysis.
In step 1 of the analysis, the claims are evaluated to determine whether they fall within one of the four statutory categories (i.e., process, machine, manufacture, or composition of matter). In the present case, claims 1-9 and 11 are directed to a system (i.e., a machine), claim 10 is directed to a device (i.e., a machine), and claims 12-20 are directed to a method (i.e., a process). The claims are, therefore directed to one of the four statutory categories.
Under prong 1 of step 2A, the examiner is directed to determine whether the claim recites a judicial exception. The claims are compared to groupings of subject matter that have been found by courts as abstract ideas. These groupings include
(a) Mathematical concepts—mathematical relationships, mathematical formulas or equations, mathematical calculations;
(b) 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); and
(c) Mental processes—concepts performed in the human mind (including an observation, evaluation, judgment, opinion).
Claim 1 recites (the abstract idea is underlined) a component of a gaming establishment patron management system comprising:
a support structure supported by a housing of an electronic gaming machine;
a processor operating independent from and in communication with each of an electronic gaming machine master gaming controller supported by the housing of the electronic gaming machine and a remote server of a gaming establishment credit system; and
a memory device that stores a plurality of instructions that, when executed by the processor, cause the processor to:
serially receive, from the electronic gaming machine master gaming controller and independent of any display by any display device, first slot accounting system protocol data associated with an occurrence of a handpay lockup event, wherein the occurrence of the handpay lockup event caused the electronic gaming machine master gaming controller to lock up until an award amount associated with the occurrence of the handpay lockup event is keyed off a credit meter of the electronic gaming machine,
communicate, to the remote server of the gaming establishment credit system and independent of any display by any display device, the first slot accounting system protocol data associated with the occurrence of the handpay lockup event, and
responsive to a receipt, from the remote server of the gaming establishment credit system, of second data associated with an amount of an outstanding debt owed by an identified player at the electronic gaming machine and prior to settling any of the amount of the outstanding debt owed by the identified player at the electronic gaming machine, cause a display, by an electronic gaming machine display device supported by the housing of the electronic gaming machine and independent of the electronic gaming machine master gaming controller, of an indicator associated with the outstanding debt of the identified player at the electronic gaming machine, wherein the amount is based on the occurrence of the handpay lockup event and the amount is independent of any balance displayed by the electronic gaming machine.
Claim 10 recites (the abstract idea is underlined) a device of a gaming establishment patron management system, comprising:
a support structure supported by a housing of an electronic gaming machine;
a processor operating independent from and in communication with each of an electronic gaming machine master gaming controller supported by the housing of the electronic gaming machine, a first remote server of a gaming establishment floor management system and a second remote server of a gaming establishment credit system; and
a memory device that stores a plurality of instructions that, when executed by the processor, cause the processor to:
receive, from the first remote server of the gaming establishment floor management system and independent of any display by any display device, first data associated with a handpay lockup event occurring at the electronic gaming machine which resulted in the electronic gaming machine master gaming controller to locking up until an award amount associated with the occurrence of the handpay lockup event is keyed off a credit meter of the electronic gaming machine, and
following a receipt of data associated with a communication, from the second remote server of the gaming establishment credit system to the first remote server of the gaming establishment floor management system, of second data associated with an amount of an outstanding debt owed by an identified player at the electronic gaming machine and independent of any balance displayed by the electronic gaming machine and prior to settling any of the amount of the outstanding debt owed by the identified player at the electronic gaming machine, display, by an electronic gaming machine display device supported by the housing of the electronic gaming machine and independent of the electronic gaming machine master gaming controller, information comprising a first task comprising information associated with the electronic gaming machine at which the handpay lockup event occurred.
Claim 12 recites (the abstract idea is underlined) a method of operating a component of a gaming establishment patron management system supported by a housing of an independently operating electronic gaming machine, the method comprising:
serially receiving, from an independently operating master gaming controller of the electronic gaming machine and independent of any display by any display device, first slot accounting system protocol data associated with an occurrence of a handpay lockup event associated with the electronic gaming machine that caused the master gaming controller of the electronic gaming machine to lock up until an award amount associated with the occurrence of the handpay lockup event is keyed off a credit meter of the electronic gaming machine,
communicating, to an independently operating remote server of a gaming establishment credit system and independent of any display by any display device, the first slot accounting system protocol data associated with the occurrence of the handpay lockup event, and responsive to a receipt, from the remote server, of second data associated with an amount of an outstanding debt owed by an identified player at the electronic gaming machine and prior to settling any of the amount of the outstanding debt owed by the identified player at the electronic gaming machine, displaying, by a display device of the electronic gaming machine and independent of the master gaming controller of the electronic gaming machine, an indicator associated with the outstanding debt of the identified player at the electronic gaming machine, wherein the amount is based on the occurrence of the handpay lockup event and the amount is independent of any balance displayed by the electronic gaming machine.
According to the specification:
In various embodiments, the systems and methods of the present disclosure operate to monitor for a debt settlement event and, responsive to an occurrence of such an event, cause an alert to be provided to gaming establishment personnel to pay off part or all of an amount of debt owed. (Specification [0002])
Under the broadest reasonable interpretation, these limitations fall into the 'certain methods of human activity' grouping of abstract ideas, because management of debt is a fundamental economic practice. Furthermore, debt is a commercial or legal interaction between parties for legal obligations. Thus, the claim is directed to an abstract idea.
Under prong 2 of Step 2A, the examiner considers whether additional elements integrate the abstract idea into a practical application. To do so, the examiner looks to the following exemplary considerations, looking at the elements individually and in combination:
• an additional element reflects an improvement in the functioning of a computer, or an improvement to other technology or technical field;
• an additional element that applies or uses a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition (not considered relevant to the present claims);
• an additional element implements a judicial exception with, or uses a judicial exception in conjunction with, a particular machine or manufacture that is integral to the claim;
• an additional element effects a transformation or reduction of a particular article to a different state or thing; and
• an additional element applies or uses 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.
The additional elements in the present claims are a support structure, a housing, an electronic gaming machine, a processor, an electronic gaming machine master controller, a remote server, a gaming establishment credit system, a memory device, any display device, an electronic gaming machine display device, a display device, a gaming establishment personnel mobile device, a gaming establishment patron management system, and an independently operating master gaming controller. The additional elements do no integrate the judicial exception into a practical application. In particular, the additional elements do not reflect an improvement in the functioning of a computer, or an improvement to other technology or technical field. The additional elements do not implement a judicial exception with, or uses a judicial exception in conjunction with, a particular machine or manufacture that is integral to the claim. The additional elements do not effect a transformation or reduction of a particular article to a different state or thing. The additional elements do not apply or use the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment. Accordingly, the additional elements do not integrate the abstract idea into a practical application because they does not impose any meaningful limits on practicing the abstract idea.
Under step 2B, the examiner evaluates whether the additional elements amount to significantly more than the judicial exception itself. The examiner considers if 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; 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.
The present claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. The additional elements are well-understood, routine, and conventional as shown:
a support structure, a housing (Baerlocher, US 7,846,018 B2, a support structure, housing or cabinet which provides support for a plurality of displays, inputs, controls and other features of a conventional gaming machine [C9:27-37]);
an electronic gaming machine (Vancura, US 2001/0038178 A1, the operation and design of gaming machines of chance are well known and the present invention can be adapted to operate with any conventional gaming machine; the provision of a bonus symbol 80 on the payline 90 is also conventional and it is well known that slot machines 10 can have a bonus condition randomly appear which results in a player having the opportunity to play a bonus game [0061]);
a processor, an electronic gaming machine master controller, a memory device, an electronic gaming machine display device, any display device, a display device, an independently operating master gaming controller (Bradford et al., US 6,612,928 B1, game device 100 includes the normal and well known internals needed in order to have a functioning game, such as at least one central processor, associated memory, input/output interfaces, peripheral interfaces to the video display, control buttons and lever, monetary input devices, slot machine interface board (SMIB), together with the firmware and software needed to implement the full functionality of the game [C8:7-21]);
a remote server, a gaming establishment personnel mobile device (Qureshi et al., US 2011/0145063 A1, examples of well known computing systems, environments, and/or configurations that may be suitable for use with aspects of the invention include, but are not limited to, mobile computing devices, personal computers, server computers, hand-held or laptop devices, multiprocessor systems, gaming consoles, microprocessor-based systems, set top boxes, programmable consumer electronics, mobile telephones, network PCs, minicomputers, mainframe computers, distributed computing environments that include any of the above systems or devices, and the like [0046]); and
a gaming establishment credit system, a gaming establishment patron management system, (Richards et al., US 2013/0310151 A1, the casino preferably utilizes the player identity and collateral information to determine whether to issue the PCAI; in one embodiment, the system server 40 may create a player account and associate a player's information with that account; such an account may be the same as, or be linked to, a player reward/tracking account which is associated with a casino's player loyalty program (such programs are well known in the art) [0078]).
Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept.
As a result, claims 1-20 are not directed to patent eligible subject matter.
Prior Art Rejections
There are currently no prior art rejections against claims 1-20.
Response to Arguments
Applicant's arguments filed October 21, 2025 have been fully considered but they are not persuasive.
Applicant argues that the components of the gaming establishment patron management system qualifies as a particular machine (Response [p. 10]). The examiner disagrees.
The components of the gaming establishment patron management system appear to be nothing more than creatively named generic computer components that carry out the abstract idea. Furthermore, all of the additional elements recited in the claims are well-understood, routine, or conventional.
Applicant also states that the gaming establishment patron management system achieves various previously unavailable technological improvements by interfacing with a remote server of a gaming establishment credit system and an electronic gaming machine master gaming controller when the electronic gaming machine is otherwise locked up (i.e., when the electronic gaming machine is in a holding state and unable to enable another play of a game) and would not otherwise communicate with each other, the component of the gaming establishment patron management system integrates the alleged judicial exception into a practical application (Response [p. 10]). Merely adding a generic computer, generic computer components, or a programmed computer to perform generic computer functions does not automatically overcome an eligibility rejection. Alice Corp. Pty. Ltd. v. CLS Bank Int'l, 573 U.S. 208, 224, 110 USPQ2d 1976, 1984 (2014). See also OIP Techs. v. Amazon.com, 788 F.3d 1359, 1364, 115 USPQ2d 1090, 1093-94 (Fed. Cir. 2015) ("Just as Diehr could not save the claims in Alice, which were directed to ‘implement[ing] the abstract idea of intermediated settlement on a generic computer’, it cannot save OIP's claims directed to implementing the abstract idea of price optimization on a generic computer.") (citations omitted).
The examiner maintains that the present claims are not directed to patent eligible subject matter under 35 USC 101.
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 WERNER G GARNER whose telephone number is (571)270-7147. The examiner can normally be reached M-F 7:30-15:30 EST.
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.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, DAVID LEWIS can be reached at (571) 272-7673. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/WERNER G GARNER/Primary Examiner, Art Unit 3715