DETAILED ACTION
Status of Claims
1. This office action is in response to arguments filed 3/30/2026.
2. Claims 52-71 are pending.
3. This action is non-final.
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 .
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 52-71
Claims 52-71 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.
Step 1: Claims 52-58 are directed to a method; claims 59-65 are directed to a system; claims 66-71 are directed to a non-transitory computer-readable medium – each of which is one of the statutory categories of inventions.
Step 2A: A claim is eligible at revised Step 2A unless it recites a judicial exception and the exception is not integrated into a practical application of the application.
Prong 1: Prong One of Step 2A evaluates whether the claim recites a judicial exception (an abstract idea enumerated in the 2019 PEG, a law of nature, or a natural phenomenon).
Groupings of Abstract Ideas:
I. MATHEMATICAL CONCEPTS
A. Mathematical Relationships
B. Mathematical Formulas or Equations
C. Mathematical Calculations
II. CERTAIN METHODS OF ORGANIZING HUMAN ACTIVITY
A. Fundamental Economic Practices or Principles (including hedging, insurance, mitigating risk)
B. Commercial or Legal Interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations)
C. Managing Personal Behavior or Relationships or Interactions between People (including social activities, teaching, and following rules or instructions)
III. MENTAL PROCESSES.
Concepts performed in the human mind (including an observation, evaluation, judgment, opinion).
See MPEP 2106.04 (a) (2) Abstract Idea Groupings [R-10.2019]
The limitations of the independent claims 52, 59 and 66 – receiving the payment transaction; examining contents of the payment transaction, wherein the contents of the payment transaction includes a transaction type; examining metadata associated with the payment transaction, wherein the metadata includes a payment rail preference; repairing the payment transaction by: examining an error code associated with the payment transaction; and performing a repair operation on the payment transaction based on the error code; and routing the payment transaction to the payment rail for processing – fall under the abstract idea groupings Mental Process and/or Certain Methods of Organizing Human Activity.
The limitations of the dependent claims –
Claims 53, 60, 67: wherein the repair operation includes retrying to post the payment transaction at a later point in time.
Claims 54, 61, 68: wherein the repair operation includes editing one or more elements of the contents of the payment transaction.
Claims 55, 62, 69: wherein the repair operation includes editing one or more elements of the metadata associated with the payment transaction.
Claims 56, 63, 70: wherein the repair operation includes sending the payment transaction to a data enrichment component for repair.
Claims 57, 64: wherein the data enrichment component is configured to edit one or more elements of the contents of the payment transaction.
Claims 58, 65: wherein the data enrichment component is configured to edit one or more elements of the metadata associated with the payment transaction.
Claim 71: wherein the data enrichment component is configured to; edit one or more elements of the contents of the payment transaction; or edit one or more elements of the metadata associated with the payment transaction.
– also fall under the abstract idea categories Mental Process and/or Certain Methods of Organizing Human Activity.
Hence under Prong One of Step 2A, claims 52-71 recite a combination of judicial exceptions.
Prong 2: Prong Two of Step 2A evaluates whether the claim recites additional elements that integrate the judicial exception into a practical application of the exception.
Limitations that are indicative of integration into a practical application include:
Improvements to the functioning of a computer or to any other technology or technical field – see MPEP 2106.05(a)
Applying the judicial exception with, or by use of, a particular machine – see MPEP 2106.05(b)
Effecting a transformation or reduction of a particular article to a different state or thing – see MPEP 2106.05(c)
Applying or using the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception – see MPEP 2106.05(e)
Limitations that are not indicative of integration into a practical application include:
Adding the words “apply it” (or an equivalent) 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)
Adding insignificant extra-solution activity to the judicial exception – see MPEP 2106.05(g)
Generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h)
Additional elements recited by the claims, beyond the abstract idea, include: a system comprising processor and memory; non- transitory computer-readable medium. Examiner finds that any additional element(s), beyond the judicial exception, has been recited at a high level of generality such that the claim limitations amount to no more than mere instructions to apply the exception using generic components (see MPEP 2106.05(f)) or insignificant data gathering activities (see MPEP 2106.05(g)). The combination of additional elements does not purport to improve the functioning of a computer or effect an improvement in any other technology or technical field. Instead, the additional elements do no more than “use the computer as a tool” and/or “link the use of the judicial exception to a particular technological environment or field of use.” The focus of the claims is not on improvement in computers, but on certain independently abstract ideas – receiving the payment transaction; examining contents of the payment transaction, wherein the contents of the payment transaction includes a transaction type; examining metadata associated with the payment transaction, wherein the metadata includes a payment rail preference; repairing the payment transaction by: examining an error code associated with the payment transaction; and performing a repair operation on the payment transaction based on the error code; and routing the payment transaction to the payment rail for processing – that merely uses generic computers as tools. Steps that do no more than spell out what it means to “apply it on a computer” cannot confer patent eligibility. Indeed, nothing in claim 1 improves the functioning of the computer, makes it operate more efficiently, or solves any technological problem. See Trading Techs. Int’l, Inc. v. IBG LLC, 921 F.3d 1378, 1384-85 (Fed. Cir. 2019).
Hence, the additional elements, individually and in combination, do not integrate the judicial exception into a practical application.
Hence, the claims are ineligible under Step 2A.
Step 2B: In Step 2B, the evaluation consists of whether the claim recites additional elements that amount to an inventive concept (aka “significantly more”) than the recited judicial exception.
As discussed in Prong Two, the additional elements in the claims amount to no more than mere instructions to apply the exception using generic components. When considered individually or as an ordered combination, the additional elements fail to transform the abstract idea of – receiving the payment transaction; examining contents of the payment transaction, wherein the contents of the payment transaction includes a transaction type; examining metadata associated with the payment transaction, wherein the metadata includes a payment rail preference; repairing the payment transaction by: examining an error code associated with the payment transaction; and performing a repair operation on the payment transaction based on the error code; and routing the payment transaction to the payment rail for processing – into significantly more.
See MPEP 2106.05(f) Mere Instructions To Apply An Exception [R-10.2019].
(2) Whether the claim invokes computers or other machinery merely as a tool to perform an existing process. Use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) or simply adding a general purpose computer or computer components after the fact to an abstract idea (e.g., a fundamental economic practice or mathematical equation) does not integrate a judicial exception into a practical application or provide significantly more.
Hence, the claims are ineligible under Step 2B.
Therefore, the claim(s) are rejected under 35 U.S.C. 101 as being directed to a judicial exception without significantly more.
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 52-71
Claims 52-71 are rejected under 35 U.S.C. 103 as being unpatentable over Chistolini et al. (US20240242224) in view of Yusin (US20040128240).
Claim 52:
A method for repairing a payment transaction in a real-time payments system, comprising:
receiving the payment transaction;
examining contents of the payment transaction, wherein the contents of the payment transaction includes a transaction type;
(See Chistolini: Para [0027] (“Data that a payment method selection model 213 may use to select a payment rail for a transaction include, as described above: (i) payee risk profiles 212; (ii) payment origination risk profiles 232; (iii) payer (and optionally payee) preference data 211; and/or (iv) global rail characteristics 234 (which are described in more detail below in the discussion of FIG. 3 ). The payer (or payee) preference data 211, global rail characteristics 234, and/or the payee risk profile 212 may identify or contain information that is relevant to its corresponding entity's preferred payment rails, and the model may consider this data when selecting the payment rail for the transaction.”)
examining metadata associated with the payment transaction, wherein the metadata includes a payment rail preference;
(See Chistolini: Para [0025] (“The risk profiles described above, along with preference information 211 provided by (or available in a profile of) the payer 101 and/or payee 102, will be fed to a payment method selection model 213. The preference information 211 may include information such as the payer's preferred payment rail(s), identification of payment rails that are supported by both the payer's account and the payee's account, cost and delivery windows associated with use of the payment rail, and a minimum or maximum amount that each payment rail or account permits. The preference information 211 also may include other data, objectives, or constraints.”)
….
routing the payment transaction to the payment rail for processing.
(See Chistolini: Para [0049] (“If the user selects an alternate payee account or payment rail as the payment method, the system may declassify the optimal payee account or transaction rail that the transaction model selected and include the alternate payee account and/or transactional rail in the payment initialization data as the selected payment method. The payment initialization data will be a digital file, a data feed, a message, or other data structure that is be in a format that a financial entity can use to complete the transfer of assets from a payer account that associated with the payer to the selected payee account, using the selected payment rail. At 315 the system will transmit the payment initialization data to the financial institution that holds the payer's account so that the institution can use the file/data feed to initiate the payment via the payment rail.”)
Chistolini does not specifically disclose; however, Yusin discloses the following limitations:
repairing the payment transaction by:
examining an error code associated with the payment transaction; and
(See Yusin: Para [0121] (“The Country Specific Funding File is checked for errors, in Step 352. Errors that may be found in this step include processing errors due to reformatting in the NACHA or UN/EDIFACT formats, incorrect transaction amounts, misplacement of a decimal point, missing names of a bank or originating entity, etc. If there are errors, the method returns to Step 328 (FIG. 6) to repeat the processing required to create the Worldwide Funding File and Country Specific Funding File.”)
performing a repair operation on the payment transaction based on the error code; and
(See Yusin: Para
[0074] (“The Platform 104 analyzes and processes the Transaction File, in Step 204. Analysis and processing may include analyzing the Transaction File for transactions with errors, such as incomplete or erroneous data. Errors may be caused by telecommunications error, software error, input error, etc. Transactions with one or more errors may be removed from the Transaction File, or the entire File may be rejected. A Reject File on that transaction may be provided to the respective entity, 102 a-102 n, who may correct the errors and send the transaction again in a new Transaction File.”)
[0158] (“If it is determined that there are errors, in Step 214, the Detail Records with the errors are removed from the Country Specific Funding File, in Step 216 and a Reject File is generated and sent to the TM 106, in Step 218. The Reject File identifies the rejected Detail Records and the error or errors causing the rejection. The TM 106 may correct the errors and send the Detail Records back to the Clearing Network 112 in another Country Specific Funding File.”)
Therefore, it would have been obvious to a person having ordinary skills in the art before the effective filing date of the invention to modify the above noted disclosure of Chistolini as it relates to payment rail verification to include Yusin as it relates to managing and monitoring cash transfers. The motivation for combining the references would have been to train the machine learning model on country level wire transfer monetary threshold.
Claims 59, 66 are similar to claim 52 and hence rejected on similar grounds.
Claim 53:
wherein the repair operation includes retrying to post the payment transaction at a later point in time.
(See Yusin: Para [0077])
Claims 60, 67 are similar to claim 53 and hence rejected on similar grounds.
Claim 54:
wherein the repair operation includes editing one or more elements of the contents of the payment transaction.
(See Yusin: Para [0158])
Claims 61, 68 are similar to claim 54 and hence rejected on similar grounds.
Claim 55:
wherein the repair operation includes editing one or more elements of the metadata associated with the payment transaction.
(See Yusin: Para [0064])
Claims 62, 69 are similar to claim 55 and hence rejected on similar grounds.
Claim 56:
wherein the repair operation includes sending the payment transaction to a data enrichment component for repair.
(See Yusin: Para [0073])
Claims 63, 70 are similar to claim 56 and hence rejected on similar grounds.
Claim 57:
wherein the data enrichment component is configured to edit one or more elements of the contents of the payment transaction.
(See Yusin: Claim 5)
Claim 64 is similar to claim 57 and hence rejected on similar grounds.
Claim 58:
wherein the data enrichment component is configured to edit one or more elements of the metadata associated with the payment transaction.
(See Yusin: Para [0064])
Claim 65 is similar to claim 58 and hence rejected on similar grounds.
Claim 71:
wherein the data enrichment component is configured to;
edit one or more elements of the contents of the payment transaction; or
edit one or more elements of the metadata associated with the payment transaction.
(See Yusin: Para [0064], Claim 5)
Response to Arguments
Applicant's arguments filed 3/30/2026 have been fully considered but they are not persuasive.
101
Applicant argues that the claims integrate the abstract idea into a practical application.
Examiner finds this unpersuasive because the claims merely recite a combination of abstract ideas which is not sufficient to integrate into a practical application. Examining the contents of a payment transaction, examining transaction metadata, examining error code – involve observation, evaluation, judgement or opinion and hence fall under the Mental Process category of abstract ideas. Performing repair operation on a payment transaction and routing to payment rail for processing – is a Commercial/Legal Interaction and hence falls under Certain Methods of Organizing Human Activity. The additional elements merely implement the aforementioned combination of abstract ideas on generic components. See Credit Acceptance Corp. v. Westlake Servs., 859 F.3d 1044, 1056 (Fed. Cir. 2017) (“But merely ‘configur[ing]’ generic computers in order to ‘supplant and enhance’ an otherwise abstract manual process is precisely the sort of invention that the Alice Court deemed ineligible for patenting.”) (“Our prior cases have made clear that mere automation of manual processes using generic computers does not constitute a patentable improvement in computer technology.”). Unlike BASCOM, the claims do not perform technical improvements such as local packet filtering that were unconventional in the art at the time of the invention. An ordered combination of the claimed steps does not bring about (i) an improvement to the functionality of a computer or other technology or technical field; (ii) a “particular machine” to apply or use the judicial exception; (iii) a particular transformation of an article to a different thing or state; or (iv) any other meaningful limitation. See MPEP 2106.05(a)-(c), (e)-(h). Hence, the additional elements fail to integrate the recited combination of abstract idea(s) into a practical application or provide significantly more. See MPEP 2106.05(f). For the above reasons, the Applicant’s arguments are not persuasive.
103
Applicant’s arguments with respect to claim(s) Claims 52-71 have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ARUNAVA CHAKRAVARTI whose telephone number is (571)270-1646. The examiner can normally be reached 9 AM - 5 PM ET.
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/ARUNAVA CHAKRAVARTI/Primary Examiner, Art Unit 3692
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