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 1, 2025. The rejections are stated below. Claims 1-9 and 11-9 and 11-20 are pending and have been examined.
Response to Amendment/Arguments
2. Applicant has amended claims 1, 5-6, 15, and 19-20. Claim 10 has been cancelled. Based on Applicant’s amendment and remarks, the rejection of claims 1-9 and 11-9 and 11-20 have been withdrawn. Applicant filed terminal disclaimer on 12/1/2025. The double patenting rejection of claims 1-9 and 11-9 and 11-20 have been withdrawn. Applicant’s arguments concerning 35 U.S.C. 101 have been considered but are not persuasive. Independent claims 1 and 15 recite a process of receiving a disbursement instruction, determining a customer’s available electronic payment channel, making a disbursement, sending a notification, monitoring acceptance, and detecting fraudulent activity based on redemption data. These steps are directed to the abstract idea of “routing funds based on customer information and monitoring transactions for fraud,” which is a fundamental economic practice long prevalent in commerce and finance. The concept of verifying a customer’s payment method, sending a notification of a transaction, and analyzing data for suspicious patterns is a method of organizing human activity that falls within the enumerated categories of abstract ideas.
3. Applicant contends that the recited steps, such as using a mobile application, sending a push notification configured for acceptance via a click or tap, including a link to disbursement details, and detecting fraud patterns, integrate the abstract idea into a practical application. Under the two-prong inquiry of Revised Step 2A, however, these additional elements, individually and in combination, do not integrate the judicial exception into a practical application. The claimed computing apparatus, memory, processor, network, client systems, mobile applications, database, push notification, and link are described at a high level of generality. They invoke standard computing and communication components to perform the abstract idea. Sending a push notification that can be clicked or tapped to accept a disbursement, and including a link to a website, are functions of mobile operating systems and web browsers. Monitoring acceptance and analyzing redemption data for fraud patterns are data aggregation and analysis steps performed by computing tools. The claim elements together instruct the practitioner to implement the abstract idea using activities in the field of electronic payments. They do not reflect a specific improvement in computer functionality or a concrete technical solution.
4. Applicant cites Example 42 of the USPTO’s Subject Matter Eligibility Examples. The Office’s examples are for illustrative guidance only. The governing legal framework is the Supreme Court’s Alice/Mayo test. Under that test, the question is whether the claim as a whole amounts to significantly more than the abstract idea itself. The inclusion of a particular type of user interface element does not transform the nature of the claim. Such interface features are part of mobile application development and do not change the underlying abstract process. Even if the claims were considered directed to an abstract idea, they do not recite additional elements that amount to significantly more than the exception. The additional elements are steps performed by computing components following practices. The claims apply these technologies to the abstract idea of disbursement and fraud monitoring. This is insufficient to transform the abstract idea into patent eligible subject matter.
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.
5. Claims 1-9 and 11-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
6. Claim 15 is directed to the abstract idea of “managing disbursements” 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).
7. Claim 15 recites “a method for managing … disbursements transferred from a business client of a financial institution to customers of the business client, the method comprising:
receiving, by …, a disbursement instruction from a … over a …, and causing the disbursement instruction to be processed by a …, the … processing the disbursement instruction to perform processes including:
analyzing, by the …, the disbursement instruction to extract customer identification information;
using, by the …, the customer identification information to determine, by accessing a customer profile in a …, when at least one available payment channel for the customer includes an … payment channel; and
making, by the …, a disbursement in accordance with the disbursement instruction using the at least one available payment channel and sending an … notification to the customer of the disbursement, the … notification being a … notification that is … to allow acceptance of the disbursement by receiving at least one from among a click, a tap on the push notification, and a return text message, and the … notification including a link to a viewing of at least one disbursement detail on a …;
monitoring, by the …, acceptance of the disbursement by the customer and notifying the business client when the disbursement expires without acceptance by the customer, obtaining redemption data, and detecting at least one pattern that corresponds to fraudulent activity based on the obtained redemption data; and
generating, by the …, at least one alert to be transmitted to the customer when a disbursement status changes to at least one from among an issued status, an accepted status, a declined status, and an expired status”.
8. These limitations (with the exception of italicized limitations) describe an abstract idea of managing disbursements and corresponds to Certain Methods of Organizing Human Activity( commercial interactions, sales activities, business relations). Accordingly, claim 15 recites an abstract idea (Step 2A: Prong 1: YES).
9. The claim also recites as additional elements such as “at least one processor, business client system, network, first mobile application, customer database, electronic, push notification that is configured, link, web site” which do no more than implement the abstract idea and/or provide a particular technological environment. Therefore, claim 15 recites an abstract idea without a practical application (Step 2A - Prong 2: NO).
10. Further, as the additional elements of claim 15 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 15 is not patent eligible (Step 2B: NO).
11. Claim 1 also recite the abstract idea of idea of managing disbursements and corresponds to Certain Methods of Organizing Human Activity (commercial interactions, sales activities, business relations) step one of step 2A (MPEP 2106.04). Claim 1 includes the additional elements of “a computing apparatus comprising a memory comprising programmed instructions stored thereon; and at least one processor coupled to the memory and configured, network, first client computing system having a mobile application, customer database, electronic, second mobile application, second client computing 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.
12. Claim 2 recites “wherein the … to receive a batch file of disbursement instructions” 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.
13. Claim 3 recites “wherein the … to receive a single disbursement instruction” 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.
14. Claim 4 recites “wherein the disbursement instruction includes a customer identifier including at least one from among an email address and a mobile phone number” which further defines the abstract idea.
15. Claim 5 recites “wherein the disbursement instruction includes a business client brand, business client account information, and a disbursement description” which further defines the abstract idea.
16. Claim 6 recites “wherein the … to select the offer by extracting information from the disbursement instruction including customer data and client data, and to access an …, select at least one offer based on the extracted information, and correlate the offer with the disbursement” which further defines the abstract idea. The claim recites “at least on processor is further configured to execute the stored programmed instructions and offer database” 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.
17. Claim 7 recites “wherein the … to generate multiple offers with a single disbursement instruction” 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.
18. Claim 8 recites “wherein … to direct the disbursement to an appropriate location” 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.
19. Claim 9 recites “wherein the location is a … account” which further defines the abstract idea. The claim recites “virtual” 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.
20. Claim 11 recites “wherein the disbursement notification includes a … explaining the disbursement” which further defines the abstract idea. The claim recites “co-branded user interface” 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.
21. Claim 12 recites “wherein the … allows selection of location for the disbursement including one of a virtual account, bank account, a prepaid card, and a credit card” which further defines the abstract idea. The claim recites “user interface” 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.
22. Claim 13 recites “wherein the … allows the customer to decline payment” which further defines the abstract idea. The claim recites “user interface” 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 the … to direct the disbursement in accordance with rules stored in the customer profile” 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.
24. Claim 16 recites “further comprising receiving a batch file of disbursement instructions” which further defines the abstract idea.
25. Claim 17 recites “further comprising receiving a single disbursement instruction” which further defines the abstract idea.
26. Claim 18 recites “wherein the disbursement instruction includes a customer identifier including at least one from among an email address and a mobile phone number” which further defines the abstract idea.
27. Claim 19 recites “wherein the disbursement instruction includes a business client brand, the business client account information, and a disbursement description” which further defines the abstract idea.
28. Claim 20 recites “wherein the selecting of the offer comprises: extracting information from the disbursement instruction including customer data and client data; accessing an; selecting the offer based on the extracted information; and correlating the offer with the disbursement” which further defines the abstract idea. The claim recites “offer database” 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.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Calvin Hewitt can be reached on 571-272-6709. 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
/RYAN D DONLON/Supervisory Patent Examiner, Art Unit 3692 March 3, 2026