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 .
Claim Status
The claims filed 10/30/2025 are examined herein
Claims 1-3, 5-11, and 13-20 are pending.
Claims 1, 9, and 17 are independent.
Claims 1, 5-9, and 13-20 are currently amended.
Claims 2-3 and 10-11 are original.
Claims 4 and 12 are canceled.
Response to Arguments
Applicant's arguments filed 10/30/2025 have been fully considered but they are not fully persuasive.
35 U.S.C. 101
Applicant’s arguments regarding the rejection of claims 1-3, 5-11, and 13-20 as being directed to an abstract idea without significantly more have been considered but are not persuasive.
Applicant argues that the pending claims address a technical problem, through a technical solution, in which a “training mode” is provided to generate bound pairs of initiator parties and vendors parties, based on historical transaction data (see Remarks, pg. 9).
The argument is not persuasive. It is important to keep in mind that an improvement in the abstract idea itself (e.g. a recited fundamental economic concept) is not an improvement in technology. For example, in Trading Technologies Int’l v. IBG, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019), the court determined that the claimed user interface simply provided a trader with more information to facilitate market trades, which improved the business process of market trading but did not improve computers or technology. With regards to representative claim 1, the amended limitations drawn to maintaining bound pairs of initiator parties and vendor parties based on historical transaction data is not a technical improvement but an improvement to the abstract idea itself. The limitations drawn to using this data for matching and providing data indicating the match also fall under the abstract idea. The additional element of generating the pairs using a platform computing device and storing the bound pairs in a data structure are merely reciting the words “apply it” (or an equivalent) with the judicial exception, or merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea, as discussed in MPEP § 2106.05(f). These additional elements are described at a high level of generality in a manner which does not convey a technical improvement to one of ordinary skill in the art. As such, they do not provide integration into a practical application under Step 2A Prong 2 of the subject matter eligibility framework, nor do they provide an inventive concept under Step 2B.
Applicant argues that the claimed inventions provides for cross-domain assurance in connection with pre-authorized transactions and expands processing networks functionality by enabling it do something it could not do before (see Remarks, pg. 9).
The argument is not persuasive. The receipt of an authorization request with an indicator of initiator/vendor pair confidence, or mere indicator, which conveys a historical relationship or affiliation of the parties of the pair also falls under the abstract idea. As described above, an improvement in the abstract idea itself (e.g. a recited fundamental economic concept) is not an improvement in technology.
Applicant further argues that it is clear that the claims are not directed to any essential element of an economic function because the term “fundamental” evokes foundational, or a common or persistent component of something or “essential structure, function, or fact” (see Remarks, pp. 9-10).
The argument is not persuasive. The term “fundamental” in “fundamental economic principles” does not necessarily mean old and well known. The courts have used the phrases “fundamental economic practices” or “fundamental economic principles” to describe concepts relating to the economy and commerce. Here, not only does representative claim 1 set forth or describe receiving, processing, and forwarding transaction requests, but it also sets forth mitigating risk through matching and providing an indicator of matches between entities in a transaction.
Applicant further argues that the claims certainly integrate the alleged idea into a practical application because they improve the functioning of the computer. Applicant argues that the pending claims impose functionality to learn and then to apply a cross-domain identification technique where bound pairs of parties demonstrate a confidence in the transaction, which is a new and useful function similar to that in McRO. Applicant further argues that a claim’s compatibility with conventional computers does not render it abstract, but can provide a technical improvement through performance of specific, unique limitations.
The argument is not persuasive. Providing matched data indicators to an issuer improves the quality of fraud or risk decision, not the functioning of the computer network. The system merely adds business information derived from historical transaction relationships to a request message sent to an issuer. As discussed above, this is an improvement to the abstract idea, not a technical improvement to computer or network technology itself. Furthermore, 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 a computer or improves any other technology. Their collective functions merely provide generic computer implementation of the abstract idea.
35 U.S.C. 103
The prior rejection of claims 1-3, 5-11, and 13-20 under 35 U.S.C. 103 are withdrawn in view of the current amendments.
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 1-3, 5-11, and 13-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Step 1
Claims 1-3, 5-11, and 13-20 are directed to a method, system, or non-transitory computer product, and thus fall within the statutory categories of invention. (Step 1: YES).
Step 2A - Prong 1
The Examiner has identified independent method claim 1 as the claim that represents the claimed invention for analysis and is similar to independent system claim 9 and product claim 17. Claim 1 recites the limitations of:
1. A computer-implemented method for use in connection with network transactions, the method comprising:
as part of a training mode, generating, by a platform computing device, bound pairs of initiator parties and vendor parties, based on historical transaction data, each bound pair including one of the initiator parties and one of the vendor parties, the initiator parties specific to pre-authorization requests included in the historical transaction data and the vendor parties specific to authorization requests included in the historical transaction data; and
store the bound pairs in a data structure; and then
receiving, by the platform computing device, an authorization request for a transaction to an account, the authorization request including data specific to a first vendor party;
matching, by the platform computing device, the authorization request to a pre-authorization request, the pre-authorization request including a first initiator party;
matching, by the platform computing device, the first initiator party and the first vendor party, as a pair, to one of the bound pairs of initiator parties and vendor in the data structure;
appending, by the platform computing device, to the authorization request, an indicator of the match between the first initiator party and the first vendor party, and the one of the bound pairs in the data structure; and
forwarding the authorization request with the indicator to an issuer associated with the account.
These limitations, under their broadest reasonable interpretation, cover performance of the limitation as “Certain Methods of Organizing Human Activity”. The claim limitations delineated in bold above recite a fundamental economic practice, as they pertain to receiving, processing, and forwarding, transaction requests. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation as a fundamental economic practice, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea. The platform computing device in claim 1 is just applying generic computer components to the recited abstract limitations. The recitation of generic computer components in a claim does not necessarily preclude that claim from reciting an abstract idea. Claims 9 and 17 are also abstract for similar reasons. (Step 2A-Prong 1: YES. The claims recite an abstract idea)
Step 2A - Prong 2
This judicial exception is not integrated into a practical application. In particular, the independent claims recite the additional elements of:
Claim 1: platform computing device
Claim 9: processing network computing device
Claim 17: non-transitory computer readable storage medium
The computer hardware/software is/are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function) such that it amounts no more than mere instructions to apply the exception using a generic computer component. 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 and are at a high level of generality. Therefore, claims 1, 9, and 17 are directed to an abstract idea without a practical application. (Step 2A-Prong 2: NO. The additional claimed elements are not integrated into a practical application)
Step 2B
The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when considered separately and as an ordered combination, they do not add significantly more (also known as an “inventive concept”) to the exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional element of using a computer hardware 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. See Applicant’s specification para. 0076-0078 about implementation using general purpose or special purpose computing devices and MPEP 2106.05(f) where applying a computer as a tool is not indicative of significantly more. Accordingly, these additional elements, do not change the outcome of the analysis, when considered separately and as an ordered combination. Thus, claims 1, 9, and 17 are not patent eligible. (Step 2B: NO. The claims do not provide significantly more)
Dependent Claims
Dependent claims 2-3, 5-8, 10-11, 13-16, and 18-20 further define the abstract idea that is present in their respective independent claims 1, 9, and 17, and thus correspond to “Certain Methods of Organizing Human Activity” and hence are abstract for the reasons presented above. The dependent claims do not include any additional elements that integrate the abstract idea into a practical application or are sufficient to amount to significantly more than the judicial exception when considered both individually and as an ordered combination. Therefore, the dependent claims are directed to an abstract idea without significantly more.
Thus, claims 1-3, 5-11, and 13-20 are not patent-eligible.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Izenson (US 10,304,056 B1) discloses a system for identifying and associating merchant attributes data of a merchant with transaction data may be integrated with existing payment processing systems to provide for detailed merchant attributes data (e.g., merchant name, merchant ownership data, and merchant address data). The system may receive and modify merchant attributes data retrieved from an external source (e.g., an acquirer computer or third party to a transaction) and store the merchant attributes data in a database. The merchant attributes data may be retrieved and correlated with transaction data and provided to entities (e.g., issuer computers) involved with the transaction for authorization decisioning, fraud analysis, and data analytics.
Groarke (US 2018/0025354 A1) discloses a data mapping (DM) computing device including a processor and a memory in communication with the processor is provided. The processor receives a plurality of validated data messages associated with a plurality of transactions through a first communication channel and receives a non-validated data message associated with a first transaction through a second communication channel. Each validated data message includes a plurality of validated data elements with a validated merchant identifier. The non-validated data message includes a plurality of non-validated data elements with a non-validated merchant identifier. The processor further compares the validated data messages and the non-validated data message, identifies a validated data message that is associated with the first transaction based on the comparison, maps the non-validated merchant identifier and the validated merchant identifier of the identified validated message, and stores the mapped merchant identifiers in a linked identifier table within the memory.
Dubey (US 2023/0047717 A1) discloses methods and systems for merchant data cleansing in payment network. Method performed by server system includes accessing electronic payment transaction records from transaction database. Each electronic payment transaction record includes merchant data fields. Method includes determining set of electronic payment transaction records with ambiguous merchant data fields having matching probability scores less than predetermined threshold value computed by probabilistic matching model and identifying at least one issue for non-matching of each of set of electronic payment transaction records. Method includes determining data model based on at least one issue of each of set of electronic payment transaction records. Data model is one of: phone-to-city model, payment aggregator model, and merchant name normalization model. Method includes updating set of electronic payment transaction records with unambiguous merchant data fields corresponding to ambiguous merchant data fields by applying data model to each of set of electronic payment transaction records.
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 ERIC T WONG whose telephone number is (571)270-3405. The examiner can normally be reached 9am.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Michael W Anderson can be reached at 571-270-0508. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/ERIC T WONG/Primary Examiner, Art Unit 3693
ERIC WONG
Primary Examiner
Art Unit 3693