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 .
Terminal Disclaimer
The terminal disclaimer filed on 06/12/2026 disclaiming the terminal portion of any patent granted on this application which would extend beyond the expiration date of PAT 12,437,303 and PAT 12,614,183 has been reviewed and is accepted. The terminal disclaimer has been recorded. The Double Patenting rejection has been withdrawn.
Status of Claims
Claims 1-12 and 18 are currently pending and rejected.
Claims 13-17 and 19-20 are currently pending and allowed.
Claim Rejection – 35 U.S.C. 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 1-12 and 18 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter. The rationale for this finding is explained below. In the instant case, the claims are directed towards detecting and remediating anomalies with institutional financial instruments. The concept is related to managing transactions between human entities, thus the present claims fall within the Certain Method of Organizing Human Activity grouping. The claims do not include limitations that are “significantly more” than the abstract idea because the claims do not include an improvement to another technology or technical field, an improvement to the functioning of the computer itself, or meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment. Note that the limitations, in the instant claims, are done by the generically recited computer device. The limitations are merely instructions to implement the abstract idea on a computer and require no more than a generic computer to perform generic computer functions that are well-understood, routine and conventional activities previously known to the industry. Therefore, claims 1-12 and 18 are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter.
Step 1: The claims 1-12 and 18 are directed to a process, machine, manufacture, or composition matter.
In Alice Corp. Pty. Ltd. v. CLS Bank Intern., 134 S. Ct. 2347 (2014), the Supreme Court applied a two-step test for determining whether a claim recites patentable subject matter. First, we determine whether the claims at issue are directed to one or more patent-ineligible concepts, i.e., laws of nature, natural phenomenon, and abstract ideas. Id. at 2355 (citing Mayo Collaborative Servs. v. Prometheus Labs., Inc., 132 S. Ct. 1289, 1296–96 (2012)). If so, we then consider whether the elements of each claim, both individually and as an ordered combination, transform the nature of the claim into a patent-eligible application to ensure that the patent in practice amounts to significantly more than a patent upon the ineligible concept itself.
Claims 1-18 are directed to a process (i.e., method claims).
Step 2A: The claims are directed to an abstract idea.
Prong One
The present claims are directed towards detecting and remediating anomalies with institutional financial instruments. The concept comprises performing a text extraction process on a check image, decoding an IMB barcode in the check image to obtain a character code, utilizing the character code to extract encoded check information including a payee ZIP code, performing a fraud detection by analyzing and scoring check textual information and the encoded check information, and routing the check image based on the fraud detection process. Detecting anomalies by analyzing printed textual information against encoded information is a fundamental economic activity and managing transactions between human, thus the present claims clearly fall within the Certain Method of Organizing Human Activity grouping. Claims 1-18 do not explicitly recite any computer hardware or have any indication that the claims are performed by a computer. Under the broadest reasonable interpretation, claims 1-18 can be interpreted as being performed entirely by human. Accordingly, the present claims recite an abstract idea.
Prong Two
Claims 1-18 do not recite any additional element. Under the broadest reasonable interpretation, claims 1-18 can be interpreted as being performed entirely by human. Even if the process is performed by a computer, the computer merely performs basic computer functions, such as text extraction (OCR), decoding barcode, comparing information, and routing check according to result of analysis. Claims 1-18 do not recite limitation that improve the functioning of computer, effect a physical transformation, or apply the abstract concept in some other meaningful way beyond generally linking the use of the abstract concept to a particular technological environment. As such, the present claims fail to integrate into a practical application.
Step 2B: The claims do not recite additional elements that amount to significantly more than the abstract idea.
As discussed earlier, claims 1-18 do not recite any additional element. Even if the process is performed by a computer, the computer merely performs basic computer functions, such as text extraction (OCR), decoding barcode, comparing information, and routing check according to result of analysis. According to MPEP 2106.05(d), “performing repetitive calculations”, “receiving, processing, and storing data”, “electronically scanning or extracting data from a physical document”, “electronic recordkeeping”, “storing and retrieving information in memory”, and “receiving or transmitting data over a network, e.g., using the Internet to gather data” are considered well-understood, routine, and conventional functions of computer. Claims 1-18 do not improve the functioning of computer. Simply implementing the abstract idea on a generic computer or using a computer as a tool to perform an abstract idea cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. Therefore, the present claims are ineligible for patent.
Prior Art Cited Not Applied
Foster et al. (Patent No.: US 12,039,504) is cited, because the prior art teaches performing a text extraction process on a check image of an institutional financial
instrument to obtain check textual information (see col 14 line 6-25); performing a fraud detection process on the check image based on both (1) scores generated during the text extraction process, and (2) inconsistency between the check textual information and the encoded check information (see col 3 line 59 through col 4 line 29);
performing an Optical Character Recognition (OCR) process, performing a template matching process using alphanumeric characters and symbols in a predetermined font, or performing a deep learning analysis on the check image (col 14 line 26-57); for each template of the list of templates, generating a match score array corresponding to each of a plurality of patches within the check image, the plurality of patches being sized corresponding to an expected character size (col 2 line 42 through col 3 line 42); based on the fraud detection process, either routing the image of the object for additional fraud analysis and remediation or permitting further processing without additional fraud analysis (see col 5 line 18-23, col 6 line 3-9, col 19 line 53 through col 20 line 20).
However, Foster does not teach decoding an intelligent mail barcode (IMB) in the check image to obtain a character code; and utilizing the character code to extract encoded check information including a payee ZIP code from the IMB, as required in the independent claim 1 and 19.
Pintsov et al. (Pub. No.: US 2004/0247168) is cited, because the prior art teaches a system and method of automatically selecting check templates for image-based fraud detection including the steps of representing a check image from an account, matching the check image against a series of known check templates from the account, producing confidence scores corresponding to the degree of similarities of the check image compared to each check template and matching the confidence scores with a predetermined high similarity threshold and a predetermined low similarity threshold. However, Pintsov does not fulfill the deficiency of Foster et al.
Kriegsfeld et al. (Pub. No.: US 2022/0309856) is cited, because the prior art teaches check image fraud detection. However, Kriegsfeld does not fulfill the deficiency of Foster et al.
For these reasons, no prior art-based rejection is cited in this Office Action.
Response to Argument
Rejection under 35 U.S.C. 101
Applicant's arguments filed on 06/12/2026 have been fully considered but they are not persuasive. Applicant argued the image enhancement processes recited in claim 1 yield an IMB representation that is “significantly clearer and of higher quality,” resulting in far greater accuracy of decoding the IMB values,” and the overall technique achieves “lower false positive detection rates, higher true positive detection rates, and increased accuracy overall”. Examiner points out however, Applicant merely amended independent claim 1 by adding the limitation, “wherein the decoding includes performing one or more image enhancement processes on at least a portion of the check image including the IMB, the one or more image enhancement processes including one or more tilt fixing process or a noise removal process” from claim 13. The amended feature does not provide any detail of the image enhancement process (a tilt fixing process or a noise removal process). As such, the image enhancement process could be interpreted as existing and well-known image enhancement process. Including a well-known process does not improve computer function or render the claim any less abstract. Applicant must recite detailed steps of an improved image enhancement process to integrate the abstract concept into a practical application and overcome the rejection under 35 U.S.C. 101.
Examiner finds independent claim 19 contains all the details of the improved image enhancement processes. At the minimum, Applicant needs to include all the features from claim 13 to overcome the rejection under 35 U.S.C. 101. Examiner maintains the ground of rejection for claims 1-12 and 18.
Conclusion
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/HAO FU/Primary Examiner, Art Unit 3695
JULY-2026
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