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 communication of December 31, 2025. The rejections are stated below. Claims 1-5, 7-13, and 15-21 are pending and have been examined.
Response to Amendment/Arguments
2. Applicant’s arguments concerning 35 U.S.C. 101 have been considered but are not persuasive. Applicant contends that the amended claims recite an improvement in access control for an account. Controlling which party may transfer or withdraw funds from a prefunded account is a financial and business relationship. The claimed controlling step describes a business decision to grant a transaction processor authority to move funds while withholding that authority from the issuer. This decision does not originate from a limitation of computer hardware or software. Storing the account on a storage device is the ordinary use of a computer for data retention. Using a computer in this way does not transform a business method claim into a technical improvement. See Alice Corp. v. CLS Bank Int’l, 573 U.S. 208, 216 17 (2014). Applicant’s reliance on specification paragraphs describing a filter function does not alter this conclusion. Filtering transactions based on a cumulative limit is a financial practice. Performing that practice with a computer does not change the underlying abstract idea. The steps of determining an accumulated authorization amount, comparing it to a threshold, and generating or forgoing an authorization request are mental steps that can be carried out without a computer. Performing these steps with a processor does not make them less abstract. See CyberSource Corp. v. Retail Decisions, Inc., 654 F.3d 1366, 1372 (Fed. Cir. 2011).
3. The claimed elements do not integrate the abstract idea into a practical application. Under the Alice framework, the question is whether additional elements transform the nature of the claim. The elements identified by the applicant are the steps of the abstract idea itself, implemented on computer components. They do not reflect an improvement in computer functionality. The recited transaction processing system, storage device, and issuer system are tools through which the abstract idea is carried out. Their use does not integrate the idea into a practical application; it instructs applying the idea on a computer. That is insufficient under Alice. 573 U.S. at 223 24.
4. The claims do not recite a Bascom type inventive concept. Applicant asserts the claims have a non-conventional arrangement. In Bascom, the inventive concept was in the installation of a filtering tool at a specific location with customizable features for end users. Bascom Global Internet Servs. v. AT&T Mobility LLC, 827 F.3d 1341, 1350 (Fed. Cir. 2016). The claims here do not recite a specific location or architectural innovation. They describe a transaction processor checking a cumulative amount against a threshold, a financial control that could be placed anywhere in a network. This is not a specific discrete implementation as in Bascom. It is a description of a business rule implemented on a computer system.
5. Dependent claim 21 does not alter the eligibility analysis. Claim 21 adds steps for credential generation and validation. These are security measures used to control account access. Adding authentication to an abstract process does not provide an inventive concept. See Alice, 573 U.S. at 225 26.
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.
6. Claims 1-5, 7-13, and 15-21 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
7. Claim 1 is directed to the abstract idea of “processing transactions” which is grouped under “organizing human activity… fundamental economic practice, commercial interactions” [sales activities, business relations) in prong one of step 2A (See 2019 Revised Patent Subject Matter Eligibility Guidance).
8. Claim 1 recites “a …-implemented method comprising:
controlling a prefunded account of an issuer system by …, the prefunded account stored on a … of an account provider and containing a prefunded amount provided by the …, the controlling comprising … to transfer and/or withdraw funds and/or to cause funds to be transferred or withdrawn from the prefunded account, and the controlling comprising not enabling the … to transfer and/or withdraw funds and/or to cause funds to be transferred or withdrawn from the prefunded account;
processing, with the …, a plurality of … payment transactions initiated by a plurality of users using … issued by the … by:
sequentially receiving, with the …
and from a plurality of …, a plurality
of first transaction request messages associated with a plurality of first transactions
initiated by … issued
by the …, each first transaction of the plurality of first transactions having an
associated first transaction amount;
for each first transaction of the plurality of first transactions:
in response to receiving the first transaction request message,
determining, with the …, that
the issuer system issued a corresponding … based on transaction data contained in the first transaction request message;
determining, with the …, an accumulated authorization amount based on preceding transaction amounts of the plurality of first transactions that have been authorized and the corresponding first transaction amount;
determining, with the …, that the accumulated authorization amount does not exceed satisfy
a threshold based on the prefunded amount; and
in response to determining that the accumulated authorization
amount does not exceed the threshold, generating and communicating, with the
…, an authorization request
message associated with the corresponding first transaction to the …;
receiving, with the … and from …, a second transaction request
message associated with a second transaction initiated by a … issued by the …, the second transaction having an associated second transaction amount;
in response to receiving the second transaction request message,
determining, with the …, that
the … issued the … based on transaction data contained in the second transaction request message;
determining, with the …, an updated accumulated authorization amount based on the
accumulated authorization amount and the second transaction amount;
determining, with the …, that the updated accumulated authorization amount exceeds
the threshold; and
in response to determining that the updated accumulated
authorization amount exceeds the threshold, …, the second transaction and
forgoing generating and communicating an authorization request message associated
with the second transaction to the …”.
9. These limitations describe an abstract idea of processing transactions and corresponds to Certain Methods of Organizing Human Activity (fundamental economic principles, commercial interactions, sales activities, business relations). Accordingly, claim 1 recites an abstract idea (Step 2A: Prong 1: YES).
10. The claim also recites as additional elements such as “at least one processor of a transaction processing system, storage device, issuer system, electronic, plurality of first merchant systems, a plurality of first payment devices of the plurality of payment devices issued by the issuer system, second merchant system, second payment device, of the plurality of payment devices issued by the issuer system” which do no more than implement the abstract idea and/or provide a particular technological environment. Therefore, claim 1 recites an abstract idea without a practical application (Step 2A - Prong 2: NO).
11. Further, as the additional elements of claim 1 do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field. Thus, claim 1 is not patent eligible (Step 2B: NO).
12. Claims 9 and 17 also recite the abstract idea of idea of processing transactions and corresponds to Certain Methods of Organizing Human Activity (fundamental economic practice commercial interactions, sales activities, business relations) step one of step 2A (MPEP 2106.04). Claim 9 includes the additional elements of “a system comprising at least one processor of a transaction processing system, the at least one processor configured, issuer system, storage device, electronic, plurality of payment devices, plurality of first merchant systems, a plurality of first payment devices of the plurality of payment devices issued by the issuer system, second merchant system, second payment device, of the plurality of payment devices issued by the issuer system”. Claim 17 includes the additional elements of “a computer program product comprising at least one non-transitory computer-readable medium including program instructions that, when executed by at least one processor, cause the at least one processor of a transaction processing system, issuer system, storage device, electronic, plurality of payment devices, plurality of first merchant systems, a plurality of first payment devices of the plurality of payment devices issued by the issuer system, second merchant system, second payment device, of the plurality of payment devices issued by the issuer system”. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as they do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field.
13. Claim 2 recites “wherein the transaction processing system is configured to transfer funds from the prefunded account, but the issuer system is not configured to transfer funds from the prefunded account” which further defines the abstract idea. The claim recites “transaction processing system is configured and issuer system” as additional elements. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as they do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field.
14. Claim 3 recites “wherein the issuer system transfers additional funds to the prefunded account, the computer-implemented method further comprising: in response to the issuer system transferring the additional funds to the prefunded account, updating a balance in the prefunded account based on the additional funds” which further defines the abstract idea. The claim recites “at least one processor is further configured to execute the stored program instructions” as additional elements. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as they do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field.
15. Claim 4 recites “further comprising: receiving, by the …, a webhook notification in response to the … transferring the additional funds to the prefunded account” which further defines the abstract idea. The claim recites “transaction processing system and issuer system” as additional elements. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as they do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field.
16. Claim 5 recites “wherein the … transfers the additional funds to the prefunded account during processing of at least one of the plurality of first transactions” which further defines the abstract idea. The claim recites “issuer system” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field.
17. Claim 7 recites “further comprising: during settlement of a transaction of the plurality of first transactions, automatically transferring, by the …, at least a portion of the first transaction amount corresponding to the transaction from the prefunded account to an account of the … corresponding to the transaction” which further defines the abstract idea. The claim recites “transaction processing system and first merchant system” as additional elements. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as they do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field.
18. Claim 8 recites “wherein the automatic transfer is executed in response to a default message associated with the …” which further defines the abstract idea. The claim recites “issuer system” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field.
19. Claim 10 recites “wherein the transaction processing system is configured to transfer funds from the prefunded account, but the issuer system is not configured to transfer funds from the prefunded account” which further defines the abstract idea. The claim recites “transaction processing system is configured and issuer system” as additional elements. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as they do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field.
20. Claim 11 recites “wherein the issuer system transfers additional funds to the prefunded account, the computer-implemented method further comprising: in response to the issuer system transferring the additional funds to the prefunded account, updating a balance in the prefunded account based on the additional funds” which further defines the abstract idea. The claim recites “at least one processor is further configured to execute the stored program instructions” as additional elements. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as they do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field.
21. Claim 12 recites “the … to: receive a webhook notification in response to the … transferring the additional funds to the prefunded account” which further defines the abstract idea. The claim recites “at least one processor configured and issuer system” as additional elements. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as they do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field.
22. Claim 13 recites “wherein the … transfers the additional funds to the prefunded account during processing of at least one of the plurality of first transactions” which further defines the abstract idea. The claim recites “issuer system” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field.
23. Claim 14 recites “wherein controlling the prefunded account comprises … to transfer at least a portion of the prefunded amount from the prefunded account” which further defines the abstract idea. The claim recites “configuring the transaction processing system” as additional elements. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as they do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field.
24. Claim 15 recites “further comprising: during settlement of a transaction of the plurality of first transactions, automatically transferring, by the …, at least a portion of the first transaction amount corresponding to the transaction from the prefunded account to an account of the … corresponding to the transaction” which further defines the abstract idea. The claim recites “transaction processing system and first merchant system” as additional elements. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as they do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field.
25. Claim 16 recites “wherein the automatic transfer is executed in response to a default message associated with the …” which further defines the abstract idea. The claim recites “issuer system” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field.
26. Claim 18 recites “wherein the transaction processing system is configured to transfer funds from the prefunded account, but the issuer system is not configured to transfer funds from the prefunded account” which further defines the abstract idea. The claim recites “transaction processing system is configured and issuer system” as additional elements. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as they do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field.
27. Claim 19 recites “wherein the issuer system transfers additional funds to the prefunded account, the computer-implemented method further comprising: in response to the issuer system transferring the additional funds to the prefunded account, updating a balance in the prefunded account based on the additional funds” which further defines the abstract idea. The claim recites “at least one processor is further configured to execute the stored program instructions” as additional elements. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as they do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field.
28. Claim 20 recites “the … to: receive a webhook notification in response to the … transferring the additional funds to the prefunded account” which further defines the abstract idea. The claim recites “at least one processor configured and issuer system” as additional elements. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as they do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field.
29. Claim 21 recites “wherein controlling the prefunded account further comprises:
generating a credential for the … but not for the
issuer system; during at least one of the plurality of first transactions, receiving the
credential from the …; validating the credential; and based on the credential being validated, allowing the … to transfer funds from the prefunded account” which further defines the abstract idea. The claim recites “transaction processing system” as an additional element. The additional element does no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as it does no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, it does not improve computer functionality or improve another technology or technical field.
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 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 KEVIN T POE whose telephone number is (571)272-9789. The examiner can normally be reached on Monday-Friday 9:30am through 6pm EST.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Ryan Donlon can be reached on 571-270-3602. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/K.T.P/Examiner, Art Unit 3692 /KEVIN T POE/
/RYAN D DONLON/Supervisory Patent Examiner, Art Unit 3692 February 27, 2026