DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application is being examined under the pre-AIA first to invent provisions.
Response to Arguments
Applicant's arguments filed 5/20/2026 have been fully considered but they are not persuasive.
Arguments and Responses to the 35 USC 101 rejection:
Applicant’s representative argues the claims are not directed to an abstract idea. Applicant’s representative further states “that the claims, at least as amended, are not directed to a certain method of organizing human activity. Instead, claim 1 relates to a technical solution by reciting, in part, "generating a displayable and scannable transaction code, the transaction code embedding a transaction identification number unique to the transaction and a location…., and "transferring the transaction amount from the account of the user to the third party based on authenticating the user using the authentication information and receiving a verification response to the verification request."
In response, it has been clearly enumerated that claims directed to an abstract idea are patent-ineligible. Abstract ideas are characterized as concepts identified by the courts which include (1) mathematical concepts, (2) mental processes and (3) certain methods of organizing human activity.
Among those concepts performed as being identified in the category of “Certain Methods of Organizing Human Activity” are “commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations).
Here, the claimed concept still falls into the category of functions of organizing human activities such as managing commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations).
The BRI of the claimed limitations describe functions of:
generating a displayable and scannable transaction code, the transaction code embedding a transaction identification number unique to the transaction and a location of one of the user or the third party, receiving a transfer request to transfer funds from the account of the user to the third party, and generating a verification request to confirm the information related to the transaction.
Claim 1 does not even recite the functions are being performed by a computer or processor or computerized system. Claim 7 recites using a mobile device performing the claimed invention. The use of a generic computer technology (such as a generic mobile device) for generating and receiving data or information, and providing the data to a computing system by transferring data, does not recite an improvement to a particular computer technology. See, e.g., McRO, Inc. v. Bandai Namco Games Am. Inc., 837 F .3 d 1299, 1314-1315 (Fed. Cir. 2016) ( finding claims not abstract because they "focused on a specific asserted improvement in computer animation").
As such, claims 1 and 7 recite generating and receiving data or information, and transferring data as these functions are not a technological implementation or improvement of a technological field. Applicant is to be reminded that a system, apparatus, machine or method for performing business, however, novel, useful, or commercially successful, is not patentable apart from the means for making the system practically useful or carrying it out. The applicant is making use of generic devices to finally transfer data or funds to a third party.
Accordingly, the additional elements (such as a generic mobile device and a computing system) do not improve (1) the processor or database and user interface, or (2) another technology or technical field. See Guidance, 84 Fed. Reg. at 55 (citing MPEP § 2106.05(a)). Rather, the above-noted additional elements merely (1) apply the abstract idea on a computer; (2) include instructions to implement the abstract idea on a computer (computing device or system) ; or (3) use the computer as a tool to perform the abstract idea. See Guidance, 84 Fed. Reg. at 55 (citing MPEP § 2106.05. Therefore, the recited additional elements do not integrate the abstract idea into a practical application when reading the claims.
None of the steps, functions and/or elements recited in the claims provide, and nowhere in the applicant’s shows any description or explanation as to how the claimed device or mobile device are intended to provide: (1) a “solution . . . necessarily rooted in computer technology in order to overcome a problem specifically arising in the realm of computer networks,” as explained by the Federal Circuit in DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d 1245, 1257 (Fed. Cir. 2014); (2) “a specific improvement to the way computers operate,” as explained in Enfish, 822 F.3d at 1336; or (3) an “unconventional technological solution ... to a technological problem” that “improve[s] the performance of the system itself,” as explained in Amdocs (Israel) Ltd. v. Openet Telecom, Inc., 841 F.3d 1288, 1299-1300 (Fed. Cir. 2016).
The claims "do[es] not improve the functioning of the computing system or mobile device or make it operate more efficiently, or solve any technological problem." Trading Techs. Int'l, Inc. V. IBG LLC, 921 F.3d 1084, 1093 (Fed. Cir. 2019). "Nothing in the claim[s], understood in light of the specification, calls for anything but preexisting computers and displays, programmed using techniques known to skilled artisans, to present the new arrangement of information." Brumfield V. IBG LLC, 97 F Ath 854, 868 (Fed. Cir. 2024). The claims also do not show a technical improvement in the architecture of a processor using a computing logic of the computing system or the mobile device. The recited functions involve generic or conventional functions and setup of a basic mobile device or computer system.
Each claim as a whole, does not amount to significantly more than the abstract idea itself. This is because the claim does not effect an improvement to another technology or technical field; the claim does not amount to an improvement to the functioning of a computer itself; and the claim does not move beyond a general link of the use of an abstract idea to a particular technological environment.
Accordingly, claims 1-2 and 5-11 are directed to an abstract idea.
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 1-2 and 5-11 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
Subject Matter Eligibility Standard
When considering subject matter eligibility under 35 U.S.C. 101, it must be determined whether the claim is directed to one of the four statutory categories of invention, i.e., process, machine, manufacture, or composition of matter.
Specifically, claims 1 and 7 are directed to a method. Each of the claims falls under one of the four statutory classes of invention.
If the claim does fall within one of the statutory categories, it must then be determined whether the claim is directed to a judicial exception (i.e., law of nature, natural phenomenon, and abstract idea).
The claims, when the bolded limitations are removed, recite the following abstract concept.
Claim 1 recites:
A computer-implemented method comprising:
receiving a request for a transaction between a user and a third party;
generating a displayable and scannable transaction code, the transaction code embedding a transaction identification number unique to the transaction and a location of one of the user or the third party;
sending the transaction code to one of the user or the third party for the other of the user and the third party to scan to request a transfer of funds from an account of the user to the third party;
receiving a transfer request to transfer funds from the account of the user to the third party, the transfer request including the transaction code and information related to the transaction including a transaction amount for transferring to the third party, wherein the transaction code is amended to include authentication information associated with the user;
generating a verification request to confirm the information related to the transaction, and
transferring the transaction amount from the account of the user to the third party based on authenticating the user using the authentication information and receiving a verification response to the verification request.
Claim 2 recites: wherein the transfer request including the information related to the transaction including the transaction amount is received from the third party.
Claim 5 recites: determining a second location of the user; and determining that the second location is within a predetermined distance of the location, wherein transferring funds in the transaction amount to the third party is based on the determination that the second location is within the predetermined distance of the location.
Claim 6 recites denying the transfer request if a difference between a time provided in the transfer request and a timestamp embedded in the transaction code exceeds a predetermined time limit.
Claim 7 recites:
generating, by a client application running on a mobile device of a user, a selectable option to initiate a payment transaction;
receiving, by the client application, a user request to initiate a payment transaction; generating, by the client application, a transaction request input screen;
receiving, by the transaction request input screen of the client application, an input indicating a payee;
generating, by the client application, a transaction code unique to the payment transaction, the transaction code based on the payee;
providing, by the client application, the transaction code to the user; and
facilitating, by the client application, a transfer of funds from a user account associated with the client application to the payee in response to receiving a disbursement request containing the transaction code from the payee, wherein the transfer is facilitated based on authenticating the transaction code contained in the disbursement request.
Claim 8 recites: generating, by the client application, a machine readable code that embeds the transaction code.
Claim 9 recites: providing, by the client application and upon completion of the transfer of funds to the payee, a confirmation of the completed transfer to the user.
Claim 10 recites: providing, by the client application and prior to transferring funds to the payee, a current account balance of the user account associated with the client application to the user.
Claim 11 recites: wherein the input provided via the transaction request input screen comprises one of a phone number or an email address associated with the payee.
Applicant is to be noted that:
The steps of “receiving” involve a data gathering function.,
the steps or functions of “generating” involve generic computer functions and/or mental processes.
The steps of “sending” involve an insignificant post solution activity.
Here, the claimed concept falls into the category of functions of organizing human activities such as managing commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations).
The BRI of the claimed limitations describe functions of:
generating a displayable and scannable transaction code, the transaction code embedding a transaction identification number unique to the transaction and a location of one of the user or the third party, receiving a transfer request to transfer funds from the account of the user to the third party, and generating a verification request to confirm the information related to the transaction.
Step 2A, Prong Two: The judicial exception is not integrated into a practical application, In particular, the clams recite the bolded limitations noted above as understood to be the additional limitations:
The claimed “mobile device” of claim 7 is similarly understood in light of applicant's specification as mere usage of any arrangement of computer software or hardware intermediate components potentially using networks to communicate with instructions are properly understood to be mere instructions to apply the abstraction using a computer or device or computer system.
Performing steps or functions by a mobile or a computing system merely limit the abstraction to a computer field by execution by generic computers. See MPEP 2106.05.
As noted in MPEP 2106.04(d), limitations which amount to instructions to implement an abstract idea on a computer or merely using a computer as a tool, limitations which amount to
insignificant extra-solution activity, and limitations which amount to generally linking to a particular technological environment do not integrate a practical exception into a practical application.
The receiving, generating, providing and transferring functions are similar to Alappat, which as noted in MPEP 2106. 05(b)(1) is superseded, and the correct analysis is to look whether the added elements integrate the exception into a practical application or provide significantly more than the judicial exception. The functions of the claims in the instant application are performed by one or more processors or computing system which receive, generate, determine and transfer data or funds.
Consideration of these steps as a combination does not change the analysis as they do not add anything compared to when the steps or functions are considered separately. The claims recite a particular sequence of functions of finally facilitating a transfer of fund from a user account to a payee in response to receiving a disbursement request containing a transaction code from the payee.
Performance of these steps or functions technologically may present a meaningful limit to the scope of the claim does not reasonably integrate the abstraction into a practical application.
Step 2B: The elements discussed above with respect to the practical application in Step 2A, prong 2 are equally applicable to consideration of whether the claims amount to significantly more. Accordingly, the clams fail to recite additional elements which, when considered individually and in combination, amount to significantly more. Reconsideration of these elements identified as insignificant extra-solution activity as part of Step 2B does not change the analysis.
Claims 1-2 and 5-6 do not recite any additional elements.
Receiving, generating, providing and transferring data by electronic means or hardware amount to receiving data over a network has been recognized by the courts as routine, and conventional (See MPEP 2106.05(d)UD, citing Symantec, 835 F.3d at 1321, 120 OSPQ2d at 1362 (Utilizing an intermediary computer to forward information); TL Communications LEC v. AV Auto. LLC, 823 F.3d 607, G10, L18 USPO2d 1744, 1748 (ed. Cir. 2016) Casing a telephone for image transmission); OFF Techs., fac. v. Amazon.com, fic., 788 B.Ad 1359, 1363, Lis USPO2d 1090, 1093 (ed, Cir. 2015) (sending messages over a network}, buySAFE, fic. v. Google, Inc.. 768 F.3d 1350, 1355, 112 USPQ2d 1093, 1996 (Pod, Cyr. 2014) (computer receives and sends information over a network).
Positively reciting a “mobile device” as noted in claim 7, does not change the analysis as these aspects are properly considered as additional elements which amount to instructions to apply it with a computer.
These claimed elements also as found in the dependent claims are also recited at a high level of generality such that they amount to no more than mere instructions to apply the exception using a generic component.
In processing the claims, it is noted that the recitation of the additional elements does not impact the analysis of the claims because this element in combination is noted only to be a general purpose computer for performing basic or routine computer functions. The claimed mobile device is noted to a be a generic computer for collecting data and performing routine and conventional functions therein. This additional element does not overcome the analysis as this element is merely considered as the additional element which amounts to instructions to be applied to the generic computer or mobile device.
The judicial exception is not integrated into a practical application. In particular, the claimed “mobile device” is recited at a high level of generality such that it amounts to no more than mere instructions to apply the exception using a generic component.
Accordingly, the 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 claimed mobile device is also seen as generic computer component for receiving data, generating data, transferring data, and performing generic functions without an inventive concept as such do not amount to significantly more than the abstract idea. The claimed mobile device is interpreted as being recited at a high level of generality and even if the claims recited in the affirmative.
The type of data being manipulated does not impose meaningful limitations or render the idea less abstract. Looking at the elements as a combination, the elements do not add anything more than the elements analyzed individually. Therefore, the claims do not amount to significantly more than the abstract idea itself.
Applicant is reminded that a statutory claim would recite an automated machine implemented method or system with specific structures for performing the claimed invention so as to provide an improvement to another technology or technical field, an improvement to the functioning of the computer itself, or meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment. Each claim as a whole, does not amount to significantly more than the abstract idea itself. This is because each claim does not effect an improvement to another technology or technical field; the claim does not amount to an improvement to the functioning of a computer itself; and the claim does not move beyond a general link of the use of an abstract idea to a particular technological environment.
Accordingly, claims 1 and 7 are directed to an abstract idea.
The dependent claim(s) when analyzed and each taken as a whole are held to be patent ineligible under 35 U.S.C. 101 because the additional recited limitation(s) fail(s) to establish that the claim(s) is/are not directed to an abstract idea.
Claims 1-2 and 5-11 are allowable over the art of record. Accordingly, the prior art taken alone or in combination failed to teach or suggest:
“receiving a transfer request to transfer funds from the account of the user to the third party, the transfer request including the transaction code and information related to the transaction including a transaction amount for transferring to the third party, wherein the transaction code is amended to include authentication information associated with the user, generating a verification request to confirm the information related to the transaction, and transferring the transaction amount from the account of the user to the third party based on authenticating the user using the authentication information and receiving a verification response to the verification request” as recited in independent claim 1.
“generating, by the client application, a transaction code unique to the payment transaction, the transaction code based on the payee; providing, by the client application, the transaction code to the user, and facilitating, by the client application, a transfer of funds from a user account associated with the client application to the payee in response to receiving a disbursement request containing the transaction code from the payee, wherein the transfer is facilitated based on authenticating the transaction code contained in the disbursement request”, as recited in independent claim 7.
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.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to FRANTZY POINVIL whose telephone number is (571)272-6797. The examiner can normally be reached on M-Th 7:00AM to 5:30PM.
Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Michael 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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/fp/
/FRANTZY POINVIL/Primary Examiner, Art Unit 3693
June 10, 2026
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