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 .
DETAILED ACTION
This Non-Final office action is in response to the application filed on August 23, 2024, the amendments to the claims filed on November 26, 2025, and the Request for Continued Examination filed on June 15, 2026.
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 June 15, 2026 has been entered.
Claim Rejections - 35 USC § 112
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 21-40 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) 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 applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. The recitations, “selecting a transaction inference machine learning model from a plurality of machine learning models based on the dispute classification; and utilizing the transaction inference machine learning model to analyze additional transaction metadata associated with additional transaction for the user account with an indication of the dispute classification category to output the one or more potential transactions” in lines 16-21 of claim 21, similarly recited in claims 28 and 35, and, “utilizing the transaction inference machine learning model to process an encoding of the dispute classification” in lines 1-2 of claim 25, similarly recited in claims 32 and 39, is not supported by the specification. While there is support in the specification for, “particular embodiments, the inter-network facilitation system 104 may include one or more of the following: a web server, action logger, API-request server, transaction engine, cross-institution network interface manager, notification controller, action log, third-party-content-object-exposure log, inference module, authorization/privacy server, search module, user-interface module, user-profile (e.g., provider profile or requester profile) store, connection store, third-party content store, or location store” in paragraph [0153] and numerous recitations for machine learning models, the specification is silent regarding, “a transaction inference machine learning model”. Claims 22-24, 26, 27, 29-31, 33, 34, and 36-38, and 40 are considered to be rejected by virtue of their dependencies. Appropriate correction is required.
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 21-39 and 41 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Claims 21-39 and 41 are directed to a system, method, or product which are/is one of the statutory categories of invention. (Step 1: YES).
The Examiner has identified independent method Claim 21 as the claim that represents the claimed invention for analysis and is similar to independent product Claim 28 and system Claim 35. Claim 21 recites the limitations of receiving, from a client device, a dispute request comprising transaction data corresponding to an initial disputed transaction for a user account associated with the client device; based on receiving the dispute request, initiating an interactive query flow that comprises providing one or more queries for display on the client device and receiving one or more responses from the client device; determining a dispute classification for the initial disputed transaction by analyzing, utilizing one or more dispute classification machine learning models or heuristic models, (i) transaction metadata associated with the initial disputed transaction and (ii) the one or more responses to generate the dispute classification, the dispute classification corresponding to a dispute classification category from a plurality of dispute classification categories; identifying one or more potential transactions within the user account to generate a multi- transaction dispute package comprising the initial disputed transaction and the one or more potential transactions by: selecting a transaction inference machine learning model from a plurality of machine learning models based on the dispute classification; and utilizing the transaction inference machine learning model to analyze additional transaction metadata associated with additional transactions for the user account with an indication of the dispute category to output the one or more potential transactions; and based on receiving, from the client device, an indication of a selection of at least one additional disputed transaction from the one or more potential transactions, generating the multi-transaction dispute package comprising the initial disputed transaction and the at least one additional disputed transaction.
These limitations, under their broadest reasonable interpretation, cover performance of the limitation as certain methods of organizing human activity. Generating a multi-transaction dispute package recites a commercial or legal interaction. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation as a commercial or legal interaction, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea. The client device in Claims 21 and 28 and at least one processor and client device in Claim 35 is just applying generic computer components to the recited abstract limitations. The one or more dispute classification machine learning models or heuristic models and transaction inference machine learning model selected from a plurality of machine learning models in Claims 21, 28, and 35 merely confines the use of the abstract idea to a particular technological environment. Claims 28 and 35 are also abstract for similar reasons. (Step 2A-Prong 1: YES. The claims are abstract)
This judicial exception is not integrated into a practical application. In particular, the claims only recite client device in Claims 21 and 28 and at least one processor and client device in Claim 35 and the one or more dispute classification machine learning models or heuristic models and transaction inference machine learning model selected from a plurality of machine learning models in Claims 21, 28, and 35. The computer hardware is 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. Therefore, claims 21, 28, and 35 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. See Applicant’s specification para. [0126-0131] 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. Even assuming there was a technical problem, the claims, as written, fail to recite the details of how a technical solution to the technical problem was accomplished. If there was a technical problem (e.g., existing technology was incapable of performing the claimed functions) then the claims should recite the details of the technical solution (e.g., how existing technology was improved to overcome this inability). However, the claims, as written, provide no such details and merely recite that the claimed functions (i.e., the outcome) are being performed. In addition, performing the judicial exception steps using machine learning merely confines the use of the abstract idea to a particular technological environment and thus fails to add an inventive concept to the claims. See MPEP 2105(h). 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. Thus claims 21, 28, and 35 are not patent eligible. (Step 2B: NO. The claims do not provide significantly more)
Dependent claims 22-27, 29-34, 36-39, and 41 further define the abstract idea that is present in their respective independent claims 21, 28, and 35 and thus correspond to Certain Methods of Organizing Human Activity and hence are abstract for the reasons presented above. Claims 22, 29, and 36 further determine if a dispute qualifies for the multi-transaction dispute package; Claims 23, 30, and 37 further determine the dispute classification; Claims 24, 31, and 38 further define the classification categories; Claims 25, 32, and 39 further define identifying the transactions; Claims 26, 27, 33, and 34 further detail the displaying and selecting of potential transactions; Claim 41 further defines the metadata. 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 claims 22-27, 29-34, 36-39, and 41 are directed to an abstract idea. Thus, the claims 21-39 and 41 are not patent-eligible.
Response to Arguments
Applicant's arguments filed June 15, 2026 have been fully considered but they are not persuasive.
Applicant’s arguments regarding the 35 USC 101 rejection of record (Remarks, pages 8-10) are acknowledged, however they are not persuasive.
Applicant’s arguments that the claims are analogous to those of Desjardins and, “that the present specification identifies a specific technical problem with conventional solutions” (Remarks, pages 8-9), are acknowledged, however they are not persuasive. MPEP 2106.04(d)(1) sets forth that, “the specification should be evaluated to determine if the disclosure provides sufficient details such that one of ordinary skill in the art would recognize the claimed invention as providing an improvement in the functioning of a computer, or an improvement to other technology or a technical field. 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 only 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 that the claim improves technology or a technical field. Second, if the specification sets forth an improvement in technology or a technical field, the claim must be evaluated to ensure that the claim itself reflects the disclosed improvement”. In Ex Parte Desjardins, “the specification identified the improvement to machine learning technology by explaining how the machine learning model is trained to learn new tasks while protecting knowledge about previous tasks to overcome the problem of “catastrophic forgetting,” and that the claims reflected the improvement identified in the specification. Indeed, enumerated improvements identified in the Desjardins specification included disclosures of the effective learning of new tasks in succession in connection with specifically protecting knowledge concerning previously accomplished tasks; allowing the system to reduce use of storage capacity; and the enablement of reduced complexity in the system. Such improvements were tantamount to how the machine learning model itself would function in operation and therefore not subsumed in the identified mathematical calculation. However, the current claims are different, as they fail to set forth any particular technology to perform the actions of the claims. Further, the specification is silent as to an improvement to machine learning models or the use of any particular machine learning model and merely recites that there is a choice between two generic models, “the multi-transaction dispute system 102 utilizes either machine learning model 404 or 406” (paragraph [0077]). This recitation is repeated throughout the specification without adding details as to a difference between machine learning models 404 and 406 or reciting any improvements to those models. The current claims do not purport to have a technological solution to a technological problem but rather the focus of the claims is not on such an improvement in computers as tools, but on certain independently abstract ideas that use computers as tools.
Applicant’s arguments that the claims are analogous to those found statutory in Bascom, (Remarks, pages 9-10), are not found persuasive. In Bascom, the court held that the inventive concept consisted of installing a filtering tool at a specific location, remote from the end-users, with customizable filtering features specific to each end user. However, the current claims to do not perform any such filtering action (or its equivalent) that is location specific and user specific. Further, the claims fail to set forth a specific combination of elements in specific locations but rather disclose known components functioning in their known capacity in their known locations. Hence, Bascom does not apply here.
Applicant’s arguments regarding the 35 USC 112(a) rejection (Remarks, pages 10-11) are acknowledged, however they are not persuasive. Specifically, there is nothing recited within the specification that contemplates that the machine learning models are specific or that there is anything more than two of them, “the multi-transaction dispute system 102 utilizes either machine learning model 404 or 406” (paragraph [0077]). This recitation is repeated throughout the specification without adding details as to a difference between machine learning models 404 and 406 or reciting any improvements to those models. Further, the term, “inference” is only used in paragraph [0153] to set forth that system 104 may include an, “inference module”. The specification clearly sets forth that the, “multi-transaction dispute system 102” contains the machine learning models and that the “inference module” is part of, “an internetwork facilitation system 104”. While the specification does set forth that System 102 is contained within system 104, it is self-contained, see Figure 1, and there is no support for the elements of system 104 to be contained within system 102. Therefore, this cannot provide support for the claim limitation of, “a transaction inference machine learning model.”
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to LINDSAY M MAGUIRE whose telephone number is (571)272-6039. The examiner can normally be reached Monday to Friday 8:30 to 5:00.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Anita Coupe can be reached at (571) 270-3614. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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Lindsay Maguire
6/26/26
/LINDSAY M MAGUIRE/Primary Examiner, Art Unit 3619
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