Prosecution Insights
Last updated: April 19, 2026
Application No. 18/739,107

SYSTEMS AND METHODS FOR BREAKING THE f+ 1 BARRIER: EXECUTING PAYMENT TRANSACTIONS IN PARALLEL WITH LESS THAN f+1 VALIDATIONS

Final Rejection §101§102
Filed
Jun 10, 2024
Examiner
ROSEN, ELIZABETH H
Art Unit
3693
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
COMMISSARIAT À L'ÉNERGIE ATOMIQUE ET AUX ÉNERGIES ALTERNATIVES
OA Round
2 (Final)
47%
Grant Probability
Moderate
3-4
OA Rounds
3y 3m
To Grant
99%
With Interview

Examiner Intelligence

Grants 47% of resolved cases
47%
Career Allow Rate
104 granted / 223 resolved
-5.4% vs TC avg
Strong +52% interview lift
Without
With
+52.1%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
52 currently pending
Career history
275
Total Applications
across all art units

Statute-Specific Performance

§101
34.0%
-6.0% vs TC avg
§103
29.8%
-10.2% vs TC avg
§102
6.3%
-33.7% vs TC avg
§112
21.2%
-18.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 223 resolved cases

Office Action

§101 §102
DETAILED ACTION Status of Application This action is a Final Rejection. This action is in response to the amendment and response filed on December 10, 2025. Claims 1-8 and 10 have been amended. Claims 1-10 are pending and rejected. The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . 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. Information Disclosure Statement The information disclosure statement (IDS) submitted on January 12, 2026 has been considered by the examiner. Response to Arguments The rejections under 35 U.S.C. 112(a) and (b) are withdrawn in light of Applicant’s amendments and pages 6-14 of Applicant’s remarks. Regarding the rejection under 35 U.S.C 101, Applicant argues that the claims “are directed to a specific improvement in the way distributed computer systems validate digital transactions in an asynchronous, Byzantine-fault-tolerant environment.” Remarks at 15. Applicant asserts that the claims recite “specific computer-network behaviors and algorithmic structures that improve the operation of distributed validator systems themselves, not mere automation of a long-standing economic practice.” Id. at 16. However, Applicant has not shown where the Specification describes a technological improvement and Applicant has not described the alleged improvement. Applicant further argues that “[t]he claimed methods do not merely say ‘use a computer’ to validate payments; they recite a particular architecture (asynchronous validator nodes subject to Byzantine faults and an adaptive adversary), a particular data flow (TID and nonce-based seed, pseudorandom selection of validators, publicly verifiable replay of the selection), and a mathematically constrained quorum system ((k1,k2) intersection and non-intersection properties, validation slack, and high-probability bounds) that collectively enable non-consensus parallel validation while provably preventing double spending and guaranteeing settlement properties for honest parties.” Remarks at 16. However, Applicant is using existing technology to implement a business process, i.e., an abstract idea. As such, the rejection under 35 U.S.C. 101 has been maintained. Claim Objections Claim 1 is objected to for the following reason: Claim 1 recites “accessing as input by at a processor of a validator-selection node of a plurality of validator computing nodes….” This claim appears to include a typographical error in the portion of the limitation that recites “by at a processor.” Appropriate correction is required. 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 1-10 are rejected under 35 U.S.C. § 101 as being directed to non-statutory subject matter because the claimed invention is directed to an abstract idea without significantly more. Step 1: Does the Claim Fall within a Statutory Category? (see MPEP 2106.03) Yes, with respect to claims 1-10, which recite a method and, therefore, are directed to the statutory class of process. Step 2A, Prong One: Is a Judicial Exception Recited? (see MPEP 2106.04(a)) The following claims identify the limitations that recite the abstract idea in regular text and that recite additional elements in bold: 1. A method for validating a digital transaction, comprising: accessing as input by at a processor of a validator-selection node of a plurality of validator computing nodes interconnected by an asynchronous message-passing network, both of a transaction identifier (TID) and a nonce, and selecting by the processor and based on the TID and the nonce, a set of validator computing nodes from among the plurality of validator computing nodes in accordance with a publicly verifiable selection rule, the selecting comprising: (i) computing, for each of the plurality of validator computing nodes, a pseudorandom value using a cryptographic function of the TID, the nonce and an identifier of the validator computing node; (ii) designating as the set of validator computing nodes those validator computing nodes whose pseudorandom values satisfy a selection predicate such that at least a threshold number T of the designated validator computing nodes are selected according to a uniform random distribution over the plurality of validator computing nodes, T being a predetermined integer threshold stored in a memory of the validator-selection node; and (iii) enabling any third party, given the TID, the nonce and identifiers of the designated validator computing nodes, to verify that the set of validator computing nodes was selected in accordance with the publicly verifiable selection rule. 2. The method of claim 1, wherein the processor selects the set of validators using a cryptographically secure hash function that is modeled as a random oracle model. 3. The method of claim 1, wherein the processor selects the set of validators using a shared source of randomness comprising a pseudorandom value generated by a verifiable random function or a distributed coin-tossing protocol and made available to the plurality of validator computing nodes. 4. The method of claim 1, further comprising: selecting, by the processor, a quorum of validators from the set of validator computing nodes for validating payment transactions associated with a shared transaction identifier (TID), the quorum having a cardinality m and being determined with respect to two parameters k1 and k2, with k1 < k2,such that: (1) at least k1 payment transactions having the shared transaction identifier TID can be validated concurrently using respective quorums selected in accordance with the selection rule of claim 1; and (2) no more than a total of k2 payment transactions having the shared transaction identifier TID can be validated. 5. The method of claim 4, wherein the quorum comprises a subset of validators selected uniformly at random from the set of validators, the subset having the cardinality m. 6. The method of claim 4, wherein the set of validators is divided into groups of validators according to a predetermined criterion and the quorum comprises, for each group, a number of validators selected uniformly at random from that group, the number for each group corresponding to a predetermined fraction of validators in that group. 7. The method of claim 5, wherein the cardinality m depends on at least one of (i) a synchrony assumption specifying synchronous or asynchronous message passing, (ii) failure assumptions specifying an upper bound ƒ on a number of faulty validators, or (iii) a power of an adversary specifying whether the adversary is adaptive or non-adaptive. 8. The method of claim 4, further comprising, for a chosen subset from the set of validators, validating payment transactions and settling the payment transactions from a payor to ensure that one or more preconditions is satisfied with probability at least 1 - ε, where ε is a negligible function of a security parameter n. 9. The method of claim 8, wherein the one or more preconditions includes a condition that a total of payments from a fund that can be settled cannot exceed the initial balance of the fund, a second condition that a validated transaction to an honest payee is guaranteed to be settled, and a third condition that a settlement of a fund of an honest payor is no less than the initial balance minus the payments made from the fund. 10. The method of claim 8, further comprising, by the chosen subset of validators, validating and settling payment transactions from partially validated funds. Yes. But for the recited additional elements as shown above in bold, the remaining limitations of the claims recite certain methods of organizing human activity. The claims are directed to validating a transaction. This type of method of organizing human activity is a fundamental economic practice because it involves processing a payment and a commercial interaction such as agreements in the form of contracts, legal obligations, sales activities or behaviors, and business relations. Thus, the claims recite an abstract idea. Step 2A, Prong Two: Is the Abstract Idea Integrated into a Practical Application? (see MPEP 2106.04(d)) No. The claims as a whole merely use a computer as a tool to perform the abstract idea. The computing components (i.e., additional elements that are in bold above) are recited at a high level of generality and are merely invoked as a tool to implement the steps. For example, only a programmed general purpose computing device is needed to implement the claimed process. Simply implementing the abstract idea on a generic computer is not a practical application of the abstract idea. Furthermore, the abstract idea is merely being linked to a particular technological environment, i.e., a blockchain or computing environment. Employing well known technology within a blockchain or computing environment to execute the abstract idea, even when limiting the use of the abstract idea to this environment, does not integrate the exception into a practical application or add significantly more. Additionally, there is no improvement to the functioning of a computer or technology. Therefore, the abstract idea is not integrated into a practical application. Step 2B: Does the Claim Provide an Inventive Concept? (see MPEP 2106.05) No. As discussed with respect to Step 2A, Prong 2, the additional elements in the claims, both individually and in combination, amount to no more than tools to perform the abstract idea. Merely performing the abstract idea using a computer cannot provide an inventive concept. Therefore, the claims do not provide an inventive concept. As such, the claims are not patent eligible. Note Regarding Prior Art The claims are not rejected under 35 U.S.C. 102 or 35 U.S.C. 103 because the claims were not found to be disclosed in or obvious in light of the prior art. Relevant Prior Art The following references are relevant to Applicant’s invention: Agrawal, U.S. Patent Application Publication Number 2019/0164153 A1. This reference teaches double spending protection (see paragraphs 0066-0069). This reference also discloses a random oracle model (see paragraph 0105). Ma et al., U.S. Patent Application Publication Number 2020/0286083 A1. This reference teaches implementing blockchain transactions. Chan et al., U.S. Patent Number 10,565,570 B2. This reference discusses preventing double spending. Diehl U.S. Patent Application Publication Number 2019/0102782 A1. This reference teaches processing a genuine instance of a digital good using blockchain. Specifically, this reference teaches a set of validators. See Figure 4, item 480. Email Communications Per MPEP 502.03, Applicant may authorize email communications by filing Form PTO/SB/439, available at https://www.uspto.gov/sites/default/files/documents/sb0439.pdf, via the USPTO patent electronic filing system. 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 extension fee 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 ELIZABETH H ROSEN whose telephone number is (571) 270-1850 and email address is elizabeth.rosen@uspto.gov. The examiner can normally be reached Monday - Friday, 10 AM ET - 7 PM ET. 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, Michael Anderson, can be reached at 571-270-0508. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /ELIZABETH H ROSEN/Primary Examiner, 3693
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Prosecution Timeline

Jun 10, 2024
Application Filed
Sep 06, 2025
Non-Final Rejection — §101, §102
Dec 10, 2025
Response Filed
Feb 07, 2026
Final Rejection — §101, §102 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

3-4
Expected OA Rounds
47%
Grant Probability
99%
With Interview (+52.1%)
3y 3m
Median Time to Grant
Moderate
PTA Risk
Based on 223 resolved cases by this examiner. Grant probability derived from career allow rate.

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