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 1-20 are pending in this instant application per claim amendments and remarks filed on 08/12/2026, wherein Claims 6, 8, 13 and 15 have been amended. Claims 1, 8 and 15 are independent claims reciting method, non-transitory computer-readable medium and system claims. Claims 2-7, 9-14 and 16-20 are respective dependent claims.
No IDS has been filed by the Applicant so far.
This Office Action is a final rejection in response to the claim amendments and the remarks filed by the Applicant on 12 AUGUST 2026 for its original application filed on 06 SEPTEMBER 2024 that is titled: “Multi-Stage Mobile Deposit Check Verification and Fraud Prevention System”.
Accordingly, amended claims 1-20 are now being rejected herein.
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 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (abstract idea) without significantly more, wherein Claims 1, 8 and 15 are independent method, non-transitory computer readable medium and system claims respectively.
Exemplary Analysis.
Claim 1: Ineligible.
The claim recites a series of steps. The claim is directed to a method reciting a series of steps, which is a statutory category of invention (Step 1 -- YES).
The claim is analyzed to determine whether it is directed to a judicial exception. The claim recites the limitations of: receiving first mobile check image portraying a first side of a mobile deposit check; determining, based on the first mobile check image, an initial acceptance probability for the mobile deposit check; requesting, based on determining the initial acceptance probability, a second mobile check image portraying a second side of the mobile deposit check; and determining, based on the first mobile check image and the second mobile check image, a final acceptance probability for the mobile deposit check. In other words, the claim describes a procedure that utilizes a multi-stage image processing approach to extract and analyze data from multiple check images at various stages of depositing mobile deposit checks. These limitations, as drafted, are steps of a method that, under its broadest reasonable interpretation, covers performance of the limitations via a method of organizing human activity such as fundamental economic principles or practices (including hedging, insurance, mitigating risk), and/or commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations), and/or managing behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions), but for the recitation of generic computer/s and/or computer component/s such as the devices/ mobile devices. These limitations fall under the “certain methods of organizing human activity” group (Step 2A1 -- YES).
Next, the claim is analyzed to determine if it is integrated into a practical application. The claim recites additional elements of: client device as part of a system with a processor. These additional elements are considered extra-solution activities. The devices and processors in the steps are recited at a high level of generality, i.e., as generic processors performing generic computer/s functions of processing data. These generic processors are no more than mere instructions to apply the exception using generic computer/s and/or computer component/s. Accordingly, these additional elements 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 claim is directed to the abstract idea (Step 2A2 -- NO).
Next, the claim is analyzed to determine if there are additional elements in this claim 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 in the claim amount to no more than mere instructions to apply the exception using generic computer/s and/or computer component/s. The same analysis applies here in Step 2B, i.e., mere instructions to apply an exception using a generic computer and/or computer components over a network cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. Because the additional elements of: client device as part of a system with a processor, were considered to be extra-solution activities in Step 2A, they are re-evaluated in Step 2B to determine if they are more than what is well-understood, routine and conventional in the field. The disclosure does not provide any indication that these devices (processors) are anything other than generic processors and the Symantec, TLI, and OIP Techs. court decisions (MPEP 2106.05 (d)(II)) indicate that mere collection or receipt of data over a network is a well‐understood, routine, and conventional function when it is claimed in a merely generic manner (as it is here). Also, paras [0117]--[0118] and [0126]--[0127] of the Applicant’s own Specification describe ---
{“ [0117] In particular embodiments, the client device 1006 may be an electronic device including hardware, software, or embedded logic components or a combination of two or more such components and capable of carrying out the appropriate functionalities implemented or supported by client device 1006. As an example, and not by way of limitation, a client device 1006 may include any of the computing devices discussed above in relation to FIG. 9. A client device 1006 may enable a network user at the client device 1006 to access network 1004. A client device 1006 may enable its user to communicate with other users at other client devices 1006. …………………………………………………………………………………………………………………………………….
[0118] In particular embodiments, the client device 1006 may include a requester application or a web browser, such as MICROSOFT INTERNET EXPLORER, GOOGLE CHROME or MOZILLA FIREFOX, and may have one or more add-ons, plug-ins, or other extensions, such as TOOLBAR or YAHOO TOOLBAR. A user at the client device 1006 may enter a Uniform Resource Locator (“URL”) or other address directing the web browser to a particular server (such as server), and the web browser may generate a Hyper Text Transfer Protocol (“HTTP”) request and communicate the HTTP request to server. The server may accept the HTTP request and communicate to the client device 1006 one or more Hyper Text Markup Language (“HTML”) files responsive to the HTTP request. The client device 1006 may render a webpage based on the HTML files from the server for presentation to the user. This disclosure contemplates any suitable webpage files. As an example, and not by way of limitation, webpages may render from HTML files, Extensible Hyper Text Markup Language (“XHTML”) files, or Extensible Markup Language (“XML”) files, according to particular needs. Such pages may also execute scripts such as, for example and without limitation, those written in JAVASCRIPT, JAVA, MICROSOFT SILVERLIGHT, combinations of markup language and scripts such as AJAX (Asynchronous JAVASCRIPT and XML), and the like. Herein, reference to a webpage encompasses one or more corresponding webpage files (which a browser may use to render the webpage) and vice versa, where appropriate. ………………………………………………………………………………………………………………..
[0126] The web server may include a mail server or other messaging functionality for receiving and routing messages between the inter-network facilitation system 104 and one or more client devices 1006. An action logger may be used to receive communications from a web server about a user’s actions on or off the inter-network facilitation system 104. In conjunction with the action log, a third-party-content-object log may be maintained of user exposures to third-party-content objects. A notification controller may provide information regarding content objects to a client device 1006. Information may be pushed to a client device 1006 as notifications, or information may be pulled from client device 1006 responsive to a request received from client device 1006. Authorization servers may be used to enforce one or more privacy settings of the users of the inter-network facilitation system 104. A privacy setting of a user determines how particular information associated with a user can be shared. The authorization server may allow users to opt into or opt out of having their actions logged by the inter-network facilitation system 104 or shared with other systems, such as, for example, by setting appropriate privacy settings. Third-party-content-object stores may be used to store content objects received from third parties. Location stores may be used for storing location information received from client devices 1006 associated with users. …………………………………..
[0127] In addition, the third-party system 1008 can include one or more computing devices, servers, or sub-networks associated with internet banks, central banks, commercial banks, retail banks, credit processors, credit issuers, ATM systems, credit unions, loan associates, brokerage firms, linked to the inter-network facilitation system 104 via the network 1004. A third-party system 1008 can communicate with the inter-network facilitation system 104 to provide financial information pertaining to balances, transactions, and other information, whereupon the inter-network facilitation system 104 can provide corresponding information for display via the client device 1006. In particular embodiments, a third-party system 1008 communicates with the inter-network facilitation system 104 to update account balances, transaction histories, credit usage, and other internal information of the inter-network facilitation system 104 and/or the third-party system 1008 based on user interaction with the inter-network facilitation system 104 (e.g., via the client device 1006). Indeed, the inter-network facilitation system 104 can synchronize information across one or more third-party systems 1008 to reflect accurate account information (e.g., balances, transactions, etc.) across one or more networked systems, including instances where a transaction (e.g., a deposit) from one third-party system 1008 affects another third-party system 1008. ”} ---
and indicate that the concept described by the extra-solution additional elements is
conventional. Accordingly, a conclusion that the aforementioned extra-solution additional elements are well-understood, routine and conventional activity is supported under Berkheimer options 2 and 3, respectively.
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 elements do not amount to a claim as a whole that is significantly more than the abstract idea itself. Therefore, the claim does not amount to significantly more than the recited abstract idea (Step 2B -- NO), and the claim is not patent eligible.
The analysis above applies to all statutory categories of the invention including independent non-transitory computer readable medium Claim 8 and independent system Claim 15, which perform the steps similar to those of the independent method Claim 1. Furthermore, the limitations of dependent method Claims 2-7, further narrow the independent method Claim 1 with additional steps and limitations (e.g., providing a notification for the mobile deposit check based on determining that the initial acceptance probability satisfies an acceptance threshold; determining that the initial acceptance probability satisfies the acceptance threshold and does not satisfy the second acceptance threshold, generating a restrictive endorsement notification instructing the client device to include a restrictive endorsement in the second mobile check image;
determining the final acceptance probability based on the restrictive endorsement in the second mobile check image; holding the mobile deposit check based on determining that the initial acceptance probability does not satisfy the hold threshold; receiving, from the image data verification system, verified check data for the mobile deposit check; and generating the initial acceptance probability utilizing an acceptance probability machine learning model that processes the verified check data; generating a deferred restrictive endorsement for the mobile deposit check by requesting a restrictive endorsement for the second mobile check image in response to determining the initial acceptance probability; etc.), and do not resolve the issues raised in rejection of the independent method Claim 1. Similarly, dependent non-transitory computer-readable medium Claims 9-14 and dependent system Claims 16-20 also further narrow their independent Claims 8 and 15 respectively, which are rejected as ineligible for patenting under 35 U.S.C. 101 based upon the same analysis.
Therefore, claims 1-20 are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter.
Claim Rejections - 35 USC §103
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
This application currently names joint inventors. In considering patentability of the claims the Examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. The Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the Examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention.
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office Action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
The factual inquiries set forth in Graham v. John Deere Co., 383 U.S.1,148 USPQ 459 (1966), that are applied for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
1.) Determining the scope and contents of the prior art.
2.) Ascertaining the differences between the prior art and the claims at issue.
3.) Resolving the level of ordinary skill in the pertinent art.
4.) Considering objective evidence present in the application indicating obviousness or nonobviousness.
Claims 1-20 are rejected under 35 USC 103 as unpatentable over a combination of references (Yoshida and Thasanon for all claims, plus Coleman, Franklin and Shevyrev for some claims) as described below for each claim/ limitation.
Exemplary Analysis for Rejection of Claims 1-7
Independent Claim 1 is rejected under 35 USC 103 as unpatentable over Pub. No. US 2025/ 0259153 filed by Yoshida et al. (hereinafter “Yoshida”) in view of Pub. No. US 2025/ 0322395 filed by Thasanon, Namfon (hereinafter “Thasanon”), and as described below for each claim/ limitation.
Examiner notes that all claims have been copied as recited by the Applicant to keep them readable and whole, even if the limitations within a claim that are not taught explicitly by the primary/previous reference (are noted in parentheses), but these limitations are noted explicitly as taught by a secondary/new reference whenever a secondary/new reference has been used.
Examiner notes that, for brevity in this rejection, the motivation statement has not been repeated herein every time a secondary reference has been used.
With respect to Claim 1, Yoshida teaches ---
1. A computer-implemented method, comprising:
receiving, from a client device, a first mobile check image portraying a first side of a mobile deposit check;
(see at least: Yoshida Abstract; and para [0041] about {“In some embodiments, OCR (Optical Character Recognition) processing of an image of a check may include OCR processing performed at a backend system, for example, during a check image validation process. …”}; and para [0079] about {“Client device 302 may obtain and transmit check images, including front and back images of a check, captured using camera 308. The check images may then be stored in the customer account 408 for later use if necessary. …”}; and para [0089] about {“In some embodiments, the front side imagery may be processed followed by the back side imagery. Alternatively, or in combination, the front side and back side imagery may be processed together or in parallel.”}; and para [0105] about {“…… In some embodiments, a check image 603 may depict both a front and a back side of a check (e.g., be a merged picture). In some embodiments, a check image 603 may depict a back side of a check. In some embodiments, check images 603 may include pixel data. …”}; which together are the same as claimed limitations above to include ‘a client device’ and ‘a first mobile check image’ portraying ‘a first side’ of ‘a mobile deposit check’ per BRI rules)
Examiner notes that Yoshida’s teachings of “front and back images of a check” are the same as claimed limitations of ‘a first side’ and ‘a second side’ of a check.
Yoshida teaches ---
determining, based on the first mobile check image, an initial acceptance probability for the mobile deposit check;
(see at least: Yoshida ibidem and citations listed above to include ‘a first mobile check image’ and ‘a mobile deposit check’; and para [0019] about {“…… Upon being provided an image of a check, the predictive ML model may be configured to provide a likelihood the check image will be successfully processed via OCR (e.g., a confidence score). Using the confidence score or other indication of the likelihood from the predictive ML model, a mobile banking app operating on the customer's mobile device may provide an image acceptance status to the customer via a user interface (UI). …”}; and para [0021] about {“…… In such embodiments, the predictive ML model may still determine a likelihood of successful OCR processing prior to forwarding an image for further processing. In such embodiments, an image acceptance status may also be provided to a customer in real-time via a UI.”}; and para [0074] about {“In some embodiments, image acceptance status 416 may include instructions that may be based on a diagnostic of the image run by a diagnostic ML model (e.g., diagnostic model 614 discussed with respect to FIG. 6). …”}; and para [0109] about {“In some embodiments, when a financial instrument type acceptability confidence score that indicates a likelihood the financial instrument image depicts an acceptable financial instrument type is used, the predetermined threshold related to financial instrument type acceptability certainty may be from 50% to 100%, including subranges. …”}; and para [0167] about {“In some embodiments, method 700 may include providing instructions to a user (e.g., via image acceptance status 416) to modify a condition of image capture based on a value of a parameter associated with a check image captured prior to the deposit check image. …”}; which together are the same as claimed limitations above to include ‘an initial acceptance probability’ per BRI rules)
Yoshida teaches ---
requesting, based on determining the initial acceptance probability, a second mobile check image from the client device portraying a second side of the mobile deposit check; and
(see at least: Yoshida ibidem and citations listed above to include ‘a client device’ and ‘an initial acceptance probability’; and para [0157] about {“Step 702 may include categorizing a collection of check images (e.g., image collection 602) into a first plurality of check images (e.g., pass images 608) that have successfully been processed via OCR to obtain deposit data and a second plurality of check images (e.g., fail images 610) that have failed OCR processing. Step 702 may include associating categorization data (e.g., via labels as described with respect to FIG. 6) with each of the first plurality of check images and each of the second plurality of check images.”}; and para [0158] about {“Step 704 may include providing the first plurality of check images, the second plurality of check images, and the categorization data to an untrained or partially trained machine learning (ML) model to obtain a further trained ML model (e.g., confidence model 612).”}; and para [0217]; which together are the same as claimed limitations above to include ‘a second mobile check image’ portraying ‘a second side’ per BRI rules)
Yoshida teaches ---
determining, based on the first mobile check image and the second mobile check image, (a final acceptance probability) for the mobile deposit check.
(see at least: Yoshida ibidem and citations listed above to include ‘a first mobile check image’ and ‘the second mobile check image’ plus ‘a mobile deposit check’; and para [0053] for ‘image memory 312 to assess the likelihood the one or more images will be able to be successfully processed via OCR’; and para [0102] about {“For example, mobile banking app 304 (or the other component) may receive from the predictive ML model 1) a confidence score indicating a likelihood the financial instrument image depicts a certain financial instrument type (a financial instrument type confidence score, usually that for the most likely financial instrument type), and/or 2) a confidence score indicating a likelihood the financial instrument image depicts an acceptable financial instrument type (a financial instrument type acceptability confidence score, which may also be a confidence score indicating a likelihood the financial instrument image depicts an impermissible financial instrument type), as discussed above. …”}; and para [0137] about {“The resulting classification model 614 may provide, in response to receiving an image of a financial instrument, a financial instrument type acceptability determination (e.g., acceptable/ impermissible type) and/or an associated financial instrument type acceptability confidence score indicating a likelihood the financial instrument type acceptability determination is correct. …”}; and para [0138] about {“…… In addition, the resulting classification model 614 may provide, in response to receiving the image of the financial instrument, a financial instrument type acceptability determination (e.g., acceptable/impermissible type) and/or an associated financial instrument type acceptability confidence score indicating a likelihood the financial instrument type acceptability determination is correct. …”}; and paras [0210]-[0211]; which together are the same as claimed limitations above)
Yoshida teaches as disclosed above, but it may not explicitly disclose about ‘a final acceptance probability’. However, Thasanon teaches it explicitly.
(see at least: Thasanon Abstract; and para [0018] about {“…… whether images of documents depict types of financial instruments that are accepted for remote deposit. …… Additionally, during the time between providing images for deposit and receiving a notification regarding final acceptance of the deposit, …”}; and para [0085] about {“…… In some embodiments, the financial instrument images may be stored (e.g., in file DB 320) with associated data including image metadata, results of real time ML image assessment, final financial instrument type/type acceptability determinations, or any combination thereof. …”}; which together are the same as claimed limitations above to include ‘a final acceptance probability’)
It would have been obvious prior to the time of the effective filing date of the claimed invention to have an ordinary person of skill in the art to modify the teachings of Yoshida with the teachings of Thasanon. The motivation to combine these references would be to permit financial institutions that provide mobile banking apps via which a customer may deposit paper checks from virtually anywhere using their smartphone or tablet (see para [0001] of Yoshida), and to allow financial institutions for remote verification of identification documents to allow access to a service, product, and/or website, even though certain types of documents are sometimes not accepted for remote mobile deposit purposes or identity verification (see para [0001] of Thasanon).
Dependent Claim 2 is rejected under 35 USC 103 as unpatentable over Yoshida and Thasanon as applied to the rejection of independent Claim 1 above, and as described below for each claim/ limitation.
With respect to Claim 2, Yoshida and Thasanon teach ---
2. The computer-implemented method of claim 1, further comprising providing a notification for the mobile deposit check based on determining that the initial acceptance probability satisfies an acceptance threshold.
(see at least: Yoshida ibidem and citations listed above to include ‘a mobile deposit check’ and ‘an initial acceptance probability’; and para [0068] about {“…… adjust a threshold confidence a predictive ML model must reach in order for an image to be classified as “pass” (predicted to successfully pass OCR processing). …… determine an optimized threshold confidence that reduces the number of attempts while still reducing the number of images that pass the real time image assessment but later fail OCR processing. In the process of calculating the optimized threshold confidence, reducing the number of attempts and reducing the number of images that pass real time image assessment but later fail OCR processing may be weighted differently. …… In some embodiments, the optimized threshold confidence may be provided back to mobile banking app 304 and/or a predictive ML model operating on mobile ML platform 310 for use in classifying images.”}; and para [0094] about {“……… In some embodiments, a predetermined threshold may be set within mobile banking app 304. In response to the confidence score meeting the predetermined threshold, mobile banking app 304 may forward the check image for OCR processing (e.g., at cloud banking system 316 or a third party server). In the case of the confidence score being a confidence score predicting whether the image will pass, meeting the predetermined threshold may include equaling or exceeding the predetermined threshold. In the case of the confidence score being a confidence score predicting whether the image will fail, meeting the predetermined threshold may include equaling or being less than the predetermined threshold.”}; which together are the same as claimed limitations above to include ‘satisfies an acceptance threshold’)
(see at least: Thasanon ibidem and citations listed above to include ‘a final acceptance probability’)
Dependent Claims 3-4 and 7 are rejected under 35 USC 103 as unpatentable over Yoshida and Thasanon as applied to the rejection of Claims 1-2 and 6 above, and further in view of Pub. No. US 2013/ 0297379 filed by Coleman, Thomas E. (hereinafter “Coleman”), and as described below for each claim/ limitation.
With respect to Claim 3, Yoshida and Thasanon teach ---
3. The computer-implemented method of claim 1, further comprising:
determining, based on the first mobile check image, that the initial acceptance probability satisfies an acceptance threshold and (does not satisfy a second acceptance threshold); and
(see at least: Yoshida ibidem and citations listed above to include ‘an initial acceptance probability’--‘satisfies an acceptance threshold’)
(see at least: Thasanon ibidem and citations listed above to include ‘a final acceptance probability’; and para [0172] about {“…… in response to the confidence score meeting a predetermined threshold, incident detection engine 710 may determine that a deposit attempt should be denied. In some embodiments, this determination may be provided to a payee customer in real-time as a document acceptance status 416. In response to incident detection engine 710 determining that the confidence score does not meet a predetermined threshold, incident detection engine 710 may determine that further assessment of the security of the deposit attempt is required. …”}; which together are the same as claimed limitations above to include ‘does not satisfy a second acceptance threshold’)
Yoshida and Thasanon teach ---
based on determining that the initial acceptance probability satisfies the acceptance threshold and does not satisfy the second acceptance threshold, generating (a restrictive endorsement notification) instructing the client device to include (a restrictive endorsement in the second mobile check image).
(see at least: Yoshida ibidem and citations listed above to include ‘an initial acceptance probability’--‘satisfies an acceptance threshold’)
(see at least: Thasanon ibidem and citations listed above to include ‘a final acceptance probability’ and ‘does not satisfy a second acceptance threshold’)
Yoshida and Thasanon teach as disclosed above, but they may not explicitly disclose about ‘a restrictive endorsement notification’ and ‘a restrictive endorsement in the second mobile check image’. However, Coleman teaches them explicitly.
(see at least: Coleman Abstract; and paras [0038]--[0039] about {“According to another aspect of the invention, members can order special iPool personal checks which are imprinted with a restrictive endorsement, such as the following:” [0039] All endorsers and transferees agree, by accepting this instrument not to use any information obtained about the drawer from this instrument in any manner whatsoever and acknowledge the personal nature of such Information and its ownership by the drawer.”}; and para [0063] about {“…… These checks, which include the usual bank and account number information for the consumer, in addition include a notice and a restrictive endorsement on the back of the check …… Part of this notice is a restrictive endorsement, the acceptance of which by the merchant indicates their agreement to the restriction on the use of the customer's personal and transactional data: specifically, that the transaction and the payment therefor is solely for the purposes of the purchase of the goods or services, and that the merchant and all holders in due course are prohibited from using the consumer's personal information, or information specific to the transaction for which the check was given in payment, for any other purpose. …”}; and para [0064] about {“A similar path is followed for other vendor payments 108, where the restrictive endorsement and notice on the checks is passed at step 214 to the vendor, and at step 215 to all other financial processors and intermediaries 412-414.”}; which together are the same as claimed limitations above to include ‘a restrictive endorsement notification’ and ‘a restrictive endorsement in the second mobile check image’)
It would have been obvious prior to the time of the effective filing date of the claimed invention to have an ordinary person of skill in the art to modify the teachings of Yoshida and Thasanon with the teachings of Coleman. The motivation to combine these references would be to permit financial institutions that provide mobile banking apps via which a customer may deposit paper checks from virtually anywhere using their smartphone or tablet (see para [0001] of Yoshida), and to allow financial institutions for remote verification of identification documents to allow access to a service, product, and/or website, even though certain types of documents are sometimes not accepted for remote mobile deposit purposes or identity verification (see para [0001] of Thasanon), and to protect a person’s (user’s) privacy of four types:-- informational privacy, privacy of communication, physical privacy, and physical space privacy in business transactions (see para [0012] of Coleman).
With respect to Claim 4, Yoshida, Thasanon and Coleman teach ---
4. The computer-implemented method of claim 3, further comprising determining the final acceptance probability based on the restrictive endorsement in the second mobile check image.
(see at least: Yoshida ibidem and citations listed above to include ‘an initial acceptance probability’ and ‘a second mobile check image’)
(see at least: Thasanon ibidem and citations listed above to include ‘a final acceptance probability’ and ‘does not satisfy a second acceptance threshold’)
(see at least: Coleman ibidem and citations listed above to include ‘a restrictive endorsement notification’ and ‘a restrictive endorsement in the second mobile check image’)
With respect to Claim 7, Yoshida, Thasanon and Coleman teach ---
7. The computer-implemented method of claim 1, further comprising generating a deferred restrictive endorsement for the mobile deposit check by requesting a restrictive endorsement for the second mobile check image in response to determining the initial acceptance probability.
(see at least: Yoshida ibidem and citations listed above to include ‘an initial acceptance probability’ and ‘a second mobile check image’)
(see at least: Thasanon ibidem and citations listed above to include ‘a final acceptance probability’ and ‘does not satisfy a second acceptance threshold’)
(see at least: Coleman ibidem and citations listed above to include ‘a restrictive endorsement notification’ and ‘a restrictive endorsement in the second mobile check image’; which together are the same as claimed limitations above to include ‘a deferred restrictive endorsement’)
Dependent Claim 5 is rejected under 35 USC 103 as unpatentable over Yoshida and Thasanon as applied to the rejection of Claims 1-2 & 6 above, and further in view of Pub. No. US 2026/ 0010883 filed by Franklin et al. (hereinafter “Franklin”), and as described below for each claim/ limitation.
With respect to Claim 5, Yoshida and Thasanon teach ---
5. The computer-implemented method of claim 1, further comprising:
determining that the initial acceptance probability (does not satisfy a hold threshold); and
holding the mobile deposit check based on determining that the initial acceptance probability (does not satisfy the hold threshold).
(see at least: Yoshida ibidem and citations listed above to include ‘an initial acceptance probability’ and ‘a mobile deposit check’)
(see at least: Thasanon ibidem and citations listed above to include ‘a final acceptance probability’ and ‘does not satisfy a second acceptance threshold’)
Yoshida and Thasanon teach as disclosed above, but they may not explicitly disclose about ‘does not satisfy a/the hold threshold’. However, Franklin teaches them explicitly.
(see at least: Franklin Abstract; and para [0016] about {“...... For example, a hold may be placed on the check based on incomplete or inaccurate information. In current systems, the depositor's choices may be limited to cancelling the transaction, waiting for the hold to clear or contacting the bank for additional information. …… And, a third graphical indicator may display a status of post deposit activities (e.g., funds availability schedules, potential fraud, denial of funds, etc.). …”}; and para [0071] about {“…… As a result of the generated funds availability schedule, a status message 422 displays: “A five day hold will be placed on this check.” While not an error, this hold period may be fatal to a successful completion of the deposit process. …”}; and para [0075] about {“…… As shown, if insufficient funds exist to cover the amount of the check a status message 424 may be displayed to the depositor. The message may indicate a “hold” on the funds and provide an option for the depositor to contact the payor or simply cancel the remote deposit process. …”}; which together are the same as claimed limitations above to include ‘does not satisfy a/the hold threshold’ per BRI rules)
It would have been obvious prior to the time of the effective filing date of the claimed invention to have an ordinary person of skill in the art to modify the teachings of Yoshida and Thasanon with the teachings of Franklin. The motivation to combine these references would be to permit financial institutions that provide mobile banking apps via which a customer may deposit paper checks from virtually anywhere using their smartphone or tablet (see para [0001] of Yoshida), and to allow financial institutions for remote verification of identification documents to allow access to a service, product, and/or website, even though certain types of documents are sometimes not accepted for remote mobile deposit purposes or identity verification (see para [0001] of Thasanon), and to allow financial institutions provide evolving ways to make online banking and digital money management more convenient for users (see para [0001] of Franklin).
Dependent Claim 6 is rejected under 35 USC 103 as unpatentable over Yoshida and Thasanon as applied to the rejection of independent Claim 1 above, and further in view of Pub. No. US 2023/ 0281629 filed by Shevyrev et al. (hereinafter “Shevyrev”), and as described below for each claim/ limitation.
With respect to Claim 6, Yoshida and Thasanon teach ---
6. The computer-implemented method of claim 1, further comprising:
providing check image data extracted from the first mobile check image to an image
data verification system;
receiving, from the image data verification system, verified check data for the mobile deposit check; and
(see at least: Yoshida ibidem and citations listed above to include ‘a mobile deposit check’ and ‘an initial acceptance probability’; and para [0041] about {“…… OCR processing may include, but is not limited to, verification of data extracted from fields of the check based on a comparison with historical customer account data found in the customer's account (e.g., customer account 408) or the payer's account. …”}; and para [0083] about {“In a non-limiting example, OCR of a check image may identify the MICR data as a verified data field that may be used to access a customer's account 408. …”}; which together are the same as claimed limitations above to include ‘an/the image data verification system’ and ‘verified check data’ per BRI rules)
(see at least: Thasanon ibidem and citations listed above to include ‘a final acceptance probability’)
Yoshida and Thasanon teach ---
generating the initial acceptance probability utilizing [[an]] a trained acceptance probability machine learning model that processes the verified check data, ,wherein the trained acceptance probability machine learning model is trained to (analyze mobile check data) and restrictive endorsement data to determine the initial acceptance probability.
(see at least: Yoshida ibidem and citations listed above to include ‘an initial acceptance probability’ and ‘verified check data’; and Abstract for ‘a predictive machine learning (ML) model; and para [0008] about {“FIG.6 illustrates an example flow diagram of a machine learning (ML) system, according to some embodiments.”}; and para [0022] about {“Machine learning algorithms may build a model based on sample data, known as “training data,” in order to make predictions or decisions without being explicitly programmed to do so. …”}; and para [0023] about {“A machine learning engine (e.g., operating on ML platform 329) may use various classifiers to map concepts associated with a specific image capture/OCR process to capture relationships between concepts (e.g., device movement data vs. OCR processing success). …”}; and para [0024] about {“In some embodiments, machine learning models may be trained on a remote machine learning platform (e.g., ML platform 329) using other customer's transactional information (e.g., previously submitted deposit check images and OCR processing results). …”}; and para [0026] about {“In some embodiments, the ML engine may operate on, and machine learning models may be trained on, a mobile machine learning platform (e.g., mobile ML platform 310). In such embodiments, the machine learning models may be trained on a single customer's transactional information (e.g., previously submitted deposit check images and OCR processing results).”}; which together are the same as claimed limitations above to include ‘[[an]] a trained acceptance probability machine learning model’ per BRI rules)
(see at least: Thasanon ibidem and citations listed above to include ‘a final acceptance probability’)
Yoshida and Thasanon teach as disclosed above, but they may not explicitly disclose about ‘analyze mobile check data’. However, Shevyrev teaches them explicitly.
(see at least: Shevyrev Abstract and Brief Summary in paras [0004]-[0006]; and para [0017]
about {“This disclosure describes one or more embodiments of a mobile check deposit system that in real time (or near real time) predicts whether an initiated network transaction (e.g., mobile check deposit) is fraudulent based on a machine-learning model that intelligently weights features associated with the network transaction. For example, in less than a hundred millisecond latency, the mobile check deposit system can determine a mobile check deposit is fraudulent from image-based check data, network account data, historical transactions, and other features.… … Moreover, by utilizing a machine-learning model to analyze these and other features, the mobile check deposit system can intelligently adapt to new fraud schemes, changes to fraud behavior, etc. …”}; which together are the same as claimed limitations above to include ‘analyze mobile check data’)
It would have been obvious prior to the time of the effective filing date of the claimed invention to have an ordinary person of skill in the art to modify the teachings of Yoshida and Thasanon with the teachings of Franklin. The motivation to combine these references would be to permit financial institutions that provide mobile banking apps via which a customer may deposit paper checks from virtually anywhere using their smartphone or tablet (see para [0001] of Yoshida), and to allow financial institutions for remote verification of identification documents to allow access to a service, product, and/or website, even though certain types of documents are sometimes not accepted for remote mobile deposit purposes or identity verification (see para [0001] of Thasanon), and to prevent hackers trying to simulate the features of an authorized or legitimate transaction, computing systems that apply rigid computing models (e.g., heuristics) often cannot detect the difference between fraudulent and non-fraudulent features for mobile check deposits (see para [0002] of Shevyrev).
With respect to Claims 8-14, the limitations of these non-transitory computer-readable medium claims method claims are rejected under 35 USC 103 based on the exemplary analysis above for the rejection of method Claims 1-7 as described above using cited references of Yoshida, Thasanon, Coleman, Franklin and Shevyrev, because the limitations of these non-transitory computer-readable medium Claims 8-14 are commensurate in scope to limitations, and thus duplicates, of the above rejected method Claims 1-7 as described above.
With respect to Claims 15-20, the limitations of these system claims are rejected under 35 USC 103 based on the exemplary analysis above for the rejection of method Claims 1-7 as described above using cited references of Yoshida, Thasanon, Coleman, Franklin and Shevyrev, because the limitations of these system Claims 15-20 are commensurate in scope to limitations, and thus duplicates, of the above rejected method Claims 1-7 as described above.
Response to Arguments
Applicant's remarks (pages 8--13) and claim amendments dated 12 AUGUST 2026 with respect to the rejection of amended Claims 1-20 have been carefully considered, but they are not persuasive and do not put these amended claims in a condition ready for Allowance. Thus, the rejection of amended Claims 1-20, as described above, is being maintained herein with some modifications in this Office Action, where needed to provide clarification in response to the Applicant’s claim amendments and remarks by adding new Shevyrev reference that has been added in response to the Applicant’s latest claim amendments (on 08/12/2026).
Applicant's arguments with respect to rejection of Claims 1-20 under 35 USC 103 have been considered, but they are moot in view of the new ground/s of rejection (Shevyrev reference), which was necessitated by the Applicant's ‘amendments to the claims’ and/or arguments. See MPEP §706.07(a).
In response to the Applicant’s latest arguments against the rejection under 35 USC 101, Examiner respectfully disagrees. Also, Examiner clarifies that the instant application is nothing more than an improvement of an abstract idea, wherein using technology/ computers to execute an abstract idea is at most an improvement to the abstract idea.
In response to the Applicant’s arguments of 08/12/2026 against 101 rejection, Examiner respectfully disagrees with the Applicant’s arguments --- {“The claims recite a specific, unconventional ordered combination of limitations: receiving a first image, determining an initial probability from that first image alone, and based on that determination, requesting a second image. As noted in the Specification (112-3),……”}. Examiner notes that the Specification’s paras [0112]-[0113] don’t recite a novelty nor do these paras recite an “ordered combination”.
In additional response to the Applicant’s arguments of 08/12/2026 against the rejection under 35 USC 101, Examiner respectfully disagrees with arguments that the instant application is similar to Ex Parte Desjardins argued as -- {“Similarly, Applicant's claim recites the specific steps of receiving and processing a first image to determine an initial acceptance probability prior to selectively requesting a second image. This achieves the technical benefits from the specification of reduced processor downtime, avoidance of bottlenecks, and conservation of computational resources.”}. Examiner notes that in Ex Parte Desjardins, it was found --- {“The Appeals Review Panel (ARP) overall credited benefits including reduced storage, reduced system complexity and streamlining, and preservation of performance attributes associated with earlier tasks during subsequent computational tasks as technological improvements that were disclosed in the patent application specification.”}. However, the instant application’s Specification does not recite nor support limitations of “reduced processor capacity” and/or “reduced memory capacity”. It is noted by Examiner that the Specification has no support for the phrases from the Ex Parte Desjardins findings about “reduced storage”, “reduced system complexity” and “streamlining”, and the Specification does not support “system complexity” nor “less storage”.
In response to the Applicant’s arguments of 08/12/2026 traversing the rejection under 35 USC 101, Examiner respectfully disagrees with the Applicant’s arguments claiming that In Re: McRo applies to the instant application. Examiner notes that the current application is not similar to McRo, because the claims in McRo are focused on a specific asserted improvement in computer animation, i.e., the automatic use of rules of a particular type. Those claims do not simply use a computer as a tool to automate conventional activity, it is the incorporation of the claimed rules, not the use of the computer, that “improved existing technological process” by allowing the automation of further tasks. Further, an improvement in computer related technology can be improvement to computer itself or steps/functions that allow a computer to perform a function it could not perform before the invention. The current invention is not related to an improvement in technology but rather uses the computer as a tool to apply the abstract idea.
In response to the Applicant traversing 103 rejection by arguing on 08/12/2026 --- {“The cited combination of Yoshida and Thasanon fails to teach or suggest the conditional multi-stage request of a second mobile check image. In particular, the Office Action relies on paragraphs [0157] and [0158] of Yoshida to allegedly teach "requesting, based on determining the initial acceptance probability, a second mobile check image from the client device portraying a second side of the mobile deposit check."”}, and Examiner respectfully disagrees. Examiner notes that the claims listing of 08/12/2026 does not recite “conditional multi-stage request”; and furthermore, Examiner notes that in the last non-final Office Action of 03/12/2026, on pages 11-12, it clearly states --- {“(see at least: Yoshida ibidem and citations listed above to include ‘a client device’ and ‘an initial acceptance probability’; and para [0157] about {“Step 702 may include categorizing a collection of check images (e.g., image collection 602) into a first plurality of check images (e.g., pass images 608) that have successfully been processed via OCR to obtain deposit data and a second plurality of check images (e.g., fail images 610) that have failed OCR processing. Step 702 may include associating categorization data (e.g., via labels as described with respect to FIG. 6) with each of the first plurality of check images and each of the second plurality of check images.”}; and para [0158] about {“Step 704 may include providing the first plurality of check images, the second plurality of check images, and the categorization data to an untrained or partially trained machine learning (ML) model to obtain a further trained ML model (e.g., confidence model 612).”}; and para [0217]; which together are the same as claimed limitations above to include ‘a second mobile check image’ portraying ‘a second side’ per BRI rules)”}; which clearly shows that ‘a client device’ and ‘an initial acceptance probability’ were already rejected prior to recitation of argued limitation at the bottom of page 11 in last non-final Office Action. Thus, the Applicant’s arguments are moot.
In further response to the Applicant traversing 103 rejection by arguing on 08/12/2026 --- {“While Yoshida mentions front and back images elsewhere in its disclosure (e.g., at paragraph [0089]), it does not disclose that a request for the back image is triggered by or based on an initial acceptance probability of the front image.”}; & Examiner respectfully disagrees with this argument. Examiner notes that in middle of Page 12 of the last non-final Office Action, it is clearly stated --- {“Yoshida teaches --- determining, based on the first mobile check image, an initial acceptance probability for the mobile deposit check; (see at least: Yoshida ibidem and citations listed above to include ‘a first mobile check image’ and ‘a mobile deposit check’; and para [0019] about {“…… Upon being provided an image of a check, the predictive ML model may be configured to provide a likelihood the check image will be successfully processed via OCR (e.g., a confidence score). Using the confidence score or other indication of the likelihood from the predictive ML model, a mobile banking app operating on the customer's mobile device may provide an image acceptance status to the customer via a user interface (UI). …”}; and para [0021] about {“…… In such embodiments, the predictive ML model may still determine a likelihood of successful OCR processing prior to forwarding an image for further processing. In such embodiments, an image acceptance status may also be provided to a customer in real-time via a UI.”}; and para [0074] about {“In some embodiments, image acceptance status 416 may include instructions that may be based on a diagnostic of the image run by a diagnostic ML model (e.g., diagnostic model 614 discussed with respect to FIG. 6). …”}; and para [0109] about {“In some embodiments, when a financial instrument type acceptability confidence score that indicates a likelihood the financial instrument image depicts an acceptable financial instrument type is used, the predetermined threshold related to financial instrument type acceptability certainty may be from 50% to 100%, including subranges. …”}; and para [0167] about {“In some embodiments, method 700 may include providing instructions to a user (e.g., via image acceptance status 416) to modify a condition of image capture based on a value of a parameter associated with a check image captured prior to the deposit check image. …”}; which together are the same as claimed limitations above to include ‘an initial acceptance probability’ per BRI rules)”}; wherein the word “likelihood” taught by Yoshida is a synonym for claimed “probability”, and accepted as equivalent per BRI rules. Additionally, the Applicant has traversed 103 rejection by arguing --- {“Furthermore, the cited art fails to teach determining a final acceptance probability based on both the first and second mobile check images.”}; and Examiner respectfully disagrees by noting that Yoshida’s para [0053] teaches about multiple images --- {“and para [0053] for ‘image memory 312 to assess the likelihood the one or more images will be able to be successfully processed via OCR’;”}. Thus, the Applicant’s arguments are moot.
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office Action. Accordingly, THIS ACTION IS MADE FINAL. See at least MPEP §706.07(a). 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.
The prior art made of record and not relied upon, listed in Form 892, that is considered pertinent to the Applicant's disclosure and review for not traversing already issued patents and/or claimed inventions by the claims of the current invention of the Applicant. Please note that Form 892 contains more references than those cited in the rejection above under 35 USC 103, and all the references cited on said Form 892 are relevant to this application that form a part of the body of prior art.
The Examiner has pointed out particular references contained in the prior art of record in the body of this action for the convenience of the Applicant. Although the specified citations are representative of the teachings in the art and are applied to the specific limitations within the individual claim, other passages and figures may apply as well. The Applicant should consider the entire prior art as applicable as to the limitations of the claims; and said prior art includes references with synonyms for terms used in the claims that have been interpreted under the BRI (broad reasonable interpretation) procedures of the Office. It is respectfully requested from the Applicant, in preparing the response, to consider fully the entire references as potentially teaching all or part of the claimed invention, as well as the context of the passage as taught by the prior art or disclosed by the Examiner.
Any inquiry concerning this communication or earlier communications from the Examiner should be directed to Sanjeev Malhotra whose telephone number is (571) 272-7292. The Examiner can normally be reached during Monday-Friday between 8:30-17:00 hours on a Flexible schedule.
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/S.M./
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sanjeev.malhotra@uspto.gov
/ABHISHEK VYAS/Supervisory Patent Examiner, Art Unit 3691
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