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
This action is in response to remarks received 04/28/2026.
Claims 15-20 are withdrawn from consideration pursuant to the restriction requirement and are not examined on the merits in this Office action.
This application claims earlies priority from Provisional Application 62712475, filed 07/31/2018.
Claims 1 & 8 are independent and claims 2-7 & 9-14 are dependent.
Claims 1, 7-8 and 14-15 have been amended.
Applicant’s arguments, see pages 11-12, filed 04/28/2026, with respect to rejections under 35 USC 102 have been fully considered and are persuasive. The 35 USC 102 claim rejections of the claims has been withdrawn.
Claims 1-14 are currently pending and have been examined.
Response to Arguments
With respect to Applicant’s arguments filed 04/28/2026 with respect to claim rejections under 35 USC 101 have been fully considered, however, the Examiner respectfully disagrees.
Under Step 2A, Prong One, Applicant argues that the claims cannot be performed mentally because they recite encrypted tokens, deep links, electronic calendar entries, token validation, duplicate-request detection, and decryption operations, and therefore are not directed to a mental process or method of organizing human activity. This argument is not persuasive since the rejection does not characterize the claims as a mental process. Rather, the claims are directed to organizing and managing a commercial payment transaction, including presenting payment information, initiating a payment request, validating payment information, authorizing payment, confirming payment, and updating records. These activities fall within the category of certain methods of organizing human activity and fundamental economic practices.
While the claims recite computer components and computer performed operations, the mere recitation of technological tools used to implement a payment workflow does not remove the claims from the realm of organizing human acidity. The electronic calendar entry, graphical element, deep link, encrypted token, duplicate request determination, and payment confirmation operations are all performed in furtherance of facilitating and managing the payment transaction itself. Accordingly, when considered as a whole, the focus of the claims remains the commercial payment process rather than an improvement in computer technology.
Applicant’s reliance on limitations involving encrypted tokens, deep links, and decryption is likewise unpersuasive because the claims do not recite any particular token structure, cryptographic technique, key management protocol, deep link protocol, or other technological mechanism that improves computer functionality. Rather, the claims invoke these components at a functional level as tools used within the payment workflow.
For the above reasoning, the claims remain directed to a judicial exception under Step 2A, Prong One.
Under Step 2A, Prong Two, Applicant argues that the claims integrate any alleged judicial exception into a practical application because the claims recite automatic creation of calendar entries, storage of deep links containing encrypted tokens, duplicate payment detection, token validation, decryption, and removal of tokens after successful payment. The argument is not persuasive since the additional elements do not integrate the judicial exception into a practical application. The claims do not recite an improvement to the functioning of a computer, server, electronic calendar, database, encryption technology, tokenization technology, deep link technology, or any other computer technology.
Applicant characterizes the claimed limitations as improving the reliability of computer implemented request processing and preventing duplicate payment request; however, the claims merely use generic computer components to achieve the business objective of avoiding duplicate payment transactions. Preventing duplicate payments constitutes a payment processing objective and does not, by itself, demonstrate a technological improvement in computer operations.
Similarly, the claims recite determining whether a payment request is a duplicate, validating that a token has not expired, decrypting a token, and removing the token after successful payment, however, the claims do not recite how these operations are technologically achieved, nor do they recite any particular algorithm, data structure, database architecture, cryptographic technique, or unconventional computer implementation that improves computer performance, security, memory utilization, network functionality, or other technological operation.
Although Applicant asserts that duplicate request detection occurs prior to decryption and token processing, the claims do not recite any improvement in how duplicate detection, token validation, decryption, or databased operations are technologically performed; rather, the claims merely specify the order in which information is processed within the payment workflow.
Applicant further argues that the claims impose constraints on computer execution, such as requiring duplicate request detection before decryption and enforcing one-time token use, however, the recited sequence merely defines the order in which information is processed within the payment workflow and does not represent an improvement to the operation of the underlying computer technology itself.
When considered individually and as an ordered combination, the additional elements merely automate and implement the abstract payment workflow using generic computer components. Therefore, the claims do not integrate the judicial exception into a practical application.
Applicant identifies benefits such as reducing duplicate payment requests, reducing re-entry of information, and improving payment processing reliability; however, these asserted benefits arise from the use of computer technology as a tool to perform the payment workflow and do not reflect an improvement to the functioning of the computer technology itself.
For the above reasoning, the claims remain directed to a judicial exception under Step 2A, Prong Two.
Accordingly, the 35 USC 101 rejection of the claims is maintained.
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.
Unser Step 1, independent claim 1 recites a system comprising a payment server having a processor and storage medium, and independent claim 8 recites a computer-implemented method. Accordingly, the claims fall within the statutory categories of a machine and process and are analyzed under the judicial exception framework below.
Under Step 2A, Prong One, claim 1 recites a payment server system configured to perform operations for facilitating processing of bill-payment information. The claimed operations include transmitting an electronic message for display in a statement notification interface, adding an electronic calendar entry containing a token/payment data, using a graphical element and deep link to initiate a payment request, receiving an encrypted token, determining whether the payment request is a duplicate or expired, decrypting the encrypted token to retrieve the payment data, transmitting a payment confirmation request, receiving an approval/confirmation, removing the decrypted token, and updating a payment record. Independent claim 8 recites substantially similar operations in method form. Considered as a whole, claims 1 and 8 are directed to organizing and managing a commercial payment transaction, including presenting payment information, initiating/authorizing payment, confirming the payment, and updating records. Such activity is a fundamental economic practice and a method of organizing human activity/commercial interaction. The use of a calendar entry, graphical element, token, deep link, and server merely provides computer-based tools for carrying out the payment workflow and does not change the character of the claims from the abstract idea.
Courts have consistently held that concepts such as processing payments, authorizing transactions, confirming payments, and updating financial records constitute abstract ideas. See, e.g., Alice, 573 U.S. at 219–221; Bilski v. Kappos, 561 U.S. 593 (2010); Credit Acceptance Corp. v. Westlake Servs., 859 F.3d 1044 (Fed. Cir. 2017).
Accordingly, the claims recite an abstract idea.
Under Step 2A, Prong Two, the additional elements do not integrate the abstract idea into a practical application. The claimed payment server, user device, storage medium, electronic application, electronic calendar, graphical elements, token, deep link, encryption/decryption, database, and record update functions are recited at a high-level of generality and are used as tools to implement the commercial payment process. The claim does not recite an improvement to the functioning of the server, user device, electronic calendar, deep linking technology, tokenization, encryption, database operation, or any other computer technology. Instead, the claimed components perform generic computer functions of transmitting, receiving, displaying, storing, decrypting, comparing, removing and updating information. The encrypted token and deep link are used to carry or access payment data in the payment workflow, but the claim does not specify any particular token structure, or other technical implementation that improves computer security or efficiency. Therefore, the claim merely applies the abstract idea using generic computing components, and does not impose a meaningful technological limitation.
Although the claim recites an encrypted token, duplicate-request detection, and removal of the token after payment processing, these limitations merely govern the use of payment information within the payment workflow and are not described as improving tokenization technology, cryptographic processing, computer security, database functionality or computer operation itself.
Further, preventing supplicate payment request through validation of payment information constitutes a business rule or payment processing objective and the claim does not recite a technological improvement in how computers detect duplicates, mange memory, perform cryptographic operations, or otherwise operate.
Under Step 2B, the claim does not recite an inventive concept. The additional elements, individually and as an ordered combination, amount to no more than generic computer implementation of the abstract payment workflow. The limitations relating to displaying a notification, creating a calendar entry, using a graphical element/deep link to initiate a request, transmitting and receiving payment/confirmation messages, checking duplicate or expired requests, decrypting a token to retrieve payment data, removing the decrypted token, and updating a payment record are recited functionally, i.e., by the result achieved, without any particular unconventional technical mechanism. The ordered combination reflects a conventional computerized sequence for initiating, authorizing, confirming, and recording a payment transaction, rather than a technical solution that transforms the abstract idea into patent eligible subject matter. Moreover, the ordered combination of the claimed elements merely automates a payment processing workflow that could otherwise be performed using conventional payment reminders, payment requests, approvals, confirmations, and record updates.
The claim does not recite a particular cryptographic algorithm, token-generation technique, deep link protocol, database architecture, or other unconventional technological implementation that would amount to significantly more than the abstract idea.
The claims do not recite additional elements that amount to significantly more than the abstract idea under Step 2B of the Alice/Mayo framework and therefore are not directed to patent-eligible subject matter under 35 U.S.C. § 101.
The dependent claims are separately considered. Each dependent claim adds further limitations (additional elements) beyond the abstract idea; however, those additional elements likewise amount to conventional computer implementation and/or insignificant extra-solution activity (e.g., additional notifications, additional message content, additional record fields, routine security/formatting options, or routine UI variations).
For example, claims 2 and 9 add that the user device is a mobile device and that the electronic application triggers display of the payment confirmation request, receives the approval notification, and transmits the approval notification. These limitations merely specify routine mobile device user interface and messaging operations and do not recite an improvement to mobile device functionality or any unconventional technical implementation.
Claims 3 and 10 add extracting and storing payment data form a bill statement file and generating the token including the payment data. These limitations merely add routine data extraction, storage, and token generation functions used in the payment workflow, without reciting a particular token structure, extraction technique, or technical improvement.
Claims 4 and 11 add storing the token in association with a customer identifier linked to a customer record. These limitations merely recite conventional database association and record-linking activity.
Claims 5 and 12 add generating an enhanced bill statement file form an electronic bill statement file. These limitations merely recite routine file generation/formatting and do not impose a technological constraint or improvement.
Claims 6 and 13 add processing a registration request to store an electronic address in a customer record. These limitations merely recite routine account setup and customer record management activity.
Claims 7 and 14 add that the payment request indicates payment amount, payment due date, vendor identifier, and vendor account identifier. These limitations merely specify additional informational content used in the payment request and do not add any technical improvement.
Accordingly, each dependent claim adds only conventional computer implementation details and/or insignificant extra-solution activity beyond the abstract idea. Therefore, the dependent claims likewise do not recite an inventive concept for substantially the same reasons discussed above
Since the claims are directed to an abstract idea and do not recite additional elements sufficient to amount to significantly more than the abstract idea itself, claims 1-14 are rejected under 35 U.S.C. § 101.
It is noted that a combination claim, combining multiple dependents (e.g., Claims 4 and 7?) has not been presented.
Conclusion
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 TONY P KANAAN whose telephone number is (571)272-2481. The examiner can normally be reached Monday- Friday 7:30am - 3:30 pm EST.
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/T.P.K./Examiner, Art Unit 3696
/WILLIAM J JACOB/Examiner, Art Unit 3696
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