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
This action is in reply to application 18/925,820 filed 10/24/2024. Claims 1-20 are pending. This action is non-final.
Double Patenting
Claim 14 is objected to under 37 CFR 1.75 as being a substantial duplicate of claim 7. When two claims in an application are duplicates or else are so close in content that they both cover the same thing, despite a slight difference in wording, it is proper after allowing one claim to object to the other as being a substantial duplicate of the allowed claim. See MPEP § 608.01(m). For examination purposes, Examiner will interpret claim 14 to be dependent upon claim 8.
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.
Step 1: Claims 1, 8, and 15 each recite non-transitory computer readable media, a method, and a system, respectively, to perform the following steps: receiving an indication of an employee donation to a nonprofit organization from a donation form of an external donation platform; determining additional information needed for a corporation employing the employee to make a supplemental donation to the nonprofit organization; causing collection of the additional information from one or more of: the donation form and the non-profit organization; determining, based at least in part on one or more rules, the indication of the employee donation, and the collected additional information, that the employee donation is eligible for a supplemental corporate donation; submitting, to a corporate vendor platform associated with the corporation, a request for the supplemental corporate donation, the request comprising at least a portion of the additional information and the indication of the employee donation; and notifying the nonprofit organization of the submitted supplemental corporate donation. Therefore, claims 1, 8, and 15 are each directed to one of the four statutory categories of invention: an article of manufacture, a method, and a machine, respectively.
Step 2A – Prong One: The limitations receiving an indication of an employee donation to a nonprofit organization from a donation form ... determining additional information needed for a corporation employing the employee to make a supplemental donation to the nonprofit organization; causing collection of the additional information from one or more of: the donation form and the non-profit organization; determining, based at least in part on one or more rules, the indication of the employee donation, and the collected additional information, that the employee donation is eligible for a supplemental corporate donation; submitting ... a request for the supplemental corporate donation, the request comprising at least a portion of the additional information and the indication of the employee donation; and notifying the nonprofit organization of the submitted supplemental corporate donation, as drafted, is a method that, under its broadest reasonable interpretation, only covers concepts of “Certain Methods of Organizing Human Activity” (e.g., commercial interactions – business relations). That is, nothing in the claim elements disclose anything outside the groupings of “Certain Methods of Organizing Human Activity” (e.g., commercial interactions – business relations). Accordingly, the claim recites an abstract idea.
Step 2A – Prong Two: The judicial exception is not integrated into a practical application. Claims 1, 8, and 15 merely describe how to generally “apply” the concept of the aforementioned abstract idea using generic computer components. The additional elements of claims 1, 8, and 15, one or more non-transitory computer readable media (claim 1), one or more hardware processors (claims 1 and 15), a computer (claim 8), a computer interface (claim 8), electronic (claim 8), a system (claim 15), at least one device (claim 15), an external donation platform (claims 1, 8, and 15), and a corporate vendor platform (claims 1, 8, and 15), are recited at a high level of generality and are merely invoked as generic computer tools to perform the aforementioned abstract idea. Simply implementing the abstract idea on a generic computerized system is not a practical application of the abstract idea. Accordingly, alone and in combination, the additional elements of 1, 8, and 15 do not integrate the abstract idea into a practical application. The claims are directed to an abstract idea.
Step 2B: The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above, the claims as a whole merely describe the abstract idea generally “applied” to a generic computer environment. The additional elements of claims 1, 8, and 15, one or more non-transitory computer readable media (described in spec. para. [0011]), one or more hardware processors (described in spec. para. [0151]), a computer (described in spec. para. [0099]), a computer interface (described in spec. para. [0069]), electronic (described in spec. para. [0012]), a system (described in spec. para. [0137]), at least one device (described in spec. para. [0145]), an external donation platform (described in spec. para. [0069]), and a corporate vendor platform (described in spec. para. [0083]), are recited at a high level of generality and are merely invoked as generic computer components upon which the abstract idea is “applied.” The high level of generality in which this additional element is described indicates that the additional element is sufficiently known such that the specification does not need to describe the particulars of the additional element to satisfy the statutory disclosure requirements. Thus, even when viewed as a whole, nothing in the claims add significantly more to the abstract idea. Therefore, the claims are not patent eligible.
Claims 2-7, 9-14, and 16-20 have been given the full two-part analysis including analyzing the limitations both individually and in combination. Claims 2-7, 9-14, and 16-20 when analyzed individually, and in combination, are also held to be patent ineligible under 35 U.S.C. 101. The recited limitations of the dependent claims fail to establish that the claims do not recite an abstract idea because the recited limitations of the dependent claims merely further narrow the abstract idea.
Step 2A – Prong Two: The limitations of the dependent claims fail to integrate an abstract idea into a practical application because the claims as a whole merely describe how to generally “apply” a method of the aforementioned abstract idea. The dependent claims do not comprise any additional elements. The claims as a whole merely describe how to generally “apply” the aforementioned abstract idea in a generic computer environment. Thus, even when viewed as a whole, nothing in the claims integrates the abstract idea into a practical application.
Step 2B: Performing the further narrowed abstract ideas of the dependent claims on the additional elements of the independent claim, individually or in combination, does not impose any meaningful limits on practicing the abstract ideas and amount to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Similarly, the recited limitations of the dependent claims fail to establish that the claims provide an inventive concept because claims that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept. The dependent claims do not comprise any additional elements. The claims as a whole merely describe how to generally “apply” the aforementioned abstract idea in a generic computer environment. Thus, even when viewed as a whole, nothing in the claims add significantly more to the abstract idea. Therefore, the claims are not patent eligible.
Claim Rejections - 35 USC § 102
The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
A person shall be entitled to a patent unless –
(a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention.
(a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention.
Claim 1-5, 7-12, 14-18, and 20 are rejected under 35 U.S.C. 102(a)(1) and 102(a)(2) as being anticipated by Friedman (U.S. Pub. No. 20230259988).
Regarding claims 1, 8, and 15, Friedman discloses the following limitations:
One or more non-transitory computer readable media comprising instructions which, when executed by one or more hardware processors, causes performance of operations comprising: [See [Abstract]; [0294-0295]; Friedman teaches a server used for performing automated platform-based donation matching and security using a non-transitory computer readable medium and one or more processor.]
receiving an indication of an employee donation to a nonprofit organization from a donation form of an external donation platform; [See [0179] Friedman teaches that users of the system may be employees and employers. Friedman [0026]; (Figs. 2-4); teaches a plurality of platforms working in concert in order to perform its disclosed functions. One of these platforms is a fundraising platform (i.e., an external donation platform) where a fundraiser may be shared and displayed, and which a user may interact with in order to perform a donation. Friedman (Fig. 4, elements 402, 404); [0079]; further teaches receiving an indication that a donation has been made by a user (i.e., receiving an indication of an employee donation to a nonprofit organization from a donation form of an external donation platform).]
determining additional information needed for a corporation employing the employee to make a supplemental donation to the nonprofit organization; [See [0044] Friedman teaches that “matching” a donation involves a transfer of funds in the same amount as another transfer of funds. Friedman further teaches that donation matches can be conditioned on one or more rules, such as particular fundraising events, particular causes (e.g., social justice, animal support, climate change, education, etc.) (i.e., determining additional information needed for a corporation employing the employee to make a supplemental donation to the nonprofit organization), particular individuals (e.g., employees only), particular geographic locations, etc.]
causing collection of the additional information from one or more of: the donation form and the non-profit organization; [See [0044] Friedman teaches that “matching” a donation involves a transfer of funds in the same amount as another transfer of funds. Friedman further teaches that donation matches can be conditioned on one or more rules, such as particular fundraising events, particular causes (e.g., social justice, animal support, climate change, education, etc.), particular individuals (e.g., employees only), particular geographic locations, etc. Friedman (Fig. 10); [0113]; further teaches that cause information may be displayed (i.e., causing collection of the additional information from one or more of: ... the non-profit organization) on a match sponsor user interface, which may be used to determine whether or not a match should be made according to the donation matching rules of the match sponsor.]
determining, based at least in part on one or more rules, the indication of the employee donation, and the collected additional information, that the employee donation is eligible for a supplemental corporate donation; [See [0044] Friedman teaches that “matching” a donation involves a transfer of funds in the same amount as another transfer of funds. Friedman further teaches that donation matches can be conditioned on one or more rules, such as particular fundraising events, particular causes (e.g., social justice, animal support, climate change, education, etc.), particular individuals (e.g., employees only), particular geographic locations, etc. Friedman (Fig. 10); [0113]; further teaches that cause information may be displayed on a match sponsor user interface, which may be used to determine whether or not a match should be made according to the donation matching rules of the match sponsor. If the donation meets the matching rules of the match sponsor (i.e., determining, based at least in part on one or more rules, the indication of the employee donation, and the collected additional information, that the employee donation is eligible for a supplemental corporate donation), then a matching donation may be made via the user interface element “match.”]
submitting, to a corporate vendor platform associated with the corporation, a request for the supplemental corporate donation, the request comprising at least a portion of the additional information and the indication of the employee donation; [See [0026] Friedman teaches a plurality of platforms working in concert in order to perform its disclosed functions. One of these platforms is a payment service platform (i.e., a corporate vendor platform associated with the corporation) which may be used to receive donations and request donation matches from match sponsors. Friedman (Fig. 7, element 712); [0097] teaches sending a withdrawal request for funds from the matching sponsor in accordance with a previous donation (i.e., submitting, to a corporate vendor platform associated with the corporation, a request for the supplemental corporate donation, the request comprising at least a portion of ... and the indication of the employee donation). Friedman (Fig. 10); [0113] further teaches that this request may take the form of a displayed request on a user interface. Friedman (Fig. 10); [0113] further teaches that the displayed request on the user interface may include information regarding the cause to which the donation is going (i.e., the additional information), a donor identifier, and the amount donated (i.e., submitting, to a corporate vendor platform associated with the corporation, a request for the supplemental corporate donation, the request comprising at least a portion of the additional information and the indication of the employee donation).]
and notifying the nonprofit organization of the submitted supplemental corporate donation. [See [0100]; (Fig. 7, element 718); Friedman teaches that at block 718, the payment service 104 may deposit the funds from the donation and the additional funds from the matching sponsor from the holding account 146 to a beneficiary account 752 associated with the beneficiary. Deposit of such funds may be based at least in part on the one or more conditions described herein being satisfied. In examples, a notification of the one or more conditions being satisfied may be presented to the donors, sponsors, or other entities associated with the fundraising event. Furthermore, Friedman [0223]; (Fig. 17); teaches the payment platform may send notifications to the recipient of donations (i.e., and notifying the nonprofit organization of the submitted supplemental corporate donation).]
Regarding claims 2, 9, and 16, Friedman discloses all claim 1, 8, and 15 limitations. Friedman further discloses the following limitations:
notifying the nonprofit organization of disbursement of the supplemental corporate donation. [See [0100]; (Fig. 7, element 718); Friedman teaches that at block 718, the payment service 104 may deposit the funds from the donation and the additional funds from the matching sponsor from the holding account 146 to a beneficiary account 752 associated with the beneficiary. Deposit of such funds may be based at least in part on the one or more conditions described herein being satisfied. In examples, a notification of the one or more conditions being satisfied may be presented to the donors, sponsors, or other entities associated with the fundraising event. Furthermore, Friedman [0223]; (Fig. 17); teaches the payment platform may send notifications to the recipient of donations (i.e., notifying the nonprofit organization of disbursement of the supplemental corporate donation).]
Regarding claims 3, 10, and 17, Friedman discloses all claim 1, 8, and 15 limitations. Friedman further discloses the following limitations:
causing storage of data associated with the submitted matching donation. [See [0063] Friedman teaches that when a user makes a donation and when a matching sponsor makes a donation, such a donation may have tax implications, such as for tax write-off purposes. Records of such donations should generally be maintained for audit purposes and for accurate recordkeeping. When the tax-based functionality of the payment service 104 is enabled, data indicating a given donation may be associated with a user profile of the user and saved in a database associated with the tax component 148 (i.e., causing storage of data associated with the submitted matching donation).]
Regarding claims 4 and 11, Friedman discloses all claim 1 and 8 limitations. Friedman further discloses the following limitations:
wherein the notification of the employee donation comprises one or more of: an EIN associated with the non-profit organization, a donation amount, or an employee identifier. [See (Fig. 7, element 712); [0097] Friedman teaches sending a withdrawal request for funds from the matching sponsor in accordance with a previous donation (i.e., the employee donation). Friedman (Fig. 10); [0113] further teaches that this request may take the form of a displayed request on a user interface (i.e., the notification of the employee donation). Friedman (Fig. 10); [0113] further teaches that the displayed request on the user interface may include information regarding the cause to which the donation is going, a donor identifier (i.e., the notification of the employee donation comprises one or more of: ... an employee identifier), and the amount donated (i.e., the notification of the employee donation comprises one or more of: ... a donation amount ...).]
Regarding claims 5 and 12, Friedman discloses all claim 1 and 8 limitations. Friedman further discloses the following limitations:
wherein the one or more rules comprises at least one of: a minimum donation dollar amount to be matched, a maximum donation dollar amount to be matched, one or more employee eligibility criteria, or a donation match ratio. [See [0138] Friedman teaches determining whether a match limit associated with the sponsor has been met. For example, the sponsor preferences may indicate a maximum amount of money that is to be utilized in a given period of time for matching sponsor donations (i.e., wherein the one or more rules comprises at least one of: ... a maximum donation dollar amount to be matched ...). The match limit may be based on the maximum amount of money, or on other factors such as a number of matches the sponsor has been involved in.]
Regarding claim 18, Friedman discloses all claim 15 limitations. Friedman further discloses the following limitations:
wherein the notification of the employee donation comprises one or more of: an EIN associated with the non-profit organization, a donation amount, or an employee identifier; [See (Fig. 7, element 712); [0097] Friedman teaches sending a withdrawal request for funds from the matching sponsor in accordance with a previous donation (i.e., the employee donation). Friedman (Fig. 10); [0113] further teaches that this request may take the form of a displayed request on a user interface (i.e., the notification of the employee donation). Friedman (Fig. 10); [0113] further teaches that the displayed request on the user interface may include information regarding the cause to which the donation is going, a donor identifier (i.e., the notification of the employee donation comprises one or more of: ... an employee identifier), and the amount donated (i.e., the notification of the employee donation comprises one or more of: ... a donation amount ...).]
wherein the one or more rules comprises at least one of: a minimum donation dollar amount to be matched, a maximum donation dollar amount to be matched, one or more employee eligibility criteria, or a donation match ratio. [See [0138] Friedman teaches determining whether a match limit associated with the sponsor has been met. For example, the sponsor preferences may indicate a maximum amount of money that is to be utilized in a given period of time for matching sponsor donations (i.e., wherein the one or more rules comprises at least one of: ... a maximum donation dollar amount to be matched ...). The match limit may be based on the maximum amount of money, or on other factors such as a number of matches the sponsor has been involved in.]
Regarding claims 7, 14, and 20, Friedman discloses all claim 1, 8, and 15 limitations. Friedman further discloses the following limitations:
wherein the indication of the employee donation to the nonprofit organization is received in real-time. [See (Fig. 7, element 712); [0097] Friedman teaches sending a withdrawal request for funds from the matching sponsor in accordance with a previous donation (i.e., the employee donation). Friedman (Fig. 10); [0113] further teaches that this request may take the form of a displayed request on a user interface. Friedman (Fig. 10); [0113] further teaches that the displayed request on the user interface may include information regarding the cause to which the donation is going, a donor identifier, and the amount donated. Friedman [0112] further teaches that this displayed user interface displaying user donations updates in real time (i.e., wherein the indication of the employee donation to the nonprofit organization is received in real-time).]
Claim Rejections - 35 USC § 103
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.
Claims 6, 13, and 19 are rejected under 35 U.S.C. 103 as being unpatentable over Friedman (U.S. Pub. No. 2023/0259988) in view of Palty (U.S. Pub. No. 2022/0180406).
Regarding claims 6, 13, and 19 Friedman discloses all claim 1, 5, 8, 12, 15, and 18 limitations. Friedman [0044] teaches that “matching” a donation involves a transfer of funds in the same amount as another transfer of funds. Friedman further teaches that donation matches can be conditioned on one or more rules, such as particular fundraising events, particular causes (e.g., social justice, animal support, climate change, education, etc.) (i.e., additional information), particular individuals (i.e., donor identification) (e.g., employees only)) (i.e., additional information), particular geographic locations, etc. Friedman does not, however, disclose that such additional information such as donor identification comprises one or more of an employee email address, an employee identification number, or an employee job title. Therefore, Friedman does not disclose the following limitations. Palty, however, does remedy these deficiencies of Friedman.
wherein the additional information comprises one or more of an employee email address, an employee identification number, or an employee job title. [See [0002] Palty teaches donation matching by corporation employers for fulfilling corporate social responsibilities and boosting employee morale. Palty [0018] further teaches that a donation authorization can comprise a donation amount and a donor token for the donor. The donor token can be uniquely associated with a sender account associated with the donor and maintained by a sender financial institution. The donation amount can correspond to a donee token for a donee, wherein the donee token is uniquely associated with a receiver account for the donee and maintained by a receiver financial institution. Palty [0019] further teaches that the donor token can be a public token (e.g., an email address).]
It would have been obvious to one of ordinary skill in the art before the time of filing to combine the donor identification methods of Friedman with the donor identification methods of Palty. By making this combination, a matching sponsor in the system of Friedman would be able to quickly identify a donor as an employee via their email address. With the donor identified via a registered email address instead of simply a name, a matching sponsor employer of Friedman would be able to quickly recognize a donor as one of their employees and thereby validate that matching their donation would be appropriate.
Prior Art
The following prior art is relevant to the invention but was not used in prior art rejections:
Hicks (U.S. Pub. No. 2016/0343043) – System and method for charitable giving
Mateer (U.S. Pub. No. 2022/0129955) – Systems and methods for charitable giving
Brown (U.S. Pub. No. 2014/0304186) – Directed charitable giving system
Worth (U.S. Pub. No. 2015/0206201) – Computerized system for managing the distribution of corporate donations
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to CHRIS GOMEZ whose telephone number is (571) 272-0926. The examiner can normally be reached on 7:30 AM – 4:30 PM EST.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, SHANNON CAMPBELL can be reached at (571) 272-5587. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/CHRISTOPHER GOMEZ/ Examiner, Art Unit 3628