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 .
DETAILED ACTION
This communication is in response to the application filed on 25 October 2024. Claims 1-20 are currently pending. The rejections are as stated below.
Information Disclosure Statement
The Information Disclosure Statements (IDS) submitted in this application on 25 October 2024 is in compliance with the provisions of 37 CFR 1.97. Accordingly, the IDS is being considered by the examiner. The initialed copies of the1449 are enclosed herewith.
Double Patenting
The non-statutory double patenting rejection is based on a judicially created doctrine grounded in public policy (a policy reflected in the statute) so as to prevent the unjustified or improper timewise extension of the “right to exclude” granted by a patent and to prevent possible harassment by multiple assignees. A non-statutory obviousness-type double patenting rejection is appropriate where the conflicting claims are not identical, but at least one examined application claim is not patentably distinct from the reference claim(s) because the examined application claim is either anticipated by, or would have been obvious over, the reference claim(s). See, e.g., In re Berg, 140 F.3d 1428, 46 USPQ2d 1226 (Fed. Cir. 1998); In re Goodman, 11 F.3d 1046, 29 USPQ2d 2010 (Fed. Cir. 1993); In re Longi, 759 F.2d 887, 225 USPQ 645 (Fed. Cir. 1985); In re Van Ornum, 686 F.2d 937, 214 USPQ 761 (CCPA 1982); In re Vogel, 422 F.2d 438, 164 USPQ 619 (CCPA 1970); and In re Thorington, 418 F.2d 528, 163USPQ 644 (CCPA 1969).
A timely filed terminal disclaimer in compliance with 37 CFR 1.321(c) or 1.321(d) may be used to overcome an actual or provisional rejection based on a non-statutory double patenting ground provided the conflicting application or patent either is shown to be commonly owned with this application, or claims an invention made as a result of activities undertaken within the scope of a joint research agreement.
Effective January 1, 1994, a registered attorney or agent of record may sign a terminal disclaimer. A terminal disclaimer signed by the assignee must fully comply with 37 CFR 3.73(b).
Claims 1-20 are rejected on the ground of non-statutory obviousness-type double patenting as being unpatentable over claims 1-15 of Patent No. US 12154169 B2 and claims 1-20 of Patent No. US 12567106 B2. The claims of the instant application and the patents mentioned above are drawn to methods and corresponding systems of importing a batch of receiver accounts onto an application platform associated with a real-time transaction system. Although the conflicting claims are not identical, they are not patentably distinct from each other, because they recite means or steps that are substantially the same and would have been obvious to one of ordinary skill in the art.
Furthermore, the omission of an element with a corresponding loss of function is an obvious expedient. See In re Karlson, 136 USPQ 184 and Ex parte Rainu, 168 USPQ 375.
For these reasons, the claims of the instant application are not identical to claims 1-15 of Patent No. US 12154169 B2 and claims 1-20 of Patent No. US 12567106 B2, but they are not patently distinct.
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. In particular, claims are directed to a judicial exception (abstract idea) without significantly more.
The instant claims are rejected under 35 USC 101 in view of The Decision in Alice Corporation Ply. Ltd. v. CLS Bank International, et al. in a unanimous decision, the Supreme Court held that the patent claims in Alice Corporation Pty. Ltd. v. CLS Bank International, et al. ("Alice Corp. ") are not patent-eligible under 35 U.S.C. § 101.
Claim 1 (exemplary) recites a series of steps of importing a batch of receiver accounts onto an application platform.
The claim is directed to a process, which is a statutory category of invention.
The claim is then analyzed to determine whether it is directed to a judicial exception.
Independent method claim 1, recites the limitations of receiving, at an import receiver account options screen a selection to import a receiver file, wherein the receiver file comprises a listing of a plurality of receiver accounts; isolating a subset of the plurality of receiver accounts that are invalid from a remainder of the plurality of receiver accounts that are valid; displaying, on an imported receiver account results page an indication of the subset of the plurality of receiver accounts that are invalid; downloading, upon detecting selection input provided to the imported receiver account results page data associated with each of the subset of the plurality of receiver accounts; receiving, at the import receiver account options screen another selection to import an editable document containing user edits to portions of the downloaded data for each of the subset of the plurality of receiver accounts; determining that the subset of the plurality of receiver accounts containing the user edits in the imported editable document are valid; and updating, responsive to the determining, a receiver accounts record with the subset of the plurality of receiver accounts containing the user edits.
The claimed system simply describes series of steps for importing a batch of receiver accounts onto an application platform. These limitations, as drafted, are processes that, under its broadest reasonable interpretation, covers performance that can be performed by the human mind or with pen and paper. The MPEP § 2106.04(a)(2)(III), explains that “mental processes” include acts that people can perform in their minds or using pen and paper, even if the claim recites that a generic computer component performs the acts. For example, a person is able through observation, evaluation, judgement, and/or opinion to isolate a subset of a plurality of accounts that are invalid from a remainder of a plurality of accounts that are valid; display results page an indication of the subset of the plurality of receiver accounts that are invalid; and import an editable document containing user edits to portions of the data for each of the subset of the plurality of receiver accounts; determining that the subset of the plurality of accounts containing the user edits in the imported editable document are valid; and updating, responsive to the determining, an accounts record with the subset of the plurality of receiver accounts containing the user edits.
These tasks may be performed by the human mind or with pen and paper. These limitations are directed to an abstract idea because they are concepts performed in the human mind (including an observation, evaluation, judgment or an opinion) that falls within the enumerated group of “Mental Processes”. Therefore, it is clear that exemplary independent claim 1 recites limitations that fall under the category of abstract ideas related to “mental processes”. See MPEP § 2106.04(a)(2). Accordingly, independent claim 1 recites an abstract idea.
Next, the claim is analyzed to determine if it is integrated into a practical application. The claim recites additional limitation of on a graphical user interface of the application platform of one or more processors, to perform the steps. The processor in the steps is recited at a high level of generality, i.e., as a generic computer performing a generic computer function of processing data (see Applicant’s specification ¶¶ 0028-0032). This generic computer limitations are no more than mere instructions to apply the exception using generic computer component. Also, these limitations are an attempt to limit the abstract idea to a particular technological environment. Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. See MPEP 2106.04(f). The claim is directed to the abstract idea.
Next, the claim is analyzed to determine if there are additional claim limitations that individually, or as an ordered combination, ensure that the claim amounts to significantly more than the abstract ideas (whether claim provides inventive concept). As discussed above, the recitation of the claimed limitations amounts to mere instructions to implement the abstract idea on a server (using the computer as a tool to implement the abstract idea). Taking the additional elements individually and in combination, the processor at each step of the process performs purely generic computer functions. As such, there is no inventive concept sufficient to transform the claimed subject matter into a patent-eligible application. The same analysis applies here, i.e., mere instructions to apply an exception using a generic computer component cannot integrate a judicial exception into a practical application at or provide an inventive concept. See MPEP 2106.05(h).
Viewing the limitations as an ordered combination does not add anything further than looking at the limitations individually. When viewed either individually, or as an ordered combination, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea itself. Therefore, the claim does not amount to significantly more than the recited abstract idea. Therefore, the claim is not patent eligible.
The analysis above applies to the statutory category of invention of claims 1, 8 and 15. Furthermore, dependent claims 2-7, 9-14 and 16-20 do not add limitations that meaningfully limit the abstract idea.
Dependent claims 2-7, 9-14 and 16-20, recites the additional limitations of displaying a deficient receiver account download icon for downloading the data associated with each of the subset of the plurality of receiver accounts that are invalid; determining that the receiver file is not in a predetermined file format; and automatically converting the receiver file to the predetermined file format; identifying, via analysis of the receiver file, one or more data points associated with each of the plurality of receiver accounts in the listing; accessing, via communication with another financial entity associated with at least one of the one or more data points, a storage database; comparing the identified one or more data points against one or more other data points in the storage database; and determining, based on determining that a discrepancy exists between the identified one or more data points and the one or more other data points, that an error exists in the one or more data points; identifying a row location in the receiver file where an error in each of the subset of the plurality of receiver accounts is located, a beneficiary associated with each of the subset of the plurality of receiver accounts, and an error description explaining the error; displaying a duplicate accounts table that identifies a row location in the receiver file where of one or more duplicate accounts are located; and the editable document includes the downloaded data associated with each of the subset of the plurality of receiver accounts. These limitations further define the abstract idea and are rejected under the same rational of claim 1.
The claims merely amounts to the application or instructions to apply the abstract idea on a generic processor, and is considered to amount to nothing more than requiring a generic computer to merely carry out the abstract idea itself.
The dependent claims do not impart patent eligibility to the abstract idea of the independent claims. Therefore, none of the dependent claims alone or as an ordered combination add limitations that qualify as integrating the abstract idea into a practical application.
The dependent claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements are simply steps performed by a generic computer.
Accordingly, claims 1-20 are rejected as ineligible for patenting under 35 U.S.C. 101 based upon the same analysis.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Milam US 20150081537 A1 discloses a “dropped payment file is obtained at a computing device of an operator of an electronic funds transfer bill payment system from a client of such system. The dropped payment file includes data associated with at least one unsuccessful attempt to match payment data to a corresponding biller. The data in the dropped payment file is cleaned to create an updated dropped payment file. Matching logic is applied to the updated dropped payment file to identify at least one recommended biller to which the payment data should likely have been routed to. The client is advised of the at least one recommended biller”.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to Hani Kazimi whose telephone number is (571) 272-6745. The examiner can normally be reached Monday-Friday from 8:30 AM to 5:00 PM.
Examiner interviews are available via telephone, in-person, 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, Abhishek Vyas can be reached on (571) 270-1836. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000.
Respectfully Submitted
/HANI M KAZIMI/
Primary Examiner, Art Unit 3691
Prosecution Insights