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 .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 5/11/2026 has been entered.
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, 3-10, and 12-19 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (abstract idea) without significantly more.
Under the broadest reasonable interpretation, the following claim terms are presumed to have their plain meaning consistent with the specification as it would be interpreted by one of ordinary skill in the art. MPEP § 2111.
Step 1: Does the Claim Fall within a Statutory Category? (see MPEP 2106.03) Claim 1 recites a process, which is a statutory category of invention (Step 1: YES). Claim 10 recites a system, which is a statutory category of invention (Step 1: YES). Claim 19 recites an apparatus (product), which is a statutory category of invention (Step 1: YES).
Step 2A, Prong One: Is a Judicial Exception Recited? (see MPEP 2106.04(a)). Yes.
The claims are analyzed to determine whether it is directed to a judicial exception. The following claims identify the limitations that recite additional elements in bold and the abstract idea without bold. Underlined claim limitations denote newly added claim limitations:
The claims are analyzed to determine whether it is directed to a judicial exception. Claim 1, 10 and 19 recite a method for performing automated matching of incoming wire transfers with receivables, the method being implemented by at least one processor, the method comprising: receiving a first plurality of textual messages that are associated with a corresponding plurality of wire transfers; analyzing each message included in the first plurality of textual messages to determine, for each message, respective first information that includes an amount of a corresponding wire transfer, a date, a name of a payor, and a name of an intended recipient; retrieving, from a memory, a second plurality of textual messages that are associated with a corresponding plurality of receivables; analyzing each message included in the second plurality of textual messages to determine, for each message, respective second information that includes an amount of a corresponding receivable, an expected payment date, a name of an intended payor, and a name of a payee; comparing the first information with the second information; determining, based on a result of the comparing, a respective probability that each particular one of the plurality of wire transfers matches with each particular one of the plurality of receivables; and generating, based on a result of the determining, an assessment of respective matched pairings of wire transfers included in the plurality of wire transfers with receivables included in the plurality of receivables, wherein the comparing comprises using a first artificial intelligence / machine learning (AI/ML) model that is trained to employ a natural language processing (NLP) technique to automatically determine a respective term frequency / inverse document frequency (TF/IDF) similarity score for each message included in the first plurality of textual messages with respect to each message included in the second plurality of textual messages, wherein the method further comprises inputting a result of the generating of the assessment of the respective matched pairings to a post consistency filtering process by which information that relates to the respective matched pairings is continually fed back to the first AI/ML model for updating and tuning a training of the first AI/ML model for subsequent operations, and wherein the method further comprises performing an exclusion logic test to ensure that there are no matched pairings that are contradictory based on corresponding amounts. These limitations, as drafted, under its broadest reasonable interpretation, covers performance via certain methods of organizing human activity, but for the recitation of generic computer components. Under human activity, the limitations are fundamental economic practice. More specifically, under fundamental economic practice, the claims involve mitigating risk (local processing of payments for remotely purchased goods, Inventor Holdings, LLC v. Bed Bath Beyond, 876 F.3d 1372, 1378-79, 125 USPQ2d 1019, 1023 (Fed. Cir. 2017)). The claims are also commercial interactions, such as business relations. The claims are also managing interactions between people, such as following instructions. Lastly, the claims are mental processes, which are capable of being performed in the human mind, or by pen and paper. Accordingly, the claim recites an abstract idea. The mere recitation of generic computer components in the claims do not necessarily preclude that claim from reciting an abstract idea. (Step 2A-Prong 1: Yes. The claims recite an abstract idea).
Step 2A, Prong Two: Is the Abstract Idea Integrated into a Practical Application? (see MPEP 2106.04(d)). No.
This judicial exception is not integrated into a practical application. In particular, the claim recites the additional elements of computing apparatus, processor, memory, non-transitory computer readable storage medium, communication interface, each message, textual messages, wire transfers, and the AI/ML model. The additional elements of a computing apparatus, processor, memory, non-transitory computer readable storage medium, and AI/ML model are just applying generic computer components to the recited abstract limitations (MPEP 2106.05(f)). The additional elements of communication interface are generally linking the use of the judicial exception to a particular technological environment or field of use, for the particular technology of Graphical User Interfaces (MPEP 2106.05(h)). The additional elements of textual messages are generally linking the use of the judicial exception to a particular technological environment or field of use, for the particular technology of Short Messaging Service (SMS) (MPEP 2106.05(h)). The additional elements of wire transfers are generally linking the use of the judicial exception to a particular technological environment or field of use, for the particular technology of Electronic Funds Transfers (EFT) (MPEP 2106.05(h)). The computer components are recited at such a high-level of generality (i.e. as a generic computer components) such that it amounts to no more than mere instructions to apply the exception using generic computer components, and the claims fail to recite technological detail as to how the step of the judicial exception is accomplished. 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. (Step 2A-Prong 2: NO. The judicial exception is not integrated into a practical application).
Step 2B: Does the Claim Provide an Inventive Concept? (see MPEP 2106.05). No.
The claims are next analyzed to determine if there are additional claim limitations that individually, or as an ordered combination, ensure that the claim amounts to significantly more than the abstract ideas (whether claim provides inventive concept). As discussed with respect to Step 2A2 above, the additional elements of (computing apparatus, processor, memory, non-transitory computer readable storage medium, communication interface, each message, textual messages, wire transfers, and the AI/ML model) in the claims amount to no more than mere instructions to apply the exception using a generic computer component and generally linking the use of GUI’s, SMS, and EFT to judicial exception. The same analysis applies here in Step 2B, i.e., mere instructions to apply an exception using a generic computer component and generally linking the use of GUI’s, EFT and SMS to the judicial exception cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. Viewing the limitations as an ordered combination does not add anything further than looking at the limitations individually. When viewed either individually, or as an ordered combination, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea itself. Therefore, the claims do not amount to significantly more than the recited abstract idea (Step 2B: NO; The claims do not provide significantly more, and are not patent eligible).
Claim 3 and 12 recite wherein the comparing further comprises using the first AI/ML model to determine, for each message included in the first plurality of textual messages with respect to each message included in the second plurality of textual messages, a respective difference between the amount of the corresponding wire transfer and the amount of the corresponding receivable. These limitations are also part of the abstract idea identified in claim 1, and the additional elements of textual messages and each message are generally linking the use of the judicial exception to a particular technological environment or field of use, for the particular technology of SMS (MPEP 2106.05(h)), and the claim fails to recite technological detail as to how the step of the judicial exception is accomplished. These limitations are also part of the abstract idea identified in claim 1, and the additional elements of AI/ML model are addressed in the Steps 2A2 and B as just applying generic computer components to the recited abstract limitations (MPEP 2106.05(f)) as in the claim 1 analysis above. Therefore, this claim is similarly rejected under the same rationale as claim 1, supra.
Claim 4 and 13 recite wherein the comparing further comprises using the first AI/ML model to determine, for each message included in the first plurality of textual messages with respect to each message included in the second plurality of textual messages, a respective difference between the date of the corresponding wire transfer and the expected payment date of the corresponding receivable. These limitations are also part of the abstract idea identified in claim 1, and the additional elements of textual messages and each message are generally linking the use of the judicial exception to a particular technological environment or field of use, for the particular technology of SMS (MPEP 2106.05(h)), and the claim fails to recite technological detail as to how the step of the judicial exception is accomplished. These limitations are also part of the abstract idea identified in claim 1, and the additional elements of AI/ML model are addressed in the Steps 2A2 and B as just applying generic computer components to the recited abstract limitations (MPEP 2106.05(f)) as in the claim 1 analysis above. Therefore, this claim is similarly rejected under the same rationale as claim 1, supra.
Claim 5 and 14 recite wherein the generating of the assessment comprises determining that there is a match between a first one of the plurality of wire transfers and a first one of the plurality of receivables when a corresponding probability that the first one of the plurality of wire transfers matches with the first one of the plurality of receivables exceeds a first predetermined threshold value. These limitations are also part of the abstract idea identified in claim 1, and the additional elements of wire transfers are generally linking the use of the judicial exception to a particular technological environment or field of use, for the particular technology of EFT (MPEP 2106.05(h)), and the claim fails to recite technological detail as to how the step of the judicial exception is accomplished.
Claim 6 and 15 recite wherein the assessment includes at least one matched pairing of a single wire transfer from among the plurality of wire transfers with a single receivable from among the plurality of receivables, wherein the single wire transfer does not match with any other receivable from among the plurality of receivables, and the single receivable does not match with any other wire transfer from among the plurality of wire transfers. These limitations are also part of the abstract idea identified in claim 1, and the additional elements of wire transfers are generally linking the use of the judicial exception to a particular technological environment or field of use, for the particular technology of EFT (MPEP 2106.05(h)), and the claim fails to recite technological detail as to how the step of the judicial exception is accomplished.
Claim 7 and 16 recite wherein the assessment includes a first matched pairing of a first wire transfer from among the plurality of wire transfers with a first receivable from among the plurality of receivables and at least a second matched pairing of a second wire transfer from among the plurality of wire transfers with the first receivable. These limitations are also part of the abstract idea identified in claim 1, and the additional elements of wire transfers are generally linking the use of the judicial exception to a particular technological environment or field of use, for the particular technology of EFT (MPEP 2106.05(h)), and the claim fails to recite technological detail as to how the step of the judicial exception is accomplished.
Claim 8 and 17 recite wherein the assessment includes a first matched pairing of a first wire transfer from among the plurality of wire transfers with a first receivable from among the plurality of receivables and at least a second matched pairing of the first wire transfer with a second receivable from among the plurality of receivables. These limitations are also part of the abstract idea identified in claim 1, and the additional elements of wire transfers are generally linking the use of the judicial exception to a particular technological environment or field of use, for the particular technology of EFT (MPEP 2106.05(h)), and the claim fails to recite technological detail as to how the step of the judicial exception is accomplished.
Claim 9 and 18 recite wherein the assessment includes a first matched pairing of a first wire transfer from among the plurality of wire transfers with a first receivable from among the plurality of receivables, at least a second matched pairing of a second wire transfer from among the plurality of wire transfers with the first receivable, and at least a third matched pairing of the first wire transfer with a second receivable from among the plurality of receivables. These limitations are also part of the abstract idea identified in claim 1, and the additional elements of wire transfers are generally linking the use of the judicial exception to a particular technological environment or field of use, for the particular technology of EFT (MPEP 2106.05(h)), and the claim fails to recite technological detail as to how the step of the judicial exception is accomplished.
Response to Arguments
Applicant's arguments filed 5/11/2026 have been fully considered but they are not persuasive.
Applicant argues that the currently amended claims are a practical application (Applicant arguments, pg. 12). Examiner disagrees. The currently recited “exclusion test,” as well as the “re-training” and “tuning” in the claims, does not cure a technical problem nor does it allow the AI to function differently than conventional methods. In short, there is no technical improvement to a technical problem.
The currently recited claims recite how a typical artificial intelligence model works, using specific attributes and parameters. However, the claims do not describe any particular improvement in the manner of computer functions. Although an AI model is used for the purposes of performing automated matching of incoming wire transfers with receivables, such uses are both generic and conventional. The object of the claims is to determine automated matching of incoming wire transfers with receivables, the claims do not produce technology enabling an AI model to operate. The claims call for generic use of such a AI model in the manner such models conventionally operate. Simply reciting a particular technological module or piece of equipment in a claim does not confer eligibility. The MPEP notes this distinction.
The MPEP notes this distinction (For example, in MPEP 2106.05(f)(I), it states: Whether the claim recites only the idea of a solution or outcome i.e., the claim fails to recite details of how a solution to a problem is accomplished. The recitation of claim limitations that attempt to cover any solution to an identified problem with no restriction on how the result is accomplished and no description of the mechanism for accomplishing the result, does not integrate a judicial exception into a practical application or provide significantly more because this type of recitation is equivalent to the words “apply it”. See Electric Power Group, LLC v. Alstom, S.A., 830 F.3d 1350, 1356, 119 USPQ2d 1739, 1743-44 (Fed. Cir. 2016); Intellectual Ventures I v. Symantec, 838 F.3d 1307, 1327, 120 USPQ2d 1353, 1366 (Fed. Cir. 2016); Internet Patents Corp. v. Active Network, Inc., 790 F.3d 1343, 1348, 115 USPQ2d 1414, 1417 (Fed. Cir. 2015). In contrast, claiming a particular solution to a problem or a particular way to achieve a desired outcome may integrate the judicial exception into a practical application or provide significantly more. See Electric Power, 830 F.3d at 1356, 119 USPQ2d at 1743). In the instant application, the currently recited claims use AI as generic data processing.
Applicant also argues a recent Director Squires policy September 26, 2025 memo (Arguments, pg. 10). Examiner notes, that the memo did not change USPTO Examiner guidance regarding patent eligibility, and did not say that all AI patent applications are eligible. Examiner notes that the Ex Parte Desjardins decision (as well as the Director Squires’ memo) stressed the specification of application 16/319040, in that the specification was curing a deficiency in the way that normal AI functions, and their specific way of training the AI had an improvement in the AI; the decision had nothing to do with the data itself. In the currently recited claims, the “invention” is in the data itself, and it is using AI at a “high level” which amounts to “apply it,” where there is no curing any technical problem with the way AI functions, and is just using a different set of data. Thus, the application (and currently recited claims) are more like Recentive, than Ex Parte Desjardins.
Conclusion
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/BRANDON M DUCK/Examiner, Art Unit 3693
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