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 the amendment filed 05/22/2026.
Claims 1, 4, 8, 11, 15, and 18 have been amended. Claims 1-20 are pending and have been examined on the merits (claims 1, 8, and 15 being independent).
The amendment filed 05/22/2026 to the claims has been entered.
Response to Arguments
Applicant’s arguments and amendments filed 05/22/2026 have been fully considered.
Examiner has not found the reference to teach all particulars of the claims in view of the amendments and arguments on pages 18-24 in Applicant’s response and therefore, no prior art rejection can be made on the claims 1-20.
Applicants assert that the pending claims fully comply with the requirement of 35 U.S.C. 101. Examiner respectfully disagrees. Applicant’s argument and amendments have been considered and are not persuasive. The rejections under 35 U.S.C. 101 have been maintained and clarified in view of the USPTO MPEP 2106.
Applicant’s arguments (see Applicant’s remarks, pages 14-18)
(1) Applicant’s arguments that “Thus, Applicant requests that the 35 U.S.C. § 101 rejection of claims as allegedly being directed toward an abstract idea of Organizing Human Activity be reconsidered and removed, as Step 2A Prong One: NO.” (see page 16), are not found persuasive.
Response (1): Step 2A Prong 1, under Step 2 A, Prong 1 of the 2019 Revised § 101 Guidance, it is determined whether the claims are directed to a judicial exception such as a law of nature, a natural phenomenon, or an abstract idea (See Alice, 134 S. Ct. at 2355) by identify the specific limitation(s) in the claim that recites abstract idea(s); and then determine whether the identified limitation(s) falls within at least one of the groupings of abstract ideas enumerated in the MPEP 2106.04. The cited limitations as drafted are systems and methods that, under their broadest reasonable interpretation, covers performance of a method of organizing human activity, but for the recitation of the generic computer components (e.g., processors, databases, a machine learning (ML) model). Further, none of the limitations recite technological implementations details for any of the steps but, instead, only recite broad functional language being performed by the generic use of at least one processor. Identifying and grouping one or more equivalent entities such as a company, organization, or individual conducting business activities including a financial transaction is a fundamental economic practice long prevalent in commerce systems. If a claim limitation, under its broadest reasonable interpretation, covers a fundamental economic principle or practice but for the general linking/applying to a technological environment, then it falls within the organizing human activity grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
(2) Applicant’s arguments that “The claim is thus a practical application that improves an existing technology, consistent with DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d 1245 (Fed. 7Cir. 2014). Therefore, amended Claim 1 is eligible as Step 2A Prong Two: YES..” (see page 17), are not found persuasive.
Response (2): Step 2A Prong 2, next, it is determined whether the claim is directed to the abstract concept itself or whether it is instead directed to some technological implementation or application of, or improvement to, this concept, i.e., integrated into a practical application. See, e.g., Alice, 573 U.S. at 223, discussing Diamond v. Diehr, 450 U.S. 175 (1981 ). The mere introduction of a computer or generic computer technology into the claims need not alter the analysis. See Alice, 573 U.S. at 223-24. "[T]he relevant question is whether the claims here do more than simply instruct the practitioner to implement the abstract idea on a generic computer." Alice, 573 U.S. at 225.
In the present case, the judicial exception is not integrated into a practical application. The claim limitations are not indicative of integration into a practical application by claiming an improvement to the functioning of the computer or to any other technology or technical field. Further, the claim limitations are not indicative of integration into a practical application by applying or using the judicial exception in some other meaningful way. In particular the claim limits of “by the one or more hardware processors”, “using a machine learning (ML) model”, “an unsupervised apriori model”, and “one or more databases” are claimed and described at a high level of generality and are functions any general purpose computer performs such that it amounts no more than mere instruction to apply the exception to a particular technological environment. Further, none of the limitations recite technological implementations details for any of the steps but, instead, only recite broad functional language being performed by the generic use of computer components. The claim limits also recite the use of processors, databases, a machine learning (ML) model as additional elements. However, the use of these additionally elements, described at a high level of generality, perform generic computer functions such that it amounts to no more than mere instruction to apply the exception to a particular technological environment. Accordingly, these additional elements do not integrate the abstract idea into a practical application because it does not impose any meaning limits on practicing the abstract idea. Thus, the claim is directed toward an abstract idea.
Furthermore, the claims here are not like those the Court found patent eligible in DDR, in which the inventive concept was in the modification of conventional mechanics behind website display to produce a dual-source integrated hybrid display because applicant’s claims here do not address problems unique to the Internet or require an arguably inventive device or technique for displaying information.
(3) Applicant’s arguments that “This combination yields a technical improvement: it reduces the brittleness of simple identifier matching by using co-occurrence mining and transitive merging to derive robust equivalence groups, and then it operationalizes those groups to reconcile database records that otherwise would remain unreconciled because of disparate entity identifiers. The claimed pipeline therefore provides significantly more than an abstract idea and should be found patent eligible, which is precisely the sort of innovation that the patent system is designed to encourage. Therefore, amended claim I is eligible as Step 2B: YES.” (see page 18), are not found persuasive.
Response (3): Step 2B, the claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements when considered both individually and as an ordered combination do not amount to significantly more that the abstract idea(s). As discussed above with respect to integration of the abstract idea into a practical application, the additional element of using a processor to perform the abstract idea(s) amounts to no more than mere instructions to apply an exertion using a generic computer component. Mere instruction to apply the exertion using a computer cannot provide an inventive concept. These generic computer components are claimed at a high level of generality to perform their basic functions which amount to no more than generally linking/applying the use of the judicial exception to the particular technological environment of field of use. Thus, the claims are not patent eligible.
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 without significantly more.
When considering subject matter eligibility under 35 U.S.C. 101, (1) it must be determined whether the claim is directed to one of the four statutory categories of invention, i.e., process, machine, manufacture, or composition of matter. If the claim does fall within one of the statutory categories, (2a) it must then be determined whether the claim is directed to a judicial exception (i.e., law of nature, natural phenomenon, and abstract idea), and if so (2b), it must additionally be determined whether the claim is a patent-eligible application of the exception. If an abstract idea is present in the claim, any element or combination of elements in the claim must be sufficient to ensure that the claim amounts to significantly more than the abstract idea itself. Examples of abstract ideas include fundamental economic practices; certain methods of organizing human activities; an idea itself; and mathematical relationships/formulas. Alice Corporation Pty. Ltd. v. CLS Bank International, et al., 573 U.S. (2014).
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. In the instant case, the claim(s) as a whole, considering all claim elements both individually and in combination, do not amount to significantly more than an abstract idea.
Step (1): In the instant case, the claims are directed towards to a method for identifying and grouping one or more equivalent entities such as a company, organization, or individual conducting business activities including a financial transaction which contains the steps of obtaining, pre-processing, generating, grouping, eliminating, comparing, providing, and linking. The claim recites a series of steps and, therefore, is a process. The claims do fall within at least one of the four categories of patent eligible subject matter because claim 1 is direct to a method, claim 8 is direct to a system, and claim 15 is direct to a non-transitory computer-readable storage medium, i.e. machines programmed to carrying out process steps, Step 1-yes.
Step (2A) Prong 1: A method for identifying and grouping one or more equivalent entities such as a company, organization, or individual conducting business activities including a financial transaction is akin to the abstract idea subject matter grouping of: Certain Methods of Organizing Human Activity as fundamental economic principles or practices and commercial or legal interactions. As such, the claims include an abstract idea.
The specific limitations of the invention are (a) identified to encompass the abstract idea include: { obtaining, ….., data associated with one or more financial transactions performed by one or more entities, ……, wherein the data comprise one or more data fields associated with at least one of: one or more transaction types, one or more company codes, one or more document types, one or more document numbers, one or more posting keys, one or more posting dates, one or more invoice dates, one or more clearing dates, one or more clearing documents, one or more invoice amounts, one or more entity names, and one or more entity numbers; pre-processing, ……, the data associated with the one or more financial transactions, wherein pre-processing the one or more data comprise standardizing the one or more data fields; generating, ……, one or more transaction numbers for each of the one or more financial transactions by concatenating one or more combinations of the pre-processed one or more data fields; grouping, ….., one or more entities having identical transaction numbers, into one or more initial groups; eliminating, ……, one or more groups from the one or more initial groups …… to obtain one or more intermediate groups, wherein …….. configured to obtain the one or more intermediate groups using an association identified within the one or more initial groups based on frequent item sets within the one or more initial groups by identifying combinations of the one or more entities that frequently occur together across the one or more initial groups; comparing, ……, the one or more entities across the one or more intermediate groups to obtain one or more resultant groups ……., wherein ……… comprises repeatedly merging the intermediate groups that share at least one common entity and iteratively using merged groups as inputs for subsequent merging until no further intermediate groups share a common entity, and wherein each of the one or more resultant group comprises the one or more equivalent entities performing the one or more financial transactions; providing, ……., the one or more resultant groups as an output to one or more end users …….. associated with the one or more end users; and automatically linking one or more invoices to one or more payments …….. based on the provided one or more resultant groups to reconcile records having disparate entity identifiers.}
As stated above, this abstract idea falls into the (b) subject matter grouping of: Certain Methods of Organizing Human Activity as fundamental economic principles or practices and commercial or legal interactions as obtaining data, processing data associated with financial transactions, generating transaction numbers, grouping one or more entities, eliminating one or more groups to obtain one or more intermediate groups, comparing one or more entities, providing one or more resultant groups, and linking one or more invoices to one or more payments in order to reconcile records.
Step (2A) Prong 2: The instant claims do not integrate the exception into a practical application because additional elements: “by one or more hardware processors”, “from one or more databases”, “one or more user interfaces of one or more electronic devices”, and “using a machine learning (ML) model” amount to simply applying the abstract idea to a computer component. (e.g. “apply it”) do not apply, rely on, or use the judicial exception in a manner that that imposes a meaningful limitation on the judicial exception (i.e. generally linking the use of the judicial exception to a particular technological environment or field of use - see MPEP 2106.05(h) or apply it 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 an abstract idea - see MPEP 2106.05(f)).
The instant recited claims including additional elements (i.e. one or more hardware processors, one or more databases, a machine learning (ML) model, and one or more user interfaces of one or more electronic devices) do not improve the functioning of the computer or improve another technology or technical field nor do they recite meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment. The limitations merely use a generic computing technology (Specification paragraphs [0064-0065], a computing environment 100 with a machine learning based (ML-based) computing system 104, one or more electronic devices 102 that are communicatively coupled to the ML-based computing system 104 through a network 106, one or more databases 108) as generally linking the use of the judicial exception to a particular technological environment or field of use - see MPEP 2106.05(h) or apply it 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 an abstract idea - see MPEP 2106.05(f)). Therefore, 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 with respect to integration of the abstract idea into a practical application, the additional elements (Claims: e.g., one or more hardware processors, one or more databases, a machine learning (ML) model, and one or more user interfaces of one or more electronic devices) amount to no more than mere instructions to apply the exactly using generic computer component. The claim elements when considered separately and in an ordered combination, do not add significantly more than implementing the abstract idea.
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. 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. In conclusion, merely “linking/applying” the exception using generic computer components does not constitute ‘significantly more’ than the abstract idea. (MPEP 2106.05 (f)(h)). Therefore, the claims are not patent eligible under 35 USC 101.
Dependent claims 2-7, 9-14, 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, in claims 2, 9, and 16, the step of “… wherein standardizing the data comprises at least one of: column name standardization, datetime and numeric conversion, handling of null records, currency conversion, intra-company removal,...” (i.e., standardizing the data), in claims 3, 10, and 17, the step of “… determining, ….., whether one or more datasets comprising the data having uniformity and clarity, providing data analysis and interpretation of the data, using the column name standardization,… standardizing, …, date and numeric formats across the one or more data fields…. standardizing, …., the one or more financial transactions based on one or more functional currencies of one or more business… filtering, ….., the one or more financial transactions between the one or more business units of the one or more entities….” (i.e., determining, standardizing, and filtering financial transactions), in claims 4, 11, and 18, the step of “… obtaining, ….., information associated with the one or more initial groups… computing, ……, a confidence value for each of the combination of the one or more entities using the support computed for each of the entity and the support computed for the combination of the one or more entities ...” (i.e., obtaining intermediate groups), in claims 5, 12, and 19 the step of “… determining, ….., an intersection of each intermediate group with the one or more intermediate groups… comparing, …, the one or more intermediate groups with the one or more resultant groups to determine whether a count of the one or more resultant groups is equal to a count of the one or more intermediate groups;… repeating, ……, the iterative unionization process until the count of the one or more resultant groups is equal to the count of the one or more intermediate groups, wherein the one or more resultant groups are determined as one or more inputs to the iterative unionization process….” (i.e., determining resultant groups), in claims 6, 13, and 20, the step of “… further comprising assessing, …, an accuracy of the ML model by comparing the one or more resultant groups with one or more historical entity grouping data.” (i.e., being an accuracy), and in claims 7, 14, and 20, the step of “… re-training,… the ML model by adjusting the one or more values of the one or more parameters,… processing, …, the re-trained ML model with the adjusted one or more values of the one or more parameters to optimize the accuracy ...” (i.e., optimizing the accuracy) are all processes that, under its broadest reasonable interpretation, covers performance of a fundamental economic practice but for the recitation of a generic computer component. Identifying one or more equivalent entities such as a company, organization, or individual conducting business activities including a financial transaction is a most fundamental commercial process.
This is an abstract concept with nothing more and is also 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).
In dependent claims 2-7, 9-14, and 16-20, the step claimed are rejected under the same analysis and rationale as the independent claims 1, 8, and 15 above. Merely claiming the same process using the machine learning model for identifying one or more equivalent entities such as a company, organization, or individual conducting business activities including a financial transaction and grouping one or more entities does not change the abstract idea without an inventive concept or significantly more. Clearly, the additional recited limitations in the dependent claims only refine the abstract idea further. Further refinement of an abstract idea does not convert an abstract idea into something concrete.
Therefore, claims 1-20 are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter.
Conclusion
The prior art made of record but not relied upon herein but pertinent to Applicant’s disclosure is listed in 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 extension fee 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 YONG S PARK whose telephone number is (571)272-8349. The examiner can normally be reached on M-F 9:00-5:00 PM, EST.
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/YONGSIK PARK/Examiner, Art Unit 3694
July 14, 2026
/BENNETT M SIGMOND/Supervisory Patent Examiner, Art Unit 3694
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