DETAILED ACTION
Notice of Pre-AIA or AIA Status
1. 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 response filed January 18, 2026 in which claims 1-20 are amended. Thus, claim 1-20 are pending in the application.
Claim Rejections - 35 USC § 101
2. 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 Examiner has identified independent Claim 20 as the claim that represents the claimed invention for analysis and is similar to independent Claims 1 and 12.
The claims 1-11 are directed to a method, 12-19 are directed to a non-transitory computer readable medium and claim 20 is directed to a system which is one of the statutory categories of invention (Step 1: YES).
The claim 20 recites : a memory comprising instruction data representing a set of instructions; and a processor configured to communicate with the memory and to execute the set of instructions, wherein the set of instructions, when executed by the processor, cause the processor to: obtain from a blockchain, first transaction data for a first transaction of first funds in digital currency, wherein the first transaction data comprises aggregated input records of the first transaction and aggregated output records of the first transaction; identify, from the blockchain, a second transaction, wherein: the second transaction precedes the first transaction in the blockchain; the identifying is based on the second transaction being one of a sequence of transactions, transactions in the sequence of transactions including an input record having a previous-transaction identifier that matches an output record created by a respective prior transaction in the sequence of transactions; and the sequence of transactions includes the first transaction; obtain, from the blockchain, second transaction data for the second transaction, the second transaction data comprising aggregated input and aggregated output records associated with the second transaction; label the first transaction data according to whether the first transaction was fraudulent; and train using the labeled first transaction data and the second transaction data, a model to predict whether a received transaction is fraudulent. These limitations (with the exception of italicized portions), under their broadest reasonable interpretation, when considered collectively as an ordered combination, is a process that covers Certain methods of organizing human activity such as fundamental economic principles or practices (including insurance, mitigating risk, and hedging). Predicting whether a transaction is fraudulent is a way of mitigating a risk and mitigating a risk is a Fundamental Economic Practice. The claim also recites a blockchain, a memory and a processor which do not necessarily restrict the claim from reciting an abstract idea. That is, other than, a blockchain, a memory and a processor, nothing in the claim precludes the steps from being performed as Certain methods of organizing human activity. If the claim limitations, under the broadest reasonable interpretation, covers methods of organizing human activity but for the recitation of generic computer components, then it falls within the “Certain methods of organizing human activity” grouping of abstract ideas. Accordingly, the claim 20 recites an abstract idea (Step 2A: Prong 1: YES).
This judicial exception is not integrated into a practical application. The additional elements of a blockchain, a memory and a processor result in no more than simply applying the abstract idea using generic computer elements. The specification describes the additional elements of a blockchain, a memory and a processor to be generic computer elements (see Fig. 1, Fig. 3). Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. The additional elements of a blockchain, a memory and a processor are recited at a high level of generality and under their broadest reasonable interpretation comprises a generic computer arrangement. The presence of a generic computer arrangement is nothing more than mere instructions to implement the abstract idea on a computer (MPEP 2106.05(f)). Accordingly, these additional elements, when considered separately and as an ordered combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Hence, the claims as a whole are not integrated into a practical application. Therefore, the claim 20 is directed to an abstract idea (Step 2A - Prong 2: NO).
The claim 20 does not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements of a blockchain, a memory and a processor are recited at a high level of generality in that it results in no more than simply applying the abstract idea using generic computer elements. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements amount to no more than mere instructions to apply the exception using a generic computer component (MPEP 2106.05(f)). The additional elements, when considered separately and as an ordered combination, does not add significantly more (also known as an “inventive concept”) to the exception. The additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. Thus, claim 20 is not patent eligible (Step 2B: NO).
Similar arguments can be extended to other independent claims 1 and 12 and hence the claims 1 and 12 are rejected on similar grounds as claim 20.
Dependent claims 2-11 and 13-19 are held to be patent ineligible under 35 U.S.C. 101 because the additional recited limitations only narrow the abstract idea further and thus correspond to Certain methods of organizing human activity and hence are abstract for the reasons presented above. Claims 4, 11 and 19 recite new additional elements that are not present in independent claims 1 or 12 or 20 and require further analysis under Prong Two of Step 2A and Step 2B.
Claims 4 and 11 recite a fraudulent transaction prediction system. A fraudulent transaction prediction system, recited in the claims, is recited at a high level of generality and amounts to generic computer implementation. Hence, it does not integrate the abstract idea into a practical application or provide significantly more than the abstract idea when considered individually and as an ordered combination.
Claim 19 recites the additional element of a tree based Light Gradient Boosted Machine model. A tree based Light Gradient Boosted Machine model, recited in the claims, is recited at a high level of generality and amounts to generic computer implementation. Hence, it does not integrate the abstract idea into a practical application or provide significantly more than the abstract idea when considered individually and as an ordered combination.
Viewing the claim limitations as a combination does not add anything further than looking at the claim limitations individually. When viewed either individually, or as a combination, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea. Accordingly, claim(s) 1-20 are ineligible.
Prior art
3. Applicants’ amended claims have overcome the prior art of record and Applicants’ arguments regarding the prior art of record is persuasive; therefore the current art rejection is withdrawn.
Response to Arguments
4. Applicant's arguments filed dated 01/18/2026 have been fully considered but they are not persuasive due to the following reasons:
5. With respect to Step 2A, Prong 2, Applicant argues that (pages 14-17), “as a whole, claims 1, 12, and 20 integrate any abstract features into a practical application.”
The Examiner respectfully disagrees. The Examiner would like to point out that according to 2019 Patent Eligibility Guidelines (2019 PEG), limitations that are indicative of integration into a practical application include:
• Improvements to the functioning of a computer, or to any other technology or technical field - see MPEP 2106.05(a)
• Applying or using a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition - see Vanda Memo
• Applying the judicial exception with, or by use of, a particular machine - see MPEP 2106.05(b)
• Effecting a transformation or reduction of a particular article to a different state or thing -see MPEP 2106.05(c)
• Applying or using 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 - see MPEP 2106.05(e) and Vanda Memo
In the instant case, the judicial exception is not integrated into a practical application, because none of the above criteria is met. The amendments to the claims only further define the data being used however a specific abstract idea is still an abstract idea. The limitations of the claims do not result in computer functionality improvement or technical/technology improvement when the underlying abstract idea is implemented using technology. All the features in the Applicant’s claims can at best be considered an improvement in the abstract idea. The advantages over conventional systems are directed towards improving the abstract idea. The specification describes the additional elements of a blockchain, a memory and a processor to be generic computer elements to be generic computer elements (see Fig. 1, Fig. 3). Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. Machine learning tool is used as a tool to implement the abstract idea. 50% improvement results from using machine learning tool as a tool to improve the business process. It does not improve the machine learning model. The additional elements of a blockchain, a memory and a processor are recited at a high level of generality and under their broadest reasonable interpretation comprises a generic computer arrangement. The presence of a generic computer arrangement is nothing more than mere instructions to implement the abstract idea on a computer (MPEP 2106.05(f)). Accordingly, these additional elements, when considered separately and as an ordered combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Hence, the claims as a whole are not integrated into a practical application.
6. Applicant further states that (pages 14-15), the present case is analogous to Desjardins.
The Examiner does not see the parallel between the claims of the instant case and the claims in Desjardins. The invention in Desjardins improved the operation of the machine learning model. Hence, when considered as a whole, independent claim 1 integrated an abstract idea into a practical application. In Desjardins, “when evaluating the claim as a whole, we discern at least the following limitation of independent claim 1 that reflects the improvement: "adjust the first values of the plurality of parameters to optimize performance of the machine learning model on the second machine learning task while protecting performance of the machine learning model on the first machine learning task." We are persuaded that constitutes an improvement to how the machine learning model itself operates, and not, for example, the identified mathematical calculation.”
Unlike Desjardins, claims here are not directed to "an improvement in computer functionality" or an "improvement to how the machine learning models itself operates" that would make them patent eligible (see page 17). The improvement is to the business process of determining fraud. Hence, Desjardins is not applicable.
7. Applicant further argues that (pages 15-16) the claims are analogous to those found statutory in Enfish.
The Examiner also does not see the parallel between the claims of the instant case and those of Enfish. In Enfish, the claims describe the steps of configuring a computer memory in accordance with a self-referential table, in both method claims and system claims. The focus of the claims in Enfish is on the specific asserted improvement in computer capabilities (i.e., the self-referential table for a computer database). Specifically, the claimed invention in Enfish achieves other benefits over conventional databases, such as increased flexibility, faster search times, and smaller memory requirements. Hence the Enfish claims were not directed to an abstract idea. On the other hand, the Applicant’s claims do not involve any improvements to another technology, technical field, or improvements to the functioning of the computer itself. The invention in Enfish was a technological solution to a technological problem (using self-referential table for a computer database rather than using conventional table for a computer database). Whereas the Applicant’s invention is a business solution to a problem rooted in an abstract idea. The computer is merely a platform on which the abstract idea is implemented. Thus, Enfish is not applicable.
8. With respect to the rejection of all claims under 35 U.S.C. 101 with regards to Step 2B, (pages 16-17), Applicant states that, “they include an inventive concept under Step 2B.”
One of the guidelines issued by the Office to determine if the claims recite additional elements which are not well understood, routine or conventional and hence, amount to significantly more than an abstract idea, is the USPTO guidelines of April 19, 2018 incorporating the Berkheimer memo (Berkheimer memo, hereinafter).
According to the Berkheimer memo,
In a step 2B analysis, an additional element (or combination of elements) is not well understood, routine or conventional unless the examiner finds, and expressly supports a rejection in writing with, one or more of the following:
1. A citation to an express statement in the specification or to a statement made by an applicant during prosecution that demonstrates the well-understood, routine, conventional nature of the additional element(s).
2. A citation to one or more of the court decisions discussed in MPEP § 2106.05(d)(II) as noting the well-understood, routine, conventional nature of the additional element(s).
3. A citation to a publication that demonstrates the well-understood, routine, conventional nature of the additional element(s).
4. A statement that the examiner is taking official notice of the well-understood, routine, conventional nature of the additional elements). This option should
be used only when the examiner is certain, based upon his or her personal knowledge, that the additional elements) represents well-understood, routine, conventional activity engaged in by those in the relevant art, in that the additional elements are widely prevalent or in common use in the relevant field, comparable to the types of activity or elements that are so well-known that they do not need to be described in detail in a patent application to satisfy 35 U.S.C. § 112(a).
The claim simply applies the abstract idea using generic computer elements as a tool (see MPEP 2106.05(f)). The additional elements in the claim are a blockchain, a memory and a processor. As per the rejection above, the specification describes the additional elements of a blockchain, a memory and a processor to be generic computer elements (see Fig. 1-Fig. 3). Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. There is no indication in Applicants’ claims that any specialized hardware or other inventive computer components are required. The fact that a general purpose computing system, suitably programmed, may be used to perform the claimed method and the fact that the claims at issue do not require any nonconventional computer, network, or other components, or even a “non-conventional and non-generic arrangement of known, conventional pieces” but merely call for performance of the claimed functions “on a set of generic computer components, satisfies the Berkheimer memo requirement that the additional elements are conventional elements (as outlined in criterion 1 of the Berkheimer memo). The additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. Hence, the claims do not recite significantly more than an abstract idea.
For these reasons and those stated in the rejection above, the rejection of pending claims under 35 U.S.C. 101 is hereby maintained by the Examiner.
Examiner Request
9. The Applicant is request to indicate where in the specification there is support for amendments to claims should Applicant amend. The purpose of this is to reduce potential 35 U.S.C. §112(a) or §112 1st paragraph issues that can arise when claims are amended without support in the specification. The Examiner thanks the Applicant in advance.
Conclusion
10. 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 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 date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to BHAVIN SHAH whose telephone number is (571)272-2981. The examiner can normally be reached on M-F 9AM-6PM.
If attempts to reach the examiner by telephone are unsuccessful, the examiner's supervisor, Bennett Sigmond can be reached on 303-297-4411. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/B.D.S./Examiner, Art Unit 3694
/BENNETT M SIGMOND/Supervisory Patent Examiner, Art Unit 3694