DETAILED ACTION
This office action is in response to Applicant’s communication of 3/2/2026. Amendments to claims 1, 3-7, 10-16 and 18-20 have been entered. Claims 1-20 are pending and have been examined. The rejections and response to arguments are stated below.
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 .
Claim Rejections - 35 USC § 112
The following is a quotation of 35 U.S.C. 112(b):
(b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention.
The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph:
The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention.
Claims 1-5, 6-14 and 15-20 (1-20) are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention.
Claim 1, line 13 recites “by the payment network computer” (emphasis added). It is unclear if this “payment network computer” is the “a payment network” in line 3 above. As such there is insufficient antecedent basis for this limitation. Dependent claims 2-5 are rejected for being dependent on a rejected base claim.
Claim 6, line 4 recites “by the payment network computer” (emphasis added). There is insufficient antecedent basis for this limitation in the claim. Dependent claims 7-14 are rejected for being dependent on a rejected base claim.
Claim 15, line 4 recites “by the payment network computer” (emphasis added) There is insufficient antecedent basis for this limitation in the claim. Dependent claims 16-20 are rejected for being dependent on a rejected base claim.
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 an abstract idea without significantly more. The claims do fall within at least one of the four categories of patent eligible subject matter because claims 1, 6 and 15 are directed to a process; Step 1-yes.
Under Step 2A, prong 1, representative claim 1 recites a series of steps for determining if customer transaction authentication is complete, generating a bypass message to override a block instruction and forwarding an authorization request message to an issuer to approve the transaction based on authentication confirmation which is a fundamental economic practice, i.e. mitigating transaction risk, and commercial or legal interaction, i.e. sales activities, and thus grouped as “Certain Methods of Organizing Human Activity”. The claim as a whole and the limitations in combination recite this abstract idea. Specifically, the limitations of representative claim 1, in bold below, recite the abstract idea as follows.
1. (Currently Amended) A method comprising:
receiving, by a payment network and from a merchant computer, an authorization request message comprising customer authentication information, the customer authentication information having been received by the merchant computer from a user device during a transaction;
determining, by the payment network based on the customer authentication information, whether transaction authentication is complete;
generating, by the payment network computer, a transaction bypass message to override a block instruction, wherein the transaction bypass message includes at least a portion of the customer authentication information and directs the payment network computer to forward an authorization request message for the transaction to an issuer for approval, while the block remains in place until issuer approval; and
transmitting, by the payment network computer, the transaction bypass message to the issuer to prompt the issuer to approve the transaction based on the transaction authentication being confirmed as complete.
Independent claim 6 is analyzed in the same manner although the issuer can approve or decline the transaction.
Independent claim 15 is analyzed in the same manner with the final step being the abstract idea of “removing, by the payment network computer, the user-imposed block on the merchant based on the transaction bypass.”
The claimed limitations, identified above, recite a process that, under its broadest reasonable interpretation, covers performance of a fundamental economic practice and commercial or legal interaction, but for the recitation of generic computer components. That is, other than the mere nominal recitation of a “payment network”, a “merchant computer”, a user “device” and a “payment network computer” in claim 1, a “computer-implemented” method, the “payment network computer” and a merchant “computer” in claim 6 and a “computer-implemented” method, the “payment network computer”, a merchant “computer”, a user “device”, there is nothing in the claim element which takes the steps out of the methods of organizing human activity abstract idea grouping. Thus, claim 1 as well as claims 6 and 15 recite an abstract idea.
Under step 2A, prong 2, this judicial exception is not integrated into a practical application. In particular, the claim only recites using generic, commercially available, off-the-shelf computing devices, i.e. processors suitably programmed communicating over a generic network, to perform the steps of receiving, determining, performing, declining, generating and transmitting in claim 1. The computer components are recited at a high-level of generality (i.e., as generic processors with memory suitably programmed communicating information over a generic network, see at least FIGs. 5, 6 and 7 and paragraphs [0060], any known payment network, [0067-0068], [0122], “The payment network 502, the issuer 504, the merchant 508, and the acquirer 510 include one or more than one computer apparatus 3000 described with reference to FIG. 6.”, [0132-0145] of the specification) such that it amounts no more than adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform the abstract idea, see MPEP 2106.05(f). Accordingly, the additional elements claimed do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Claim 1, as well as claims 6 and 15, are directed to an abstract idea.
Under step 2B, the claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements of using generic computer processors with memory suitably programmed communicating over a generic network to perform the limitation steps amounts no more than adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform the abstract idea, see MPEP 2106.05(f). Mere instructions to apply an exception using generic computer components interacting in a conventional manner cannot provide an inventive concept. Claims 1, 6 and 15 are not patent eligible.
For instance, in the process of claim 1, the limitation steps, claimed at a high level of generality, recite steps that are considered mere instructions to apply an exception akin to a commonplace business method or mathematical algorithm being applied on a general purpose computer, Alice Corp. Pty. Ltd.; Gottschalk and Versata Dev. Group, Inc.; see MPEP 2106.05(f)(2).
Applicant has leveraged generic computing elements to perform the abstract idea of determining if customer transaction authentication is complete, generating a bypass message to override a block instruction and forwarding an authorization request message to an issuer to approve the transaction based on authentication confirmation without significantly more.
Dependent claims 2-5, 7-14 and 16-20 when analyzed as a whole and in an ordered combination are held to be patent ineligible under 35 U.S.C. 101 because the additional recited limitation(s) fail(s) to establish that the claim(s) is/are not directed to an abstract idea, as detailed below. The additional recited limitations in the dependent claims only refine the abstract idea.
For instance, claims 2 and 19 further refine the abstract idea by receiving a message from the issuer indicating successful authentication or approval or decline of the transaction. This can be completed in a myriad of ways and provides no technical details. Claim 3 further refines the abstract idea by updating information in the message based on a received response and approving the transaction for processing. This can be completed through manual means. Claims 4, 7, 8, 13, 14 and 20 all further refine the abstract idea by either removing or maintaining the transaction block based on the issuers approval or denial and a security threshold being met. These limitations are claimed at a very high level of generality and there are no technical implementation details such that these limitations cannot be completed through mental and manual means. Claims 5 and 10 further refine the abstract idea by notifying the merchant the status of the block instruction. These limitations are recited at a very high level of generality with no technical implementation details other than applying on generic computer elements. Claim 9 further refines the abstract idea by merely receiving an authentication indicator representing a successful authentication of the user. The additional element of the user device is a generic computing device, made clear in the specification, on which this abstract concept is applied with nothing significantly more. Claim 11 further refines the abstract idea through reciting that a security threshold is maintained at a very high level of generality. Claim 12 further refines the abstract idea by receiving a message from which the authenticator indicator which is compared to the security threshold which can be completed through mental evaluation as well. Claim 16 recites generating a message containing the bypass and indicator at a very high level of generality further refining the abstract idea. Claim 17 merely defines the indicator as a strong customer authentication indicator. Examiner notes that a string customer authentication (SCA) indicator is a known security measure that requires two or more independent factors to verify a user’s identity, i.e. multi-factor authentication. As such, applicant has leveraged known security measures at a very high level of generality with nothing significantly more. Claim 18 further refines the abstract by transmitting a message to an issuer.
Clearly, the additional recited limitations in the dependent claim only refines the abstract idea further. Further refinement of an abstract idea does not convert an abstract idea into something concrete.
The claims merely amount to the application or instructions to apply the abstract idea (i.e. a series of steps for determining if customer transaction authentication is complete, generating a bypass message to override a block instruction and forwarding an authorization request message to an issuer to approve the transaction based on authentication confirmation) on one or more computers, and are considered to amount to nothing more than requiring a generic computer system (e.g. processors suitably programmed and communicating over a network) to merely carry out the abstract idea itself. As such, the claims, when considered as a whole, are nothing more than the instruction to implement the abstract idea (i.e. a series of steps for determining if customer transaction authentication is complete, generating a bypass message to override a block instruction and forwarding an authorization request message to an issuer to approve the transaction based on authentication confirmation) in a particular, albeit well-understood, routine and conventional technological environment.
Accordingly, the Examiner concludes that there are no meaningful limitations in the claims that transform the judicial exception into a patent eligible application such that the claims amount to significantly more than the judicial exception itself or integrate the judicial exception into a practical application.
Response to Arguments
Applicant’s arguments, see the Remarks filed 3/2/2026, with respect to the 35 U.S.C. 102/103 rejection of claims 1-20 have been fully considered and are persuasive. The previous 35 U.S.C. 102/103 rejection of claims 1-20 has been withdrawn.
Applicant’s arguments, see the Remarks filed 3/2/2026, with respect to the 35 U.S.C. 112(b) rejection of claims 10-20 have been fully considered and are persuasive. The previous 35 U.S.C. 112(b) rejection of claims 10-20 has been withdrawn. However, a new 35 U.S.C. 112(b) rejection of claims 1-20 is analyzed above.
Applicant’s arguments with respect to the 35 U.S.C. 101 rejection of claims 1-20 filed in the Remarks dated 3/2/2026 have been fully considered but they are not persuasive.
On page 8 of the Remarks, Applicant argues, ‘“The present invention, as defined by amended claim 1, addresses a problem that arises when a customer ("user") has requested a payment block against a merchant (for example, to stop unwanted recurring charges), but later wishes to conduct a legitimate transaction with that merchant. The invention enables the payment network to bypass and potentially remove such user- requested merchant blocks based on customer authentication information that is already present in the authorization request message received from the merchant. The claimed invention enables legitimate authenticated transactions to proceed despite the existence of a block instruction against the merchant.” Examiner respectfully disagrees.
Applicant is solving a business problem rooted in the abstract idea of determining if customer transaction authentication is complete, generating a bypass message to override a block instruction and forwarding an authorization request message to an issuer to approve the transaction based on authentication confirmation. This clearly falls under “Certain Methods of Organizing Human Activity” which is applied within a generic computing network interacting in a most conventional manner as seen in the analysis above.
On page 9 of the Remarks, Applicant argues ‘“In the claims, "generating a transaction bypass message is not a mental step or business rule"; it is a computer-generated network message with defined fields and semantics, used to modify how the payment network forwards and processes transactions. Under MPEP 2106.05(c) (improvements to another technology), this is a practical application that "improves the functioning" of a payment network.
Applicant asserts that the claim alters the functioning of the payment network itself. The claim modifies how the payment network behaves when a stop payment block is present. Without the invention as claimed, transactions from a blocked merchant are always declined. With the invention as claimed the payment network consults authentication data, generates a bypass message, forwards the transaction, and preserves the block until issuer approval. This is precisely the type of technological improvement recognized in DDR Holdings as integration into a practical application.” Examiner respectfully disagrees.
The limitation "generating a transaction bypass message is not a mental step or business rule" provides no technical implementation details in the claims or the specification as to “how” this modifies the system in a technical manner. It is merely information sent to the issuer for approval consideration to override a block instruction. As such, since this is claimed at a very high level of generality, human beings can certainly produce, through manual means, a bypass message, in a myriad of forms and communicated via a myriad of communication protocols, to an issuer for approval.
The Examiner does not see the parallel between the claims of the instant application and those of DDR Holdings. In DDR Holdings an improvement in web technology was used to address the problem of retaining web customers. DDR Holdings was solving a problem introduced by technology, such that it was a technological solution to a technological problem. Applicants’ invention is applying a solution via generic computing elements interacting in a most conventional manner as programmed to a problem rooted in an abstract idea. The claims of the instant case employ a computer system comprising a “payment network”, a “merchant computer”, a user “device” and a “payment network computer” to perform the claimed functions. In light of the Alice decision and the MPEP the features such as
“receiving, by a payment network and from a merchant computer, an authorization request message …… by the merchant computer from a user device during a transaction;”
“determining, by the payment network based on the customer authentication information, whether transaction authentication is complete;”
“generating, by the payment network computer, a transaction bypass message to override a block instruction, …… to forward an authorization request message for the transaction to an issuer for approval, ……;” and
“transmitting, by the payment network computer, the transaction bypass message to the issuer to prompt the issuer to approve the transaction ……”.
are not considered an improvement to another technology or technical field, or an improvement to the functioning of the computer itself. These features recited in the claim are only further refinements of the abstract idea. That does not change the fact that the claim is drawn to abstract ideas. There are no improvements to another technology or technical field, no improvements to the functioning of the computer itself, transformation or reduction of a particular article to a different state or thing or any other meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment as a result of performing the claimed method. As discussed earlier, the claimed steps of the method are all functions that are conventional for a computer system, which in the Applicant’s invention comprises a “payment network”, a “merchant computer”, a user “device” and a “payment network computer”. The claimed sequence of steps comprises only "steps, specified at a high level of generality," which is insufficient to supply an "inventive concept." Id. at 2357 (quoting Mayo, 132 S. Ct. at 1294, 1297, 1300). Also, the addition of merely novel or non-routine components to the claimed idea does not necessarily turn an abstraction into something concrete (See Ultramercial, Inc. v. Hulu, LLC, _ F.3d_, 2014 WL 5904902, (Fed. Cir. Nov. 14, 2014). In Alice the system was specifically programmed to perform the claimed functions.
On page 10 of the Remarks, Applicant argues ‘“Applicant asserts that the Examiner has not provided the required factual support under Berkheimer. Under Berkheimer v. HP, 881 F.3d 1360 (Fed. Cir. 2018), whether claim elements are "well-understood, routine, and conventional" is a question of fact requiring evidence. The Office Action provides no such evidence - only conclusory statements.
The coordination between the payment network and issuer is a technically relevant communication protocol that adds significantly more than the alleged abstract idea.
Applicant asserts that the specific ordered combination is non-conventional…..Even if individual components were known, Bascom holds that a non-conventional arrangement of known components can supply the inventive concept. Here, the block-state-machine architecture is not shown to be conventional.”’ Examiner respectfully disagrees.
The steps of the claims, taken individually or as an ordered combination, have been identified as corresponding to an abstract idea. The additional elements in the claims are a “payment network”, a “merchant computer”, a user “device” and a “payment network computer”. It is clear, through a plain reading of Applicant’s specification, that the computing processors are suitably programmed to perform the abstract idea, see at least FIGs. 5, 6 and 7 and paragraphs [0060], any known payment network, [0067-0068], [0122], “The payment network 502, the issuer 504, the merchant 508, and the acquirer 510 include one or more than one computer apparatus 3000 described with reference to FIG. 6.”, [0132-0145] of the specification. The claims at issue do not require any nonconventional computer, network, or other components, or even a non-conventional and non-generic arrangement of known, conventional pieces but merely call for performance of the claimed functions on a set of generic computer components. The elements of the instant process, when taken alone, each execute in a manner conventionally expected of these elements. The elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone.
According to the USPTO guidelines of April 19, 2018 incorporating the Berkheimer memo (Berkheimer memo, hereinafter),
In a step 2B analysis, an additional element (or combination of elements) is not well-understood, routine or conventional unless the examiner finds, and expressly supports a rejection in writing with, one or more of the following:
1. A citation to an express statement in the specification or to a statement made by an applicant during prosecution that demonstrates the well-understood, routine, conventional nature of the additional element(s).
2. A citation to one or more of the court decisions discussed in MPEP § 2106.05(d)(II) as noting the well-understood, routine, conventional nature of the additional element(s).
3. A citation to a publication that demonstrates the well-understood, routine, conventional nature of the additional element(s).
4. A statement that the examiner is taking official notice of the well-understood, routine, conventional nature of the additional elements). This option should be used only when the examiner is certain, based upon his or her personal knowledge, that the additional elements) represents well-understood, routine, conventional activity engaged in by those in the relevant art, in that the additional elements are widely prevalent or in common use in the relevant field, comparable to the types of activity or elements that are so well-known that they do not need to be described in detail in a patent application to satisfy 35 U.S.C. § 112(a).
The fact that a generic computing system such as described above can be suitably programmed, may be used to perform the claimed method and the claims at issue do not require any nonconventional computer, network, or other components, or even a “non- conventional and non-generic arrangement of known, conventional pieces” but instead merely call for performance of the claimed functions on a set of generic computer components, satisfies the Berkheimer memo requirement that the additional elements are conventional elements (as outlined in criterion 1 of the Berkheimer memo). The elements of the instant process, when taken alone, each execute in a manner conventionally expected of these elements. The elements of the instant process, when taken in combination, together do not offer substantially more than the sum of the functions of the elements when each is taken alone. Hence these additional elements do not add anything significantly more than an abstract idea.
The Examiner does not see the parallel between the claims of the instant case and those of Bascom. In Bascom, the claims describe a filtering system by providing customized filters at a remote server. Specifically, in Bascom an ISP server receives a request to access a website, associates the request with a particular user, and identifies the requested website. The filtering tool then applies the filtering mechanism associated with the particular user to the requested website to determine whether the user associated with that request is allowed access to the website. The filtering tool returns either the content of the website to the user, or a message to the user indicating that the request was denied. In Bascom another group of claims describe a hybrid filtering scheme implemented on the ISP server comprised of a master-inclusive list, an individual-customizable set of exclusive lists, and an individual-customizable set of inclusive lists. The focus of the claims in Bascom is on the specific asserted improvement in filtering technology by providing individually customizable filtering at the remote ISP server by taking advantage of the technical capability of certain communication networks. Specifically, the claimed invention in Bascom achieves other benefits over conventional filtering by providing Internet-content filtering in a manner that can be customized for a person attempting to access such content while avoiding the need for (potentially millions of) local servers or computers to perform such filtering and while being less susceptible to circumvention by the user, and structuring a filtering scheme not just to be effective, but also to make user-level customization administrable as users are added instead of becoming intractably complex. Hence, the Bascom claims are not directed to an abstract idea. On the other hand, Applicant’s claims do not involve any improvements to another technology, technical field, or improvements to the functioning of the computer itself. The invention in Bascom was a technological solution to a technological problem (using an improved filtering technology rather than using conventional filtering technology). Applicants’ invention is a business solution to a problem rooted in an abstract idea. The arrangement of allowing the system to receiving, ….. an authorization request message ……, determining…… whether transaction authentication is complete, generating, ……a transaction bypass message to override a block instruction, ……to forward an authorization request message for the transaction to an issuer for approval, ……, thereby transmitting, …… the transaction bypass message to the issuer to prompt the issuer to approve the transaction ……, is an improvement in the business process of determining if customer transaction authentication is complete, generating a bypass message to override a block instruction and forwarding an authorization request message to an issuer to approve the transaction based on authentication confirmation. It does not involve any improvements to another technology, technical field, or improvements to the functioning of the computer itself.
In light of the Alice decision and the guidance provided in the 2019 PEG, the features listed in the claims, are not considered an improvement to another technology or technical field, or an improvement to the functioning of the computer itself. At best these features may be considered to be a business solution, using computers, to a problem of determining if customer transaction authentication is complete, generating a bypass message to override a block instruction and forwarding an authorization request message to an issuer to approve the transaction based on authentication confirmation. The alleged benefits that Applicants argue are due to business decisions, using computers, rather than any improvement to another technology or technical field, or an improvement to the functioning of the computer itself. By relying on computing devices to perform routine tasks more quickly or more accurately is insufficient to render a claim patent eligible (See Alice, 134 S. Ct. at 2359 “use of a computer to create electronic records, track multiple transactions, and issue simultaneous instructions” is not an inventive concept). As discussed in the rejection above, the components of the instant system, when taken alone, each execute in a manner conventionally expected of these components. At best, Applicant has claimed features that may improve an abstract idea. However, an improved abstract idea is still abstract, (SAP America v. Investpic *2-3 (‘“We may assume that the techniques claimed are “groundbreaking, innovative, or even brilliant,” but that is not enough for eligibility. Association for Molecular Pathology v. Myriad Genetics, Inc., 569 U.S. 576, 591 (2013); accord buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1352 (Fed. Cir. 2014). Nor is it enough for subject-matter eligibility that claimed techniques be novel and nonobvious in light of prior art, passing muster under 35 U.S.C. §§ 102 and 103. See Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66, 89-90 (2012); Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 1151 (Fed. Cir. 2016) (“[A] claim for a new abstract idea is still an abstract idea.”)
There is a fundamental difference between computer functionality improvements, on the one hand, and uses of existing computers as tools to perform a particular task, on the other. There is nothing, for example, in the pending claims to suggest that the claimed processor(s) or memories are somehow made more efficient or that the manner in which these elements carry out their basic functions is otherwise improved in any way. The alleged advantages that Applicants argue do not concern an improvement in computer capabilities but instead relate to an alleged improvement in determining if customer transaction authentication is complete, generating a bypass message to override a block instruction and forwarding an authorization request message to an issuer to approve the transaction based on authentication confirmation, for which a computer is used as a tool in its ordinary capacity.
In summary, the computer is merely a platform on which the abstract idea is implemented. Simply executing an abstract concept on a computer does not render a computer “specialized,” nor does it transform a patent-ineligible claim into a patent-eligible one. See Bancorp Servs., LLC v. Sun Life Assurance Co. of Can., 687 F.3d 1266, 1280 (Fed. Cir. 2012). There are no improvements to another technology or technical field, no improvements to the functioning of the computer itself, transformation or reduction of a particular article to a different state or thing or any other meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment as a result of performing the claimed method. The claimed sequence of steps comprises only “conventional steps, specified at a high level of generality,” which is insufficient to supply an “inventive concept.” Id. at 2357 (quoting Mayo, 132 S. Ct. at 1294, 1297, 1300). Also, the addition of merely novel or non-routine components to the claimed idea does not necessarily turn an abstraction into something concrete (See Ultramercial, Inc. v. Hulu, LLC, _ F.3d_, 2014 WL 5904902, (Fed. Cir. Nov. 14, 2014). Hence the claims do not recite significantly more than an abstract idea.
For these reasons and those stated in the rejection above, rejection of claims 1-20 under 35 U.S.C. 101 is maintained by the Examiner.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure are listed on the enclosed PTO-892.
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 CHRISTOPHER J BRIDGES whose telephone number is (571)270-5451. The examiner can normally be reached 7:00am-3:30pm M-F EDT.
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/CHRISTOPHER BRIDGES/Primary Examiner, Art Unit 3693
Prosecution Insights