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 .
Status of Claims
Claims 1-2, 4-13, and 16-17 are pending in this application.
Claim Rejections - 35 USC § 112(a)
The following is a quotation of the first paragraph of 35 U.S.C. 112(a):
(a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention.
The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112:
The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention.
Claims 1-2, 4-13, and 16-17 are rejected under 35 U.S.C. 112(a) or pre-AIA 35 U.S.C. 112, first paragraph, as failing to comply with the written description requirement. The claim contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for pre-AIA the inventor(s), at the time the application was filed, had possession of the claimed invention.
Claims 1, 4 and 7 include the element of ““de-pseudonymizer”. This element appears to have no support in the original abstract, specification or drawings. Introduction of new matter is not allowed in amendments to the Claims (MPEP 2163.06).
Claims 2, 5-6, 8-13, and 16-17 are rejected by virtue of dependency on a rejected based claim.
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, 4-13, and 16-17 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Claims 1-2, 4-13, and 16-17 are directed to a system or method, which are/is one of the statutory categories of invention. (Step 1: YES).
The Examiner has identified independent method claim 17 as the claim that represents the claimed invention for analysis and is similar to independent system claim 1. Claim 17 recites the limitations of financial risk assessment that uses reference and transaction data.
These limitations, under their broadest reasonable interpretation, cover performance of the limitation as certain methods of organizing human activity. Transmitting reference data; processing reference data to generate “risk insights” stored in context store; “risk insights” stored in context store; transactional data = one transaction with one financial institution that includes protected information; tokenizes and hashes the transactional data in batch mode by replacing fields containing the protected information with substituted data and maintaining a map relating the protected information with the substituted data; transmitting the pseudonymizer transaction data to data repository; creating feature lists by processing pseudonymized transaction data and risk insights; creating forensic results by processing risk insights, feature lists, and transaction data to create “forensic results”; transmitting the forensic results and the context store to a sensemaker; unhashing the tokenized transactional data by accessing the map and replacing the substituted data with the protected information in the transaction; visualizes/displays results; and querying for anomalous transaction – specifically, the claim recites
“transmitting reference data… processing the reference data… to generate risk insights that are stored in a context store; pseudonymizing transactional data related to the anomalous financial transaction, where the transactional data contains information pertaining to at least one specific transaction with one specific financial institution that includes protected information, by tokenizing and hashing the transactional data in batch mode by replacing fields containing the protected information with substituted data fields containing the protected information with substituted data and maintaining a map relating the protected information with the substituted data; transmitting the pseudonymized transactional data to a data repository, creating feature lists by processing the pseudonymized transactional data and the risk insights… storing the feature lists in a feature store; creating forensic results by processing the risk insights, the feature lists, and the data from the data repository… transmitting the forensic results and the context store… de-pseudonymizing the transactional data by unhashing the tokenized transactional data in real-time mode by accessing the map and replacing the substituted data with the protected information in the transaction; visualizing analysis results; and querying… to refine the analysis result of the anomalous financial transaction”, recites a fundamental economic practice, directed to mitigating risk.
If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation as a fundamental economic practice or commercial or legal interactions, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
The “a system”, “at least one connector”, “unstructured static and temporal reference data”, “a processor”, “context generator”, “a pseudonymizer”, “a de-pseudonymizer”, “a first learner”, “a context store”, “a data repository”, “a feature generator”, “a second learner”, “GenAI”, “an analytics engine”, “a third learner”, “a feature store”, “an analytics engine”, “a third learner”, “a sensemaker”, and “a user interface”, in claim 1 are just applying generic computer components to the recited abstract limitations. The examiner notes that “de-pseudonymizer” is rejected as new matter. See Claim Rejections - 35 USC § 112(a) above. The recitation of generic computer components in a claim does not necessarily preclude that claim from reciting an abstract idea. Claims 17 is also abstract for similar reasons. (Step 2A-Prong 1: YES. 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: a computer such as a system, a pseudonymizer, a de-pseudonymizer, and a processor; a communication device such as at least one connector and a user interface; a storage unit such as a context store, a data repository, and a feature store; data and data types such as unstructured static and temporal reference data; and software module and algorithm such as a context generator, a first learner, a feature generator, a second learner, GenAI, an analytics engine, a third learner, an analytics engine, a third learner, and a sensemaker. 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 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)
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. Accordingly, these additional elements, do not change the outcome of the analysis, when considered separately and as an ordered combination. Thus, claims 1 and 17 are not patent eligible. (Step 2B: NO. The claims do not provide significantly more)
Dependent claims further define the abstract idea that is present in their respective independent claims 1 and 17 and thus correspond to Certain Methods of Organizing Human Activity, and hence are abstract for the reasons presented above.
Dependent claim 2 discloses the limitation of the context generator further includes at least one connector to topical data, which further narrows the abstract idea. Note that the technical elements “the context generator” and “at least one connector” are recited at a high level of generality. They do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
Dependent claim 4 discloses the limitation of pseudonymizer and the de-pseudonymizer are separate hardware component containing a processor, local memory, and network connectivity, which further narrows the abstract idea. Note that the technical elements “pseudonymizer”, “de-pseudonymizer”, “a separate hardware component”, “a processor”, and “local memory”, are recited at a high level of generality. They do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. The examiner also notes that “de-pseudonymizer” is rejected as new matter. See Claim Rejections - 35 USC § 112(a) above.
Dependent claim 5 discloses the limitation of the feature generator uses GenAI to create feature lists, which further narrows the abstract idea. Note that the technical elements “the feature generator” and “GenAI” are recited at a high level of generality. They do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
Dependent claim 6 discloses the limitation of the first, second, and third learners each contain a data cleaner, a data integrator, and a data extractor, which further narrows the abstract idea. Note that the technical elements “the first, second, and third learners”, “a data cleaner”, “a data integrator” and “a data extractor”, are recited at a high level of generality. They do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
Dependent claim 7 discloses the limitation of the data repository further includes a connector to customer due diligence data, which further narrows the abstract idea. Note that the technical elements “the data repository” and “a connector” are recited at a high level of generality. They do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
Dependent claim 8 discloses the limitation of the sensemaker further includes a sensemaker store that retains results of an analysis, which further narrows the abstract idea. Note that the technical elements “the sensemaker” and “a sensemaker store” are recited at a high level of generality. They do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
Dependent claim 9 discloses the limitation of the sensemaker further includes an analyst interface that includes a feedback connector wherein an analyst can override the forensic results, which further narrows the abstract idea. Note that the technical elements “the sensemaker”, “an analyst interface”, and “a feedback connector”, are recited at a high level of generality. They do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
Dependent claim 10 discloses the limitation of the analyst override is transmitted back to the context generator and to the analytics engine for reinforced learning, which further narrows the abstract idea. Note that the technical elements “the context generator” and “the analytics engine”, are recited at a high level of generality. They do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
Dependent claim 11 discloses the limitation of a query interface that accepts queries from the user into the sensemaker store, including the context store, the feature store, and the forensic results, which further narrows the abstract idea. Note that the technical elements “a query interface”, “the sensemaker store”, “the context store”, and “the feature store”, are recited at a high level of generality. They do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
Dependent claim 12 discloses the limitation of the sensemaker further includes a natural language interpreter to allow the user to query the sensemaker using natural language, which further narrows the abstract idea. Note that the technical elements “the sensemaker” and “a natural language interpreter” are recited at a high level of generality. They do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
Dependent claim 13 discloses the limitation of a SAR generator that produces a suspicious activity report based on the results of the analysis, which further narrows the abstract idea. Note that the technical element “a SAR generator” is recited at a high level of generality. It does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea.
Dependent claim 16 discloses the limitation of case management tools with a feedback loop to the sensemaker for reinforced learning, which further narrows the abstract idea. Note that the technical elements “case management tools” and “the sensemaker” are recited at a high level of generality. They do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
Thus, 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. Thus, the claims 1-2, 4-13, and 16-17 are not patent-eligible.
Response to Arguments
Applicant's arguments filed 10/31/25 have been fully considered but they are not persuasive.
In response to applicant's argument that:
“35 USC§ 101… The problem is solved in part via the pseudonymizer which is described in detail in U.S. Patent 12,032,720 (hereafter, the '720 patent) which was included by reference in the present patent application. However, the original claims lacked sufficient implementation detail in the limitations to present the inventive step required meet the criteria to be integrated into a practical application,”
the examiner respectfully disagrees. The pseudonymizer is mentioned at a high level in this application. It is claimed as a processor as of claim 4 (but could possibly be software before that). The examiner also notes that U.S. Patent 12,032,720 does not claim “pseudonymizer”; it only “pseudonymized” or “de-pseudonymized”. See Claims dated 4/9/24 for U.S. Patent 12,032,720.
In the current application, the claims disclose that the “pseudonymizer” tokenizes and hashes data by replacing data while still maintaining a data relationship (data mapping). That is just data processing. Because “pseudonymizer” is recited at a high level of generality, it does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea.
In response to applicant's argument that:
“the specific way this is accomplished in the present invention, i.e. by replacing fields in the transactional data that contain protected (private or sensitive) information with substituted (anonymous) data and then reversing the process at the conclusion of the analysis, is novel and is particularly pointed out and distinctly claimed in the amended version of the claims presented herein,”
the examiner respectfully disagrees. Replacing sensitive information with substituted/coded information and then reversing the process later with a decoding map/template is a fairly normal way of ensuring privacy. More importantly, this is an abstract idea.
In response to applicant's argument that:
“Claim I has been amended to include further limitations… a pseudonymizer having a connector to transactional data related to the anomalous financial transaction, where the transactional data contains information pertaining to at least one specific transaction with one specific financial institution that includes protected information and where the pseudonymizer tokenizes and hashes the transactional data in batch mode by replacing fields containing the protected information with substituted data and maintaining a map relating the protected information with the substituted data (emphasis original’s),”
the examiner respectfully disagrees. This is just stating that the pseudonymizer is connected (has the ability to access) to the data. The rest of the quote is just explaining what the data is about and how pseudonymizer process the data (by replacing information with substituted information – an abstract idea).
In response to applicant's argument that:
“claim I also includes the following limitation… a de-pseudonymizer coupled to the sensemaker that unhashes the tokenized transactional data in real-time mode by accessing the map and replacing the substituted data with the protected information in the transaction (emphasis original’s),”
the examiner respectfully disagrees. Again, replacing sensitive information with substituted/coded information and then reversing the process later with a decoding map/template is an abstract idea. The examiner notes again that “de-pseudonymizer” is rejected as new matter. See Claim Rejections - 35 USC § 112(a) above.
Conclusion
Accordingly, 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 extension fee 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 date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to MARK H GAW whose telephone number is (571)270-0268. The examiner can normally be reached Mon-Fri: 9am -5pm.
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, Mike Anderson can be reached on 571 270-0508. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000.
/MARK H GAW/Examiner, Art Unit 3693
Prosecution Insights