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 .
DETAILED ACTION
Status of Claims
This action is in reply to the application filed on 2nd of July 2024.
Claims 1-20 are currently pending and have been examined.
Prior Arts Search
This application is a continuation of a previously allowed patent. A new search was conducted on the broadened claims; however, no relevant prior art was identified to support rejections under §102 and §103.
Information Disclosure Statement
The Information Disclosure Statements filed 01/06/2026, 05/12/2025, 04/07/2025, 11/12/2024, 08/16/2024, and 08/02/2024 have been considered. Initialed copies of the Form 1449 are enclosed herewith.
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 abstract idea without significantly more. The claims recite abstract idea of organizing human activities. This judicial exception is not integrated into a practical application and the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Analysis
First of all, claims are directed to one or more of the following statutory categories: a process, a machine, a manufacture, and a composition of matter. For claim 1, the claim recites an abstract idea of
“…receiving a payment request from a user device for payment to an entity, wherein the payment request comprises selection of an option for payment through a third party; in response to receipt of the payment request, transmitting a customer authentication request and transaction information to a third party computing system associated with the third party, wherein the customer authentication request requests access to a payment service application programming interface (API) of the third party computing system, and wherein the customer authentication request indicates the entity as a subscriber to the payment service API; in response to authentication of the entity by the third party computing system, receiving a redirect instruction to display a login screen associated with the third party on an interface accessed by the user device; directing the user device to the login screen associated with the third party via a login API, wherein the login API is configured to provide login credentials from the user device to the third party computing system; transmitting, via an identity API, a user information request to the third party computing system; receiving the user information in response to the user information request; and registering the user with the entity using the received user information.” This is an abstract idea of a certain method of organizing human activity, since it recites a commercial or legal interactions, namely facilitating a payment. Besides reciting the abstract idea, the remaining claim limitations recite generic computer components/processes (e.g., user device, API, login screen, third party computing system). “We conclude that claim 1 is “directed to a result or effect that itself is the abstract idea and merely invoke[s] generic processes and machinery” rather than “a specific means or method that improves the relevant technology.” Smart Sys. Innovations, LLC v. Chi. Transit Authority, 873 F.3d 1364, 1371
This recited abstract idea is not integrated into a practical application. In particular, the claim only recites generic computer components/processes (e.g., user device, API, login screen, third party computing system) to receive/transmit/display data (extra-solution activities) and perform the abstract idea mentioned above. (See at least MPEP 2016.05(g): CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375 (Fed. Cir. 2011); buySafe, Inc. v. Google, Inc., 765 F.3d 1350, 1355 (Fed. Cir. 2014); OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015); Ultramercial, Inc. v. Hulu, LLC, 772 F.3D 709, 715 (Fed. Cir. 2014); Electric Power Group, LLC v. Alstom S.A., 830 F.3d 1350, 1354-55 (Fed. Cir. 2016); Intellectual Ventures I LLC v. Erie Indem. Co., 850 F.3d 1315, 1328-29 (Fed. Cir. 2017); Ameranth, 842 F.3d at 1245, 120 USPQ2d at 1857; Trading Technologies v. IBG LLC, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019)). The additional elements (e.g., user device, API, login screen, third party computing system) are recited at a high-level of generality such that they amount to no more than mere instructions to apply the exception using generic computer components or merely uses a computer as a tool to perform an abstract idea. Accordingly, these 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. Therefore, the claim is directed to an abstract idea.
The claim does not include additional elements 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 - (e.g., user device, API, login screen, third party computing system) amount to no more than mere instructions to apply the abstract idea using generic computer components or merely uses a computer as a tool to perform an abstract idea. In conclusion, merely “applying” the exception using generic computer components cannot provide an inventive concept. Therefore, the claim is not patent eligible under 35 USC 101.
Again, the insignificant extra-solution activities mentioned above were re-evaluated in step 2B. The limitations do not amount to significantly more than the abstract idea because the courts found sending/receiving/displaying of data to be well understood, routine, and conventional activities. (See at least MPEP 2016.05(g): CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375 (Fed. Cir. 2011); buySafe, Inc. v. Google, Inc., 765 F.3d 1350, 1355 (Fed. Cir. 2014); OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015); Ultramercial, Inc. v. Hulu, LLC, 772 F.3D 709, 715 (Fed. Cir. 2014); Electric Power Group, LLC v. Alstom S.A., 830 F.3d 1350, 1354-55 (Fed. Cir. 2016); Intellectual Ventures I LLC v. Erie Indem. Co., 850 F.3d 1315, 1328-29 (Fed. Cir. 2017); Ameranth, 842 F.3d at 1245, 120 USPQ2d at 1857; Trading Technologies v. IBG LLC, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019)). Thus again, claims were not patent eligible under 35 USC 101.
Similar arguments can be extended to independent claims 8 and 16.
Dependent claims 2-7, 9-15, and 17-20 have been given the full two-part analysis, analyzing the additional limitations both individually and in combination. The dependent claims when analyzed individually and in combination, are also held be patent ineligible under 35 U.S.C. 101.
For claim 2, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the payment request is received via a user interface presented on a website or mobile application of the entity, and wherein the website or the mobile application presents the user an option of providing the payment through the third party.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 3, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein registering the user with the entity using the user information comprises at least one of creating an online profile for the user with the entity and registering an account for the user with the entity.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 4, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…further comprising receiving a transaction confirmation from the third party computing system, wherein the transaction information includes at least one of an amount of the transaction, a description of the transaction, and types of accepted payment.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 5, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the transaction confirmation includes an indication of successful payment.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 6, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the login screen associated with the third party is displayed on a website or the mobile application provided by the entity as a pop-up window or as an embedded pane.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 7, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein transmitting the user information is responsive to verification of a user ID, wherein the third party comprises a financial institution, wherein the user ID comprises a financial institution identification (FIID), and wherein the method further comprises receiving the FIID for the user for registration with the entity.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 9, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the payment request is received via a user interface presented on a website or mobile application of the entity, and wherein the one or more processors are further configured, individually or collectively, to present the user an option of providing the payment through third party on the website or the mobile application.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 10, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the login screen associated with the third party is pushed from the third party computing system to the website or the mobile application of the entity via the login API.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 11, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the one or more processors are further configured, individually or collectively, to display the login screen associated with the third party on the website or the mobile application as a pop-up window or as an embedded pane.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 12, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein registering the user with the entity using the user information comprises at least one of creating an online profile for the user with the entity and registering an account for the user with the entity.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 13, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the transaction information includes at least one of an amount of the transaction, a description of the transaction, and types of accepted payment.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 14, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the transaction confirmation includes an indication of successful payment.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 15, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein transmitting the user information is responsive to verification of a user ID, wherein the third party comprises a financial institution, wherein the user ID comprises a financial institution identification (FIID), and wherein the one or more processors are further configured, individually or collectively, to receive the FIID for the user for registration with the entity.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 17, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the payment request is received via a user interface presented on a website or mobile application of the entity, and wherein the website or the mobile application provided by the entity device presents the user an option of providing the payment through the third party.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 18, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the login screen associated with the third party is displayed on the website or the mobile application provided by the entity device as a pop-up window or as an embedded pane.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 19, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein registering the user with the entity using the user information comprises at least one of creating an online profile for the user with the entity and registering an account for the user with the entity.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 20, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the transaction information includes at least one of an amount of the transaction, a description of the transaction, and types of accepted payment, and wherein the transaction confirmation includes an indication of successful payment.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to EDWARD CHANG whose telephone number is (571)270-3092. The examiner can normally be reached M - F, 9-5.
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/EDWARD CHANG/Primary Examiner, Art Unit 3696
05/14/2026
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