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 .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on February 10, 2026 has been entered.
This is the Non-Final Office Action in response to the Amendment filed on February 10, 2026 for Application No. 18/747,884, filed on June 19, 2024, title: “System And Method For Authorizing Temporary Use Of Accounts”.
Status of Claims
Claims 1-20 were pending. Per the 02/10/2026 Response, claims 1, 12, and 20 have been amended, and no claim has been added or cancelled. Accordingly, claims 1-20 remain pending in this application and have been examined.
Priority
This application was filed on 06/19/2024 and is a CON of US Application No. 17/583,490 filed on 01/25/2022 (Patented No. 12,039,530). For the purpose of examination, the 01/25/2022 is considered to be the effective filing date.
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.
Step 1:
Under the Step 1 analysis, the claims are reviewed to determine whether they fall within the four statutory categories of patentable subject matter (i.e., process, machine, manufacture, or combination of matter).
Claims 1-11 recite a system for authorizing temporary use of accounts, claims 12-19 recite a method of authorizing temporary use of accounts, and claim 20 recites a non-transitory computer readable medium for authorizing temporary use of accounts. Therefore, the claims recite a machine, process, and manufacture which fall within the four statutory categories of invention (Step 1-Yes, the claims are statutory).
Step 2A Prong 1:
Under the Step 2A, Prong 1 analysis, the claims are reviewed to determine whether they recite a judicial exception by identifying if the claim limitations fall in one of the enumerated abstract idea groupings (i.e., organizing human activity, mathematical concepts, and mental processes) that amount to a judicial exception to patentability.
Claim 12, A method of authorizing temporary use of accounts, the method executed by a system and comprising:
detecting selection, by an account holder, of available funds in an account associated with an endpoint for sharing with a recipient device; (mitigating risk before authorization – a fundamental economic practice)
detecting a spending limit, set by the account holder, for sharing of the available funds; (mitigating risk before authorization – a fundamental economic practice)
generating and posting a pending transaction against the account for an amount equal to the spending limit; and (mitigating risk before authorization – a fundamental economic practice)
after generating and posting the pending transaction
providing, via a secure communication channel established between an account holder device and the recipient device, a data structure to enable the recipient device to complete purchases using the available funds, wherein the account holder device comprises an associated application, and wherein the recipient device comprises an app used to coordinate application of the purchases to the pending transaction; (business relations – a commercial interaction)
detecting a purchase made by the recipient device using the shared available funds; and (business relations – a commercial interaction)
responsive to detecting the purchase, modifying details associated with the pending transaction to reflect the purchase, (business relations – a commercial interaction)
wherein the system is positioned and operable between (i) a server supporting the app and the associated application, and (ii) one or more endpoints comprising the endpoint associated with the account, thereby providing an interactive layer enabling coordination and delivery of data between the app and the endpoint associated with the account.
The above limitations (see underlined), as drafted, is a process that, under its broadest reasonable interpretation, covers a method of organizing human activity for authorizing temporary use of accounts but for the recitation of generic computer components (e.g., a computer system comprising processors and memories, a recipient device, an account holder device, a data structure (“app”), and a secure communications channel). More specifically, the claim is directed to a method of mitigating risk before authorizing temporary use of accounts to a recipient device, which is a fundamental economic practice (i.e., hedging, insurance, mitigating risk) and commercial interaction (i.e., agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations).
The claim steps such as “detecting selection … of available funds in an account for sharing with a recipient;”, “detecting a spending limit … for sharing of the available funds;”, “generating and posting a pending transaction against the account …”, “providing … a data structure to enable the recipient device to complete purchases using the available funds …;”, “detecting purchase made by the recipient device using the shared available funds;”, and “… modifying details associated with the pending transaction to reflect the purchase.” correspond to concepts of fundamental economic practice to ensure that the recipient uses the shared available funds before authorization of temporary use of accounts (mitigating risk before authorization) and commercial interaction between the account holder, the recipient, and the system (business relations).
The added amendments via the 11/05/2025 Response, such as “… by an account holder … with a recipient device”, “… set by the account holder …”, “… an amount equal to … and”, “after generating and posting the pending transaction”, “via a secure communication channel established between an account holder device and the recipient device, … complete purchases using the available funds, wherein the recipient device comprises an app used to coordinate application of the purchases to the pending transaction;”, “… made … using the shared available funds;”, and “responsive to detecting the purchase … details associated with …” all are additional details which further narrow the scope of the claim, but do not change the analysis. Further narrowing the details of an abstract idea does not change the analysis since a more narrow abstract idea does not make it any less abstract. The added amendments clarified that the claim steps are performed by an device and thus removed the claim rejection under the “Mental Process”, but the claim is still directed to the abstract of a method of organizing human activity.
The newly added amendments via the recent 02/10/2026 Response, such as “associated with an endpoint” and “wherein the account holder device comprises an associated application, and” further narrow the scope of the claim, but do not change the analysis.
If a claim limitation, under its broadest reasonable interpretation, covers performance of a fundamental economic practice and commercial interaction, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas (concepts performed to mitigate risk before authorizing temporary use of accounts). Accordingly, the claim recites an abstract idea.
Claim 1 recites a system and claim 20 recite a computer program with the comparable elements and limitations as discussed in claim 12. The mere nominal recitation of the generic computer components (e.g., a computer system comprising processors, communications module, memories, and mobile devices) do not take the claims out of the methods of organizing human activity grouping. Accordingly, these claims also recite an abstract idea (Step 2A, Prong 1-Yes, the claims recite an abstract idea).
Step 2A Prong 2:
Under the Step 2A, Prong 2 analysis, the claims are reviewed to determine whether the judicial exception (i.e., abstract idea) is integrated into a practical application. In order to make this determination, the additional element(s), or combination of elements, are analyzed to determine if the claim as a whole integrates the recited judicial exception into a practical application of that exception. A claim that integrates a judicial exception into a practical application will apply, rely on, or use the judicial exception in a manner that imposes a meaningful limit on the judicial exception, such that the claim is more than a drafting effort designed to monopolize the judicial exception.
The judicial exception is not integrated into a practical application. In particular, the claims recite the additional elements of a computer system comprising processors and memories, a recipient device, an account holder device, a data structure (“app”), and a secure communications channel. All the computer elements are recited at a high-level of generality (i.e., a generic processor performing generic computer functions of receiving/transmitting communications, processing information, querying the database) such that it amounts to no more than mere instructions to apply the exception using a generic computer component. This is substantiated by the Applicant’s Publication in paragraphs 39-64, and Figures 1-6 (see US Publication No. 2024/0338695-A1).
The newly added amendment via the recent 02/10/2026 Response such as “wherein the system is positioned and operable between (i) a server supporting the app and the associated application, and (ii) one or more endpoints comprising the endpoint associated with the account, thereby providing an interactive layer enabling coordination and delivery of data between the app and the endpoint associated with the account.” further clarifies that the system is positioned between a server supporting the app and the associated application, and the endpoints are associated with the accounts thereby providing an interactive layer. These newly added amendments provide more detailed description for the system, but do not change the analysis and do not make it any less abstract.
The limitations are merely instructions to implement the abstract idea on a computing device and require no than a generic computing platform to perform the generic computing functions including the steps of detecting, detecting, generating, posting, providing, detecting, and modifying. Each recited combination between the recited computing hardware and the recited computing functions has been considered. No non-generic or non-conventional arrangement is found. Accordingly, the 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 claims are directed to an abstract idea (Step 2A, Prong 2, the claims are not integrated into a practical application).
Step 2B:
Under the Step 2B analysis, the claims are reviewed to determine whether the claims provide an inventive concept (i.e., whether the claim(s) include additional elements, or combinations of elements, that are sufficient to amount to significantly more than the judicial exception (i.e., abstract idea).
The claims (1, 12, and 20) do not include additional elements, considered both individually and as an ordered combination, 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 using a computer to perform the detecting, detecting, generating, posting, providing, detecting, and modifying functions as claimed amounts to no more than mere instructions to apply the exception using a generic computer component. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Therefore, the independent claims are not patent eligible.
Dependent claims 2-11 and 13-19 depend on claims 1 and 12 and thus include all the limitations and features of claims 1 and 12. Therefore, the dependent claims also are directed to the same abstract idea of claims 1 and 12.
Claims 2 and 13 recite additional elements “wherein the computer executable instructions further cause the processor to: restrict the recipient device from using the data structure in response to the pending transaction resolving.” (Additional instructions to restrict the recipient device from using the data structure (see MPEP 2106.05(d)). These claims individually or in combination with others do not integrate the abstract idea into a practical application or add an inventive concept to the abstract idea).
Claims 3 and 14 recite additional elements “wherein a remote system does not accept the data structure from the recipient device to permit use of the shared available funds.” (Additional instructions for the system to not accept the data structure from the recipient device (see MPEP 2106.05(d)). These claims individually or in combination with others do not integrate the abstract idea into a practical application or add an inventive concept to the abstract idea).
Claims 4 and 15 recite additional elements “wherein the computer executable instructions further cause the system to: resolve the pending transaction in the account in response to one or more pre- determined criteria related to the spending limit being satisfied.” (Additional instructions for the system to determine and resolve the spending limits (see MPEP 2106.05(d)). These claims individually or in combination with others do not integrate the abstract idea into a practical application or add an inventive concept to the abstract idea).
Claims 5 and 16 recite additional elements “wherein the one or more pre-determined criteria comprise a time limit, and wherein the computer executable instructions further cause the system to: detect a request by the recipient device to extend a time limit criterion of the one or more pre- determined criteria; and send the request to the account holder device and provide an option to extend the time limit or deny the request.” (Additional instructions for the pre-determined criteria comprise a time limit and for the system to detect a request and send the request to the account holder (see MPEP 2106.05(d)). These claims individually or in combination with others do not integrate the abstract idea into a practical application or add an inventive concept to the abstract idea).
Claims 6 and 17 recite additional “wherein the secure communication channel is established via a proximity based electronic mechanism.” (Additional instructions for the data structure (see MPEP 2106.05(d)). These claims individually or in combination with others do not integrate the abstract idea into a practical application or add an inventive concept to the abstract idea).
Claims 7 and 18 recite additional “wherein the proximity based electronic mechanism comprises a link sent by the account holder device to the recipient device via an electronic communication channel or a near-field pairing process initiated by the account holder device or the recipient device.” (Additional instructions for the account holder to initiate communication (see MPEP 2106.05(d)). These claims individually or in combination with others do not integrate the abstract idea into a practical application or add an inventive concept to the abstract idea).
Claim 8 recites additional “wherein a user interface is provided to the account holder as an option within a mobile banking application on the account holder device to provide selections or impose one or more pre-determined criteria on the shared available funds, the mobile banking application being available via an app or a browser.” (Additional instructions for the account holder to impose the pre-determined criteria on the shared available funds (see MPEP 2106.05(d)). This claim individually or in combination with others does not integrate the abstract idea into a practical application or adds an inventive concept to the abstract idea).
Claim 9 recites additional “wherein a user interface is provided to the account holder as a standalone application having access to a mobile banking application on the account holder device to provide selections or impose one or more pre-determined criteria on the shared available funds.” (Additional instructions for the user interface as a standalone application (see MPEP 2106.05(d)). This claim individually or in combination with others does not integrate the abstract idea into a practical application or adds an inventive concept to the abstract idea).
Claim 10 recites additional “wherein the computer executable instructions further cause the system to: detect a request to transfer the data structure to a secondary recipient device; obtain approval from the account holder of the request to transfer the data structure; and enable the recipient device to transfer the data structure from the recipient device to the secondary recipient device.” (Additional instructions for the system to detect a request to transfer, obtain approval to transfer, and enable the recipient device to transfer (see MPEP 2106.05(d)). This claim individually or in combination with others does not integrate the abstract idea into a practical application or adds an inventive concept to the abstract idea).
Claims 11 and 19 recite additional “wherein the instructions cause the system to: access and use inferred data associated with the recipient device generated through at least one of machine learning, modeling, or pattern matching..” (Additional instructions for the user interface as a standalone application (see MPEP 2106.05(d)). These claims individually or in combination with others do not integrate the abstract idea into a practical application or add an inventive concept to the abstract idea).
The dependent claims do no more than providing additional detailed instructions and administrative requirements for the functional steps already recited in the independent claims. Every recited combination between the recited computing hardware and the recited computing functions has been considered. No inventive concept is found in the claims. The claims further describe the business relations of the certain method of organizing human activity (abstract idea) and do not include additional elements other than those of claims 1 and 12 to provide a practical application or significantly more than the judicial exception. Therefore, the dependent claims also are not patent eligible.
In conclusion, the focus of the claims is on the method for authorizing temporary use of accounts to another recipient for the convenience (e.g., no cash on hand) and saving activation fees (e.g., activation fees for activating a physical card). This is a “business solution” to a “business problem” and is substantiated in paragraphs 3-5 of the Applicant’s Specification:
[0003] There are situations where a person would prefer to provide a friend, family member or loved one with funds electronically rather than providing cash. For example, that person may want to send their kids shopping or to an attraction with friends or family but does not have cash on hand to give to them for the day.
[0004] In another scenario, the person may want to provide a gift using a credit card without paying the fees payable against the amount of the gift if they were to use a credit provider gift card, e.g., just to activate a physical card.
[0005] In yet another scenario, the person may want to send a family member to the store to pick up groceries but either does not have cash or does not want to attempt to guess how much cash the family member needs to cover the expected purchase.
There is no improvement to the computer hardware, the functioning of a computer, or the technical process. The claims are not directed to a new type of processor, network, or system memory, nor do they provide a method of processing data (e.g., authorizing temporary use of accounts) that improves the existing technological processes. The focus of the claims is not on improving computer-related technology, but on an independently abstract idea that uses computers as tools (i.e., for the convenience and saving activation fees). Thus, when viewed as a whole, the claims do no more than generally linking the use of the judicial exception to a particular technological environment or field of use. No inventive concept is found in the claims. Therefore, the claims do not add significantly more (i.e., an inventive concept) to the abstract idea (Step 2B-No, the claims are not significantly more).
Response to Arguments
Terminal Disclaimer
The terminal disclaimer filed on 11/05/2025 disclaiming the terminal portion of any patent granted on this application which would extend beyond the expiration date of Patent No. 12,039,530 has been reviewed and is accepted. The terminal disclaimer has been recorded.
Claim Rejections - 35 USC § 101
Applicant's arguments filed 02/10/2026 have been fully considered but they are not persuasive.
Step 2A – Prong 1:
Per pages 2-3, Applicant argues that how the features of “detecting a purchase made by the recipient device using the shared available funds; and responsive to detecting the purchase, modifying details associated with the pending transaction to reflect the purchase,” be characterized as “mitigating risk”.
Response:
The Examiner respectfully disagrees. As explained in the 101 analysis above, the claim steps, as a whole, are to ensure that the recipient uses the shared available funds before authorization of temporary use of accounts and alter the pending transaction to replicate the purchase - this is a fundamental economic practice (mitigating risk before authorization) and commercial interaction between the account holder, the recipient, and the system (business relations). Therefore, Applicant’s arguments are not persuasive.
Step 2A – Prong 2:
Per pages 4-7, Applicant cites paragraphs 25, 51, and 57 argues that the newly add amendments such as “providing a system that is positioned and operable between ….” improves the functionality of the associated system in general.
Response:
The Examiner respectfully disagrees and notes that Applicant has argued more than what is recited in the claims, for example in paragraph 25, it describes that the temp card system can: (i) create or leverage existing pending transaction mechanisms used at merchants (e.g., gas stations) to permit up to that amount to be applied to the account at the outset to effectively set the upper limit on the funds being spent; (ii) map purchases by the virtual card to the pending transaction and update details related to the pending transaction as purchases are made, e.g., to track an amount remaining to be used, and (iii) impose an expiry date or time duration or limit (in addition to a spending limit) such that if the funds are not spent within a certain amount of time or by a certain date, the virtual card expires and is removed from the application. The argued features are not recited in any of the independent claims. Therefore, Applicant’s arguments are not persuasive.
Step 2B:
Per pages 7-8, Applicant argues that the newly added amendments such as “wherein the system is positioned and operable … with the account” provide an inventive concept or are sufficient to amount to significantly more than any alleged abstract idea.
Response:
The Examiner respectfully disagrees. As explained in the 101 analysis above, the newly added amendments further clarifies that the system is positioned between a server supporting the app and the associated application, and the endpoints are associated with the accounts thereby providing an interactive layer. The newly added amendments provide more detailed description for the system, but do not change the analysis and do not make it any less abstract.
The amended independent claims do not include additional elements, considered both individually and as an ordered combination, 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 using a computer to perform the detecting, detecting, generating, posting, providing, detecting, and modifying functions as claimed amounts to no more than mere instructions to apply the exception using a generic computer component. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Therefore, the independent claims are not patent eligible.
The focus of the claims is on a method for authorizing temporary use of accounts (sharing of available funds) to another recipient device for the convenience (e.g., no cash on hand) and saving activation fees (e.g., activation fees for activating a physical card). Applicant’s claimed invention is basically an automation of a manual activity (i.e., authorizing temporary use of accounts to share the available funds). Automating manual processes speeds efficiency and increases accuracy over manual methods. Automating a manual activity which accomplished the same result is not sufficient to be patent eligible. A claim must be significant more than transform the abstract idea into patent eligible subject matter in order to make the claim patent-eligible per the supreme court in Alice. Applicant’s claimed invention is basically automating a manual process for the convenience (e.g., no cash on hand) and saving activation fees (e.g., activation fees for activating a physical card). This is a “business solution” to a “business problem” and is substantiated in paragraphs 3-5 of the Specification. Given the above reasons, generic computing components associated with a process of sharing the available funds with another recipient device is not inventive.
Therefore, Applicant’s arguments are not persuasive and the rejection of the claims under 35 USC § 101 is MAINTAINED.
Claim Rejections - 35 USC § 102/103
An updated prior art search did not identify any art(s), individually or in combination with others, that teaches each and every element of the claims at this time.
Conclusion
Claims 1-20 are rejected.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to HAI TRAN whose telephone number is (571)272-7364. The examiner can normally be reached Monday-Friday, 9-5.
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HAI TRAN
Primary Examiner
Art Unit 3695
/HAI TRAN/Primary Examiner, Art Unit 3695