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 .
Response to Amendment
Considering applicant's submission filed June 4, 2026, the Examiner has maintained and updated the 35 USC § 101.
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 1-7 and 9-21, are rejected under 35 U.S.C. 101 because the claimed invention is directed to abstract idea without significantly more. The claim(s) recite(s) the following limitations that are considered to be abstract ideas:
Claims 1, 13 and 20
using a reward listener to poll an event queue to determine when a user qualifies for a reward, wherein the event queue is populated through a reward making a call to publish an event to the event queue
obtaining reward information for a reward for a user, the reward information comprising a reward category, a credit type, and a reward value; identifying one or more regulatory frameworks applicable to the user, wherein the one or more regulatory frameworks define different limits based on the reward category, and wherein rewards categorized as risk-mitigation are exempt from at least one state-level regulatory limit that applies to rewards categorized as promotional;
determining a respective limit for each of the one or more regulatory frameworks;
accessing a central ledger that tracks, in real-time, rewards already redeemed by the user during one or more time periods, wherein the central ledger provides a single source for tracking the rewards already redeemed by the user;
determining a respective amount available within the respective amount limit for the user for each of the one or more regulatory frameworks based on the rewards already redeemed by the user during the one or more time periods;
determining in a real time compliance check whether the reward value exceeds the respective amount available for any of the one or more regulatory frameworks; and
when the reward value exceeds the respective amount available for any of the one or more regulatory frameworks, preventing redemption of the reward.
The limitations of independent claim 1, 13, and 20 as detailed above, as drafted, falls within the “Certain Methods of Organizing Human activity because the claims have concepts of commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations). The applicant’s claims (in summary) using a reward listener…, obtain reward information…, identify regulatory framer work(e.g. rules) determine limits.., accessing a ledger…, determining a respective amount…, determine if the reward values exceed…, if the value exceeds an amount…, prevent the redemption of the reward. Accordingly, the claims recite an abstract idea This judicial exception is not integrated into a practical application. In particular the claims recite the additional elements of using a API, central ledger, event queue, reward listener, processor, non-transitory computer readable media. The aforementioned additional generic computing elements perform the steps of the claims at a high level of generality (i.e. As a generic medium performing generic computer function of obtaining, identifying, accessing, determining) such that it amounts no more than mere instructions to apply the exception using a generic computer component. Accordingly, this additional element does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. 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 of API, central ledger, event queue, reward listener, processor, non-transitory computer readable media 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.
Thus, taken alone, the additional elements do not amount to significantly more than the above-identified judicial exception (the abstract idea). Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of the computer or improves any other technology. Their collective functions merely provide generic computer implementation.
Thus, taken individually and in combination, the additional elements do not amount to
significantly more than the above-identified judicial exception (the abstract idea).
The dependent claims 2-7, 10-13, 15-21 appear to merely further limit the abstract and as such, the analysis of dependent claims 2-7, 10-13, 15-21 results in the claims “reciting” an abstract idea The claims the claims do not recite additional elements that integrate the exception into a practical application the additional elements do not amount to an inventive concept (significantly more) other than the above-identified judicial exception (the abstract idea). Thus, based on the detailed analysis above, claims 1-7 and 9-21 are not patent eligible.
Potentially Allowable Subject Matter
Claims 1-7 and 9-21 would be allowable if the applicant were to be able to overcome the 35 U.S.C 101 rejection above.
The following is a statement of reasons for the indication of allowable subject matter: In regards to claims 1-7 and 9-21, the closest prior art found by the examiner is the prior art of Gomez (US 2019/0354982) which discloses, [0046] “With reference to FIG. 3, an initial consideration is whether the amount of the proposed transaction exceeds legal limits or the system's own policy limits to, and rejecting 40 the proposed transaction if the limit is exceeded. For example, if the agent is located in Great Britain and the amount of the proposed transaction exceeds 6,000 GBP, the proposed transaction will be rejected, as Great Britain law limits money transfers to amounts less than 6,000 GBP. If the proposed transaction amount is below legal and policy limits, the system 30 will check whether the remitter (and/or, in some embodiments, the beneficiary) is on any block lists before. This may involve reviewing one or more databases, such as an internal system database 36 of blocked remitters, or an external, government-operated database 58 of blocked money-transfer remitters or beneficiaries. If the proposed remitter or beneficiary is on such a block list, the proposed transaction will be rejected. However, the Examiner was unable to find prior art for the limitations of claim 1, 13, and 20 that the discloses identifying one or more regulatory frameworks applicable to the user, wherein the one or more regulatory frameworks define different limits based on the reward category, and wherein rewards categorized as risk-mitigation are exempt from at least one state-level regulatory limit that applies to rewards categorized as promotional;.” Thus claims 1-7 and 9-21, would be allowable over the prior art.
Response to Arguments
Applicant's arguments filed June 4, 2026 have been fully considered but they are not persuasive.
The applicant argues the 35 USC 101 rejection that the amended claims recite an improvement to the functioning of the computer, other technology or technical field and recite the use of the ideas in a meaningful way beyond generally linking to a particular technological environment. By stating, “The Specification describes this technical improvement over conventional approaches as follows: "the system can include a central ledger that captures and records every instance a customer earns a reward. This ledger can be a single source for tracking all regulatory limits associated with rewards. Moreover, the system can prevent the redemption of rewards that exceed the regulatory limits, thereby providing a real-time compliance check." Specification 28. The Examiner respectfully disagrees [0028] is stated in a conclusory manner without the details necessary to be apparent to a person of ordinary skill in the art that an improvement is present. The details of an unconventional technical solution are not present in the cited paragraph. See MPEP 2106.05(a) - If it is asserted that the invention improves upon conventional functioning of a computer, or upon conventional technology or technological processes, a technical explanation as to how to implement the invention should be present in the specification. That is, the disclosure must provide sufficient details such that one of ordinary skill in the art would recognize the claimed invention as providing an improvement. The specification need not explicitly set forth the improvement, but it must describe the invention such that the improvement would be apparent to one of ordinary skill in the art. Conversely, if the specification explicitly sets forth an improvement but in a conclusory manner (i.e., a bare assertion of an improvement without the detail necessary to be apparent to a person of ordinary skill in the art), the examiner should not determine the claim improves technology. An indication that the claimed invention provides an improvement can include a discussion in the specification that identifies a technical problem and explains the details of an unconventional technical solution expressed in the claim, or identifies technical improvements realized by the claim over the prior art. For example, in McRO, the court relied on the specification’s explanation of how the particular rules recited in the claim enabled the automation of specific animation tasks that previously could only be performed subjectively by humans, when determining that the claims were directed to improvements in computer animation instead of an abstract idea. McRO, 837 F.3d at 1313-14, 120 USPQ2d at 1100-01. In contrast, the court in Affinity Labs of Tex. v. DirecTV, LLC relied on the specification’s failure to provide details regarding the manner in which the invention accomplished the alleged improvement when holding the claimed methods of delivering broadcast content to cellphones ineligible. 838 F.3d 1253, 1263-64, 120 USPQ2d 1201, 1207-08 (Fed. Cir. 2016). The applicant further argues the 35 USC 101 rejection by the limitations are improvements beyond what is well understood, routine and conventional. The rejection does not rely on a finding that those limitations are well understood, routine and conventional. The office has considered the r API, central ledger, event queue, reward listener, processor, non-transitory computer readable media individually and in combination. The applicant has not identified in the claim a further limitation that changes the operation of those components or that they supply an inventive concept beyond the application of the recited abstract idea. Furthermore, Berkheimer evidence is not required, the Examiner has not asserted that any limitations are insignificant extra solution activity, nor has the Examiner stated that any limitations or additional elements are well understood, routine and conventional. Thus the Examiner is not required to provide Berkheimer evidence. (see MPEP 2106.07 states - At Step 2A Prong Two or Step 2B, there is no requirement for evidence to support a finding that the exception is not integrated into a practical application or that the additional elements do not amount to significantly more than the exception unless the examiner asserts that additional limitations are well-understood, routine, conventional activities in Step 2b")
Limitations that are indicative of integration into a practical application:
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
The claims do not appear to have any limitations that are indicative of integration into a practical application. Thus the 35 USC 101 rejection is maintained.
Conclusion
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 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 DARNELL A POUNCIL whose telephone number is (571)270-3509. The examiner can normally be reached Monday - Friday 10:00 - 6:00.
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/D.A.P/Examiner, Art Unit 3622
/ILANA L SPAR/Supervisory Patent Examiner, Art Unit 3622