DETAILED ACTION
1. The present application, filed on or after March 13, 2013, is being examined under the first inventor to file provisions of the AIA .
This application claims priority to a provisional application filed October 20, 2023.
The IDS filed December 2, 2025 has been considered in this Application.
Claims 1 - 20 are pending and examined as follows:
NOTE: interviews are welcome at any stage of prosecution. Please use the AIR form, the link for which can be found at the end of this action, to schedule the interview.
Claim Rejections – 35 USC § 101
2. 35 USC § 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture and composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
A. Rejection Based on Abstract Idea
Claims 1 - 20 are rejected under 35 U.S.C. § 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. Furthermore, this rejection is based on the 2019 Revised Patent Subject Matter Eligibility Guidance (2019 PEG).
B. Statutory Categories
Claim 1 is a system Claim and also recites a server, a memory, and a processor and therefore falls into the category of machine/manufacture. Claim 12 is a method Claim and therefore falls into the category of a process. Claim 20 recites a non-transitory CRM and also falls into the category of machine/manufacture.
C. The Claim Recites an Abstract Idea
Claim 1 is illustrative of the rejection of all claims.
Claim 1 recites the limitation:
“5receive, from a first entity, transaction information of a transaction, wherein the transaction information is included in an International Organization for Standardization (ISO)-supported file; generate a transaction identifier for the transaction; transmit, to the first entity, the transaction identifier for the transaction; perform an anti-money laundering (AML) check based on the transaction information; apply a machine learning model to identify a pattern based on the transaction information;”
This limitation, as drafted, is a process that, under its broadest reasonable interpretation, constitutes a method of organizing human activity, specifically, fundamental economic principles or practices. That is, analyzing this limitation in the context of the claim as a whole, it recites a process that falls within the grouping of abstract ideas comprising certain methods of organizing human activity. Fundamental economic principles or practices are examples of such methods. In this case, the fundamental economic principle or practice is the common practice of using ISO standard formatted messages in international financial transactions and monitoring such transactions for fraud or money laundering. This common practice occurs millions of times every day in the financial arena.
Furthermore, the mere nominal recitation of terms - such as “server” or “processor,” or “memory” - does not remove the claim from the category of common or abstract methods of organizing human activity.
Thus, Claim 1 recites a judicial exception, namely, an abstract idea.
D. The Claim Does Not Integrate the Abstract Idea into a Practical Application
Moreover, this judicial exception is not integrated into a practical application. The possible “additional limitations” recited in the Claim that must be considered are as follows:
A system for performing cross-border transactions, comprising a computer server including a memory and a processor,
write the AML check and the pattern to the ISO-supported file;
receive the transaction identifier from a second entity;
transmit a transaction approval message to the second entity based on the AML check and the pattern.
No additional computer components are mentioned in these limitations, and those quoted above are recited at a high level of generality. No other particular computer functions or computer component interactions within this system are recited. Checking transactions for patterns or other indicators of fraud are common computerized functions. These are recited at a high level of generality. ISO supported file formats are used in millions of transaction messages every second. Transaction identifiers are also in common use.
Monitoring transactions, writing or recording/storing data, receiving identifiers and transmitting data are among the most common and generic computer functions. This is what computers do. There is no specificity nor special functionality assigned to these steps in the claim.
Analyzing these additional limitations individually, and taking the claim as a whole and as an ordered combination, it is clear that these additional limitations do not serve to integrate the abstract idea into a practical application. They do not recite a technological solution to a technological problem. They do not improve the functioning of the computer system itself. In fact, there are very few computerized system components or functions recited. Thus, these limitations fail to recite with specificity any technical function or any improvement to the functioning of the computer system itself – if any. Therefore, the claim lacks the specificity required to transform the claim from one claiming only an outcome or a result – detecting fraud and money laundering - to one claiming a specific way of achieving that outcome or result.
Accordingly, the recitation of these generic components amounts to no more than mere instructions “to apply” the abstract idea exception using generic computer components. That is, the additional elements recited in the claim beyond the judicial exception(s) have been evaluated to determine whether those additional elements, considered individually and in combination, integrate the judicial exception(s) into a practical application. They do not.
E. Step 2B: The Claim Does Not Recite Significantly More than the Abstract Idea
This step involves the search for an “inventive concept.” However, it is clear from the case law and the MPEP that the considerations at issue are the same as those considered above with respect to the analysis of a practical application. See MPEP 2106.05(a) – (c) and (e). In other words, these analyses sharply overlap.
Therefore, based on the above analysis, the identified additional limitations do not provide “significantly more” than the abstract idea. The claim is therefore ineligible under §101. The other independent claims are, likewise, ineligible for the same reasons as they are virtually identical to Claim 10.
F. The Dependent Claims Do Not Recite Meaningful Additional Limitations
Similarly, Claim 2 recites the same abstract idea as Claim 1 by virtue of its dependency on Claim 1. Like Claim 1, this claim does not recite sufficient additional elements to integrate the abstract idea into a practical application. Claim 2 merely recites the abstract concept of an originating agent.
Claim 3 merely recites the abstract concept of types of originating agents.
Claim 4 merely recites the abstract concept of a standard ISO format, namely, 20022.
Claim 5 merely recites the abstract concept of types of transaction information.
Claim 6 merely recites the abstract concept of additional types of transaction information.
Claim 7 merely recites the abstract concept of authentication and clearing a transaction.
Claim 8 merely recites the abstract concept of generating a fraud rate.
Claim 9 merely recites the abstract concept writing a fraud score to an ISO message.
Claim 10 merely recites the abstract concept of a pattern of fraud.
Claim 11 merely recites the abstract concept of flagging a transaction and raising an alert.
Claims 12 - 20 are virtually identical to various of the aforementioned claims and are ineligible for the same reasons as set forth above.
None of these claims provide any additional meaningful limitations, non-generic computer components, or specific assignments of functionality among those components. Likewise, if at all, these claims recite only generic, computer-related limitations which are recited at such a high level of generality as to be devoid of any meaningful limitations. These limitations do not recite improvements in the functioning of the computer or to any other technology or technical field.
Therefore, these claims do not include additional elements that are sufficient to integrate the abstract idea into a practical application, nor do they amount to significantly more than the recited abstract idea because the additional elements, when considered both individually and as an ordered combination, constitute only a mere instruction to “apply” the abstract idea.
Thus, Claims 1 - 20 constitute ineligible subject matter under 35 USC § 101 as being directed to an abstract idea without more.
Claim Rejections - 35 USC § 103
4. 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 of this title, 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.
Claims 1 - 20 are rejected under 35 U.S.C. §103 as being unpatentable over U.S. Patent Publication No. 2018/0101851 to Lowenberg et al. (hereinafter “Lowenberg”) in view of Non-Patent Literature to Anonymous, “What ISO 20022’s Extra Data Means in the Fights Against Fraud,” Nice Actimize, Fraud Prevention 2021(hereinafter “Actimize”)
The title of Lowenberg is: Method and system for identification of shared devices for fraud modeling
The Abstract reads as follows:
“A method for fraud modeling based on shared computing device usage includes: storing transaction data entries, each including a transaction date and/or time, account identifier, and device identifier associated with a computing device; receiving a transaction message for a payment transaction, the transaction message including a specific device identifier, primary account number, and additional transaction data; identifying transaction data entries where the included device identifier corresponds to the specific device identifier; determining a fraud risk rating based on a number of unique account identifiers included in the identified transaction data entries over a predetermined period of time; and transmitting the transaction message and the determined fraud risk rating to a financial institution associated with the primary account number.” (emphasis added)
Thus, Lowenberg is in the same field of endeavor as the claimed invention – the detection of fraud. This reference teaches the use of generating enhanced or enriched data pertaining to possible fraud in a transaction and “sharing” that with other parties to the transaction.
Thus, Fig. 2 is illustrative of these teachings:
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Lowenberg teaches the generation of a “fraud risk rating” and forwarding that information to another party to the transaction in a message formatted in accordance with ISO 20022:
“[0023] The system 100 may include a processing server 102. The processing server 102, discussed in more detail below, may be configured to identify fraud risk ratings and use fraud modeling based on the usage of a computing device 104 across multiple payment transactions. The computing device 104 may be used by one or more consumers 106 to conduct payment transactions. Each consumer 106 may have a transaction account associated therewith, issued to the consumer 106 by an issuing institution 108. The issuing institution 108 may be a financial institution, such as an issuing bank, or other entity configured to issue transaction accounts for use in funding payment transactions.
[0027] In some embodiments, the data may be formatted in a transaction message by the merchant system 110 or an intermediate entity. The transaction message may be a specially formatted data message formatted pursuant to one or more standards governing the exchange of financial transaction messages, such as the International Organization of Standardization's ISO 8583 or ISO 20022 standards. Each transaction message may include a message type indicator indicative of a type of the transaction message. Each transaction message may also include a plurality of data elements, where each data element stores transaction data for the payment transaction, such as the payment credentials, device identifier, etc. In some embodiments, a transaction message may also include one or more bitmaps, where each bitmap indicates the data elements included in the transaction message and the data stored therein.
[0028] The payment network 112 may receive the transaction message and may forward the transaction message to the processing server 102. In some embodiments, the processing server 102 may be external to the payment network 112, and may receive the transaction message via external communication methods, such as using the payment rails associated with the payment network 112. In other embodiments, the processing server 102 may be a part of the payment network 112, and may receive the transaction message via internal communication methods, such as a local area network of the payment network 112. The processing server 102 may determine a fraud risk rating for the payment transaction, based on the computing device 104 used in the payment transaction and past usage of the computing device 104 across other payment transactions.” (Emphasis Added)
Therefore, Lowenberg in view of Actimize teaches:
1. A system for performing cross-border transactions, comprising a computer server including a memory and a processor, wherein the server is configured to: (See at least Fig. 1 and 0027 and 0065. The use of an “international” standard is indicative that transactions cross borders on a regular basis. See also 0029 and 0030 relating to geographic location of a party to a transaction.)
receive, from a first entity, transaction information of a transaction, wherein the transaction information is included in an International Organization for Standardization (ISO)-supported file; (See at least 0027, 0044, 0048, and 0065)
generate a transaction identifier for the transaction; (See at least 0007-0008)
transmit, to the first entity, the transaction identifier for the transaction; (See at least Fig. 5)
perform an anti-money laundering (AML) check based on the transaction information; (See at least Fig. 1 and its associated description beginning at 0022.)
apply a machine learning model to identify a pattern based on the transaction information; (See at least 0030, wherein past transactions is considered to constitute the recited term “pattern.”)
write the AML check and the pattern to the ISO-supported file; (See at least 0007-0008)
receive the transaction identifier from a second entity; and (See at least 0007-0008)
transmit a transaction approval message to the second entity based on the AML check and the pattern. (See at least Fig. 5 and associated description beginning at 0059)
Therefore, Lowenberg appears to teach the basic limitations of Claim 1. However, out of an abundance of caution, and subject to further consideration of the cited reference and subject to the broadest reasonable interpretation of the relevant limitation, Actimize is cited for its teachings relating to the use of the ISO 20022 message format to enhance or enrich transaction messaging.
Actimize is directly on point with the claimed invention and Lowenberg.
Actimize is in the exact same field of endeavor as Lowenberg and the claimed invention – using the enhanced data messaging features of ISO 20022 to detect money laundering.
Thus, Actimize teaches as follows in the Abstract:
“ISO 20022 is a machine-readable XML format that augments payment messaging context and content via the expansion of data from approximately 100 characters to around 9,000 characters. For users, this means a better degree of clarification for both data types and tags per individual message components.
While it’s widely acknowledged that ISO 20022 provides potential benefits to financial services firms, from improved reconciliation to rationalization of formats, the standard’s impact on financial crime for both anti-money laundering (AML) and fraud is often overlooked.” (emphasis added)
The following is a particularly salient teaching of Actimize:
“Opportunities Arise from ISO 20022’s Richer Data Schema
“The richer data schema of ISO 20022 provides new opportunities for FSOs to elevate payment messages and strengthen their fraud and AML programs. Both sending and beneficiary banks could directly share risk scores or other data relating to the customer or payment in the communications. Additionally, the payment network could add a supplementary network risk score to the message.” (Emphasis Added)
Therefore, it would have been obvious to one of ordinary skill in the relevant art at the time of filing the claimed invention to have modified the fraud detection system of Lowenberg to add the AML teachings of Actimize. The motivation to do so comes from Lowenberg. As quoted above, Lowenberg teaches the use of the ISO 20022 standard to share fraud risk ratings with other parties. It would greatly enhance the efficiency and accuracy of the system of Lowenberg to use the ISO teachings of Actimize.
With regard to Claims 2 - 11, Lowenberg in view of Actimize teaches:
2. The system according to claim 1, wherein the first entity is an originating agent. (See at least 0021)
3. The system according to claim 2, wherein the originating agent is one selected from the group consisting of a bank, a payment service provider (PSP), a third party payment PSP (TPP-PSP), a payment on behalf of (POBO) corporation, or a collection on behalf of (COBO) corporation. (See at least 0021)
4. The system according to claim 1, wherein the ISO-supported file is an ISO-20022-supported file. (See at least 0027)
5. The system according to claim 1, wherein the transaction information includes one or more selected from the group consisting of an internet protocol (IP) address associated with the transaction, a geo-location associated with transaction, a browser language, or a unique device identification (ID) that started the transaction with the first entity. (See at least 0029)
6. The system according to claim 5, wherein the transaction information further includes one or more associated with the transaction and selected from the group consisting of a name, an email, a phone number, recent account changes and account age, historical transactions and velocity metrics, size of recent remittances, an identification of the transaction as a recurring transfer, and performance of a know your client (KYC) due diligence at regular intervals and rate one or more customers based on a risk associated with the one or more customers. (See at least 0028)
7. The system according to claim 1, wherein the first entity is configured to perform an initial authentication and funds collection associated with the transaction. (See at least 0021)
8. The system according to claim 1, wherein the server is configured to generate a fraud rate associated with the first entity. (See at least 0007-0008)
9. The system according to claim 8, wherein the server is configured to write the fraud rate to the ISO-supported file. (See at least Lowenberg in view of Actimize and the sections quoted above.)
10. The system according to claim 1, wherein the pattern indicates one or more of mule accounts, unusual transaction volumes, transactions inconsistent with customer profiles, and customers with a past suspicious activity report (SAR) marked history. See sections of Actimize relating to “regulatory responsibilities.”)
11. The system according to claim 1, wherein the server is configured to provide a flag on the transaction when the pattern is an anomalous pattern. (See at least Actimize relating to growing alert volumes and raising alerts.)
With regard to Claim 12, this claim is essentially identical to Claim 1 and is obvious for the same reasons as set forth above with respect to that claim.
With regard to Claim 13, this claim is essentially identical to Claim 2 and is obvious for the same reasons as set forth above with respect to that claim.
With regard to Claim 14, this claim is essentially identical to Claim 3 and is obvious for the same reasons as set forth above with respect to that claim.
With regard to Claim 15, this claim is essentially identical to Claim 2 and is obvious for the same reasons as set forth above with respect to that claim.
With regard to Claim 16, this claim is essentially identical to Claim 8 and is obvious for the same reasons as set forth above with respect to that claim.
With regard to Claim 17, this claim is essentially identical to Claim 9 and is obvious for the same reasons as set forth above with respect to that claim.
With regard to Claim 18, this claim is essentially identical to Claim 10 and is obvious for the same reasons as set forth above with respect to that claim.
With regard to Claim 19, this claim is essentially identical to Claim 1 and is obvious for the same reasons as set forth above with respect to that claim.
With regard to Claim 20, this claim is essentially identical to Claim 1 and is obvious for the same reasons as set forth above with respect to that claim. (
Conclusion
5. Applicant should carefully consider the following in connection with this Office Action:
A. Search and Prior Art
The search conducted in connection with this Office Action, as well as any previous Actions, encompassed the inventive concepts as defined in the Applicant’s specification. That is, the search(es) included concepts and features which are defined by the pending claims but also pertinent to significant although unclaimed subject matter. Accordingly, such search(es) were directed to the defined invention as well as the general state of the art, including references which are in the same field of endeavor as the present application as well as related fields (e.g. the use of the ISO 20022 standard to detect money laundering and fraud in cross-border transactions). Indeed, there is a plethora of prior art in these fields.
Therefore, in addition to prior art references cited and applied in connection with this and any previous Office Actions, the following prior art is also made of record but not relied upon in the current rejection:
U.S. Patent Publication No. 2020/0151686 to Komandur et al. This reference relates to the concept of ISO 20022.)
B. Responding to this Office Action
In view of the foregoing explanation of the scope of searches conducted in connection with the examination of this application, in preparing any response to this Action, Applicant is encouraged to carefully review the entire disclosures of the above-cited, unapplied references, as well as any previously cited references. It is likely that one or more such references disclose or suggest features which Applicant may seek to claim. Moreover, for the same reasons, Applicant is encouraged to review the entire disclosures of the references applied in the foregoing rejections and not just the sections mentioned.
C. Interviews and Compact Prosecution
The Office strongly encourages interviews as an important aspect of compact prosecution. Statistics and studies have shown that prosecution can be greatly advanced by way of interviews. Indeed, in many instances, during the course of one or more interviews, the Examiner and Applicant may reach an agreement on eligible and allowable subject matter that is supported by the specification.
Interviews are especially welcomed by this examiner at any stage of the prosecution process. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool (e.g. TEAMS).
To facilitate the scheduling of an interview, the Examiner requests the use of the AIR form as follows:
USPTO Automated Interview Request http://www.uspto.gov/interviewpractice.
Other forms of interview requests filed in this application may result in a delay in scheduling the interview because of the time required to appear on the Examiner's docket. Thus, the use of the AIR form is strongly encouraged.
D. Communicating with the Office
Any inquiry concerning this communication or earlier communications from the examiner should be directed to WILLIAM BUNKER whose telephone number is (571)272-0017. The examiner can normally be reached on M - F 8:30AM - 5:30PM, Pacific.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Abhishek Vyas, can be reached at 571-270-1836. Information regarding the status of an application, whether published or unpublished, may be obtained from the “Patent Center” system. For more information about the Patent Center system, https://patentcenter.uspto.gov/
/William (Bill) Bunker/
U.S. Patent Examiner
AU 3691
william.bunker@uspto.gov
(571) 272-0017
February 7, 2026
/ABHISHEK VYAS/Supervisory Patent Examiner, Art Unit 3691