DETAILED ACTION
This action is in response to the amendment filed 22 May 2026.
Claims 1 – 20 are pending and have been examined.
This action has been made FINAL.
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 .
Response to Arguments
Applicant's arguments filed 22 May 2026 have been fully considered but they are not persuasive.
Applicant argues “Claim 1 recites a specific technological application that uses computer processing of transaction data to generate concrete predictive outputs and to present those outputs through a particular graphical user interface arrangement. After resolving a named entity using pending and cleared transaction data, claim 1 further requires determining that the different named entity is associated with a recurring series of transactions, identifying a last recurring transaction and a recurring period, determining a predicted upcoming transaction date, determining a predicted upcoming transaction amount from historical payment amounts, and causing a graphical user interface to display the predicted upcoming transaction date, the predicted upcoming transaction amount, and a user-selectable control configured to receive user input modifying information associated with the different named entity. These limitations do not merely recite a generalized result of organizing business information. Rather, they integrate the recited data analysis into a concrete human-machine interface that is specifically driven by machine-generated prediction outputs, thereby imposing a meaningful limit on any alleged abstract idea and amounting to a practical application under Prong Two of Step 2A.”. Examiner respectfully disagrees.
Applicant argues that “[t]hese limitations do not merely recite a generalized result of organizing business information. Rather, they integrate the recited data analysis into a concrete human-machine interface that is specifically driven by machine-generated prediction outputs, thereby imposing a meaningful limit on any alleged abstract idea and amounting to a practical application under Prong Two of Step 2A”, however this alleged improvement is not supported by the claim language, nor the disclosure. Using a Graphical User Interface (GUI) to enter in or modify information is not, in itself, a practical application, as it is amounts to insignificant extra-solution activity, such as data gathering through well known means, such as a GUI. See MPEP 2106.05(g) Further, Applicant’s specification does not appear to make any improvements to said GUI or to how data is collected through a GUI. See also MPEP 2106.05(a)1.
Further, while Applicant’ argues “machine-generated prediction outputs”, this feature is not apparent in at least claims 1 – 8, as there is no explicit recitation of any machine, computer, or hardware performing any prediction. However, in respect to claims 9 – 16 and 17 – 20, while a computer readable medium and / or a system are claimed, these amount to merely applying the judicial exception using a computer. See MPEP 2106.05(f).
Applicant further argues “Claim 1 is also related to a technical problem arising in computerized transaction-management environments: transaction records often contain incomplete or unstructured pending data, and later-arriving cleared data may change entity identification, which in turn affects whether recurring transactions can be recognized and surfaced in a usable interface. Claim 1 recites a technical solution to that problem by requiring a particular sequence of computer operations that begins with assigning and then reassigning the transaction based on updated cleared transaction data, and then uses the corrected entity association as the basis for recurring-series detection, prediction of an upcoming transaction date, prediction of an upcoming transaction amount, and GUI presentation with an interactive control. This is not a case where a claim merely states a business objective and leaves implementation to a generic computer. The claim instead ties the processing steps to a specific improvement in how computerized platforms analyze transaction streams and present forward-looking transaction information to users in an operational interface, which is a practical application of any alleged judicial exception.”. Examiner respectfully disagrees.
It is initially noted that, as remarked above, claim 1 fails to disclose any computer hardware performing any of the claim limitations.
While Applicant argues the claims are related to a technical problem arising in computerized transaction-management environments: transaction records often contain incomplete or unstructured pending data, and later-arriving cleared data may change entity identification, which in turn affects whether recurring transactions can be recognized and surfaced in a usable interface, and that claim 1 recites a technical solution to that problem by requiring a particular sequence of computer operations that begins with assigning and then reassigning the transaction based on updated cleared transaction data, and then uses the corrected entity association as the basis for recurring-series detection, prediction of an upcoming transaction date, prediction of an upcoming transaction amount, and GUI presentation with an interactive control, however these limitations fail to provide for an improvement to any technical field. The limitations described in the arguments (e.g., a particular sequence of computer operations that begins with assigning and then reassigning the transaction based on updated cleared transaction data, and then uses the corrected entity association as the basis for recurring-series detection, prediction of an upcoming transaction date, prediction of an upcoming transaction amount), these limitations are found to be a part of the judicial exception itself (see 35 USC 101 rejection in the Non-Final and in the document, below).
As further shown in the updated 101 rejection, below, the only additional elements in the independent claim 1 are receiving pending transaction data associated with a transaction and a client of a software-as-a-service (SaaS) platform, the pending transaction data including a transaction identifier and unstructured data with an unprocessed named entity; receiving cleared transaction data associated with the transaction and the client of the SaaS platform, the cleared transaction data including the transaction identifier and additional information; and a graphical user interface to display, for the different named entity, at least the predicted upcoming transaction date, the predicted upcoming transaction amount, and a user-selectable control configured to receive a user input modifying information associated with the different named entity, and none of these additional elements provide for an integration of the judicial exception into a practical application.
As stated in the MPEP 2106.05(a): “It is important to note, the judicial exception alone cannot provide the improvement. The improvement can be provided by one or more additional elements. See the discussion of Diamond v. Diehr, 450 U.S. 175, 187 and 191-92, 209 USPQ 1, 10 (1981)) in subsection II, below. In addition, the improvement can be provided by the additional element(s) in combination with the recited judicial exception.” “If it is asserted that the invention improves upon conventional functioning of a computer, or upon conventional technology or technological processes, a technical explanation as to how to implement the invention should be present in the specification. That is, the disclosure must provide sufficient details such that one of ordinary skill in the art would recognize the claimed invention as providing an improvement. 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 but 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 the claim improves technology. An indication that the claimed invention provides an improvement can include a discussion in the specification that identifies a technical problem and explains the details of an unconventional technical solution expressed in the claim, or identifies technical improvements realized by the claim over the prior art” (emphasis added).
The 35 USC 101 rejection 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.
Claims 1 – 20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter. The claimed invention, when the claims are taken as a whole, is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
Step 2A – 1: The claims recite a Judicial Exception. Exemplary independent claim 1 recites the limitations of:
receiving pending transaction data associated with a transaction and a client of a software-as-a-service (SaaS) platform, the pending transaction data including a transaction identifier and unstructured data with an unprocessed named entity;
determining whether the transaction can be assigned to an existing named entity based on the pending transaction data and one or more named entity identification rules;
responsive to determining that the transaction cannot be assigned to an existing named entity, performing an Internet search to determine a candidate named entity to which the transaction can be assigned;
assigning the transaction to the candidate named entity;
receiving cleared transaction data associated with the transaction and the client of the SaaS platform, the cleared transaction data including the transaction identifier and additional information;
reassigning the transaction to a different named entity based on the cleared transaction data;
determining that the different named entity is associated with a recurring series of transactions based on transaction data corresponding to the different named entity;
identifying a last recurring transaction in the recurring series of transactions and a recurring period for the recurring series of transactions;
determining, based on the last recurring transaction and the recurring period, a predicted upcoming transaction date for a future transaction associated with the different named entity;
determining a predicted upcoming transaction amount for the future transaction based on one or more historical payment amounts associated with the recurring series of transactions; and
causing a graphical user interface to display, for the different named entity, at least the predicted upcoming transaction date, the predicted upcoming transaction amount, and a user-selectable control configured to receive a user input modifying information associated with the different named entity.
These limitations (bolded and italicized), as drafted, are a process that, under its broadest reasonable interpretation, covers certain methods of organizing human activity, e.g., managing interactions between people, and further fall with the mental process groupings as they can performed in the human mind, including observation, evaluation, judgment, and opinion. See MPEP §§2106.04(a)(2) II. and MPEP 2106.04(a)(2) III. For example, the claim limitations determining whether the transaction can be assigned to an existing named entity based on the pending transaction data and one or more named entity identification rules, assigning the transaction to the candidate named entity, and reassigning the transaction to a different named entity based on the cleared transaction data all deal with assigning labels having to do with transactions to entities, such as merchant names, which can be considered both fundamental economic activities and managing interactions between people / entities, both of which fall under certain methods of organizing human activity2.
Additionally, the claim limitations of determining whether the transaction can be assigned to an existing named entity based on the pending transaction data and one or more named entity identification rules, responsive to determining that the transaction cannot be assigned to an existing named entity, performing an Internet search to determine a candidate named entity to which the transaction can be assigned, assigning the transaction to the candidate named entity and reassigning the transaction to a different named entity based on the cleared transaction data, determining that the different named entity is associated with a recurring series of transactions, identifying a last recurring transaction in the recurring series of transactions, determining, based on the last recurring transaction and the recurring period, a predicted upcoming transaction date, and determining a predicted upcoming transaction amount can all be performed using observation, evaluation, judgment, and opinion, which falls under the mental process grouping.
“Unless it is clear that a claim recites distinct exceptions, such as a law of nature and an abstract idea, care should be taken not to parse the claim into multiple exceptions, particularly in claims involving abstract ideas.” MPEP 2106.04, subsection II.B. However, if possible, the examiner should consider the limitations together as a single abstract idea rather than as a plurality of separate abstract ideas to be analyzed individually. “For example, in a claim that includes a series of steps that recite mental steps as well as a mathematical calculation, an examiner should identify the claim as reciting both a mental process and a mathematical concept for Step 2A, Prong One to make the analysis clear on the record.” MPEP 2106.04, subsection II.B. Under such circumstances, however, the Supreme Court has treated such claims in the same manner as claims reciting a single judicial exception. Id. (discussing Bilski v. Kappos, 561 U.S. 593 (2010)). The highlighted and bolded limitations are considered together as a single abstract idea for further analysis.
Step 2A – 2: This judicial exception is not integrated into a practical application, and the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. Exemplary claim 1 recites the additional limitations of receiving pending transaction data associated with a transaction and a client of a software-as-a-service (SaaS) platform, the pending transaction data including a transaction identifier and unstructured data with an unprocessed named entity and receiving cleared transaction data associated with the transaction and the client of the SaaS platform, the cleared transaction data including the transaction identifier and additional information, however these are recited at a high level of generalization, i.e., the claims put no limits or details on how the data is received (noting that the data is not even claimed as being received by a computer or over a network, for example), and as such are insignificant extra-solution activity. See MPEP 2106.05(g)3. Claim further recites the limitation of a graphical user interface to display… a user-selectable control configured to receive a user input modifying information associated with the different named entity.
Independent claim 9 recites the additional limitation of one or more non-transitory computer readable media configured to store computer code comprising instructions, however this is recited at a high level of generality, and amounts to no more than mere instructions to apply the exception using a generic computer. See MPEP 2106.05(f).
Independent claim 17 recites the additional limitations of a software-as-a-service (SaaS) platform and a computing server in communication with the SaaS platform, the computing server comprising a processor and a memory, however these are also recited at a high level of generality, and are merely used as tools on which to perform the abstract idea. See MPEP 2106.05(f).
Further, the claims do not provide for or recite any improvements to the functioning of a computer, or to any other technology or technical field; applying or using a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition; applying the judicial exception with, or by use of, a particular machine; effecting a transformation or reduction of a particular article to a different state or thing; or applying or using the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception.
The claim is directed to the abstract idea.
The dependent claims have the same deficiencies as their parent claims as being directed towards an abstract idea, as the dependent claims merely narrow the scope of their parent claims, and it has been held that “[i]n defining the excluded categories, the Court has ruled that the exclusion applies if a claim involves a natural law or phenomenon or abstract idea, even if the particular natural law or phenomenon or abstract idea at issue is narrow.” (buySAFE, Inc. v. Google, Inc., 765 F.3d 1350. )
Turning to the dependent claims, none of the claimed features of the dependent claims further limit the claimed invention in such a way to direct the claimed invention to statutory subject matter (e.g. change the scope of the claimed invention as to no longer be directed towards an abstract idea, or include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements or combination of elements in the claims other than the abstract idea per se), nor do they add limitations that, when taken as a combination, result in the claim as a whole amounting to significantly more than the judicial exception. In respect to exemplary dependent claims 2 – 8:
Claims 2 – 4 merely further describes the determining step;
Claim 5 merely further describes the received data;
Claims 6 and 7 merely further describe the internet search step;
Claim 8 recites an additional judicial exception step;
Step 2B: The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, explained with respect to Step 2A, Prong Two, the additional elements or combination of elements in the claims other than the abstract idea per se amount to no more than mere instructions to implement the idea on a computer, or the recitation of generic computer structure that serves to perform generic computer functions previously known to the industry4 [e.g. performing repetitive calculations; receiving, processing, and storing data; electronically scanning or extracting data from a physical document; electronic recordkeeping; automating mental tasks; receiving or transmitting data over a network, e.g., using the Internet to gather data] .
Applicant’s specification, at, e.g., paragraphs [0036], [0058], [0112], FIG. 2, provides evidence of generic computer hardware performing generic, well-known, computer functions.
Viewed as a whole, these additional claim elements, both individually and in combination, do not provide meaningful limitations to transform the above identified abstract idea into a patent eligible application of the abstract idea such that the claims amount to significantly more (e.g. improvements to another technology or technical fields, improvements to the functioning of the computer itself, or meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment) than the abstract idea itself. Thus, taken alone, the additional elements do not amount to significantly more than the above-identified judicial exception (the abstract idea). Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. Their collective functions merely provide conventional computer implementation5.
Therefore, the claims are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter. See Alice Corporation Pty. Ltd. v. CLS Bank International, 573 U.S. No. 13–298.
Allowable Subject Matter
Claims 1 – 20 would be allowable if rewritten or amended to overcome the rejection under 35 U.S.C. 101, set forth in this Office action. See, e.g., parent Applications 17/390,701 and 18/461,405.
Conclusion
The prior art made of record and not relied upon considered pertinent to Applicant’s disclosure.
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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 ALAN S MILLER whose telephone number is (571)270-5288. The examiner can normally be reached on M-F 10am-6pm. Examiner’s fax phone number is (571) 270-6288.
Examiner interviews are available via telephone and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Beth Boswell can be reached at (571) 272-6737. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000.
/ALAN S MILLER/Primary Examiner, Art Unit 3625
1 MPEP 2106.05(a) “If it is asserted that the invention improves upon conventional functioning of a computer, or upon conventional technology or technological processes, a technical explanation as to how to implement the invention should be present in the specification. That is, the disclosure must provide sufficient details such that one of ordinary skill in the art would recognize the claimed invention as providing an improvement. 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 but 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 the claim improves technology. An indication that the claimed invention provides an improvement can include a discussion in the specification that identifies a technical problem and explains the details of an unconventional technical solution expressed in the claim, or identifies technical improvements realized by the claim over the prior art. For example, in McRO the court relied on the specification’s explanation of how the particular rules recited in the claim enabled the automation of specific animation tasks that previously could only be performed subjectively by humans, when determining that the claims were directed to improvements in computer animation instead of an abstract idea. McRO 837 F.3d at 1313-14, 120 USPQ2d at 1100-01. In contrast, the court in Affinity Labs of Tex. v. DirecTV, LLC relied on the specification’s failure to provide details regarding the manner in which the invention accomplished the alleged improvement when holding the claimed methods of delivering broadcast content to cellphones ineligible. 838 F.3d 1253, 1263-64, 120 USPQ2d 1201, 1207-08 (Fed. Cir. 2016)”.
2 In further respect to at least the causing a graphical user interface to display, see also Electric Power Group v Alstom S.A. No. 2015-1778 (Fed. Cir. 1 August 2016) (“Information as such is an intangible… Accordingly, we have treated collecting information, including when limited to particular content (which does not change its character as information), as within the realm of abstract ideas.… In a similar vein, we have treated analyzing information by steps people go through in their minds, or by mathematical algorithms, without more, as essentially mental processes within the abstract-idea category...And we have recognized that merely presenting the results of abstract processes of collecting and analyzing information, without more (such as identifying a particular tool for presentation), is abstract as an ancillary part of such collection and analysis...” (internal citations omitted) (emphasis added)).
3 It is noted that the two quoted receiving steps could possibly be considered as a part of the abstract idea itself, as noted by the CAFC in Electric Power Group v Alstom S.A. No. 2015-1778 (Fed. Cir. 1 August 2016), (“Information as such is an intangible…Accordingly, we have treated collecting information, including when limited to particular content (which does not change its character as information), as within the realm of abstract ideas…” (internal citations omitted) (emphasis added)).
4 “It is well-settled that mere recitation of concrete, tangible components is insufficient to confer patent eligibility to an otherwise abstract idea. Rather, the components must involve more than performance of “‘well understood, routine, conventional activit[ies]’ previously known to the industry.” Alice, 134 S. Ct. at 2359 (quoting Mayo, 132 S.Ct. at 1294)”. Id, pages 10-11. “Likewise, the server fails to add an inventive concept because it is simply a generic computer that “administer[ s]” digital images using a known “arbitrary data bank system.” Id. at col. 5 ll. 45–46. But “[f]or the role of a computer in a computer-implemented invention to be deemed meaningful in the context of this analysis, it must involve more than performance of ‘well-understood, routine, [and] conventional activities previously known to the industry.’” Content Extraction, 776 F.3d at 1347–48 (quoting Alice, 134 S. Ct at 2359). “These steps fall squarely within our precedent finding generic computer components insufficient to add an inventive concept to an otherwise abstract idea. Alice, 134 S. Ct. at 2360 (“Nearly every computer will include a ‘communications controller’ and a ‘data storage unit’ capable of performing the basic calculation, storage, and transmission functions required by the method claims.”); Content Extraction, 776 F.3d at 1345, 1348 (“storing information” into memory, and using a computer to “translate the shapes on a physical page into typeface characters,” insufficient confer patent eligibility); Mortg. Grader, 811 F.3d at 1324–25 (generic computer components such as an “interface,” “network,” and “database,” fail to satisfy the inventive concept requirement); Intellectual Ventures I, 792 F.3d at 1368 (a “database” and “a communication medium” “are all generic computer elements”); BuySAFE v. Google, Inc., 765 F.3d 1350, 1355 (Fed. Cir. 2014) (“That a computer receives and sends the information over a network—with no further specification—is not even arguably inventive.”)”. TLI Communications LLC v. AV Automotive L.L.C., (No. 15-1372, (Fed. Cir. May 17, 2016)), at *12-13.
See additionally MPEP 2106.05(d).
5 “Nor, in addressing the second step of Alice, does claiming the improved speed or efficiency inherent with applying the abstract idea on a computer provide a sufficient inventive concept. See Bancorp Servs., LLC v. Sun Life Assurance Co. of Can., 687 F.3d 1266, 1278 (Fed. Cir. 2012) (“[T]he fact that the required calculations could be performed more efficiently via a computer does not materially alter the patent eligibility of the claimed subject matter.”); CLS Bank, Int’l v. Alice Corp., 717 F.3d 1269, 1286 (Fed. Cir. 2013) (en banc) aff’d, 134 S. Ct. 2347 (2014) (“[S]imply appending generic computer functionality to lend speed or efficiency to the performance of an otherwise abstract concept does not meaningfully limit claim scope for purposes of patent eligibility.” (citations omitted))”. Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 115 U.S.P.Q.2d 1636 (Fed. Cir. 2015).
Prosecution Insights