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 the Application
This is a non-final rejection prepared in response to U.S. Patent Application 18/948,824, filed on November 15, 2024. This application is a continuation of U.S. Patent Application No. 18/244,601, filed September 11, 2023, now U.S. Patent No. 12,147,953, which is a continuation of U.S. Patent Application No. 17/403,423, filed on August 16, 2021, now U.S. Patent No. 11,756,011, which is a continuation of U.S. Patent Application No. 16/215,334, filed on December 10, 2018, now U.S. Patent No. 11,093,912, which is a continuation of U.S. Patent Application No. 16/214,469, filed on December 10, 2018, now U.S. Patent No. 11,379,850. Claims 1 - 20 are pending and have been examined.
Information Disclosure Statements
The Information Disclosure Statements submitted by the Applicant on January 17, 2025, March 6, 2025, May 12, 2025 and October 7, 2025 are in compliance with the provisions of 37 CFR 1.97 and have been considered by the examiner.
Double Patenting Rejection
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 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); In re Thorington, 418 F.2d 528, 163 USPQ 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 non-statutory double patenting provided the reference application or patent either is shown to be commonly owned with the examined application, or claims an invention made as a result of activities undertaken within the scope of a joint research agreement. See MPEP § 717.02 for applications subject to examination under the first inventor to file provisions of the AIA as explained in MPEP § 2159. See MPEP § 2146 et seq. for applications not subject to examination under the first inventor to file provisions of the AIA . A terminal disclaimer must be signed in compliance with 37 CFR 1.321(b).
The USPTO Internet website contains terminal disclaimer forms which may be used. Please visit www.uspto.gov/patent/patents-forms. The filing date of the application in which the form is filed determines what form (e.g., PTO/SB/25, PTO/SB/26, PTO/AIA /25, or PTO/AIA /26) should be used. A web-based eTerminal Disclaimer may be filled out completely online using web-screens. An eTerminal Disclaimer that meets all requirements is auto-processed and approved immediately upon submission. For more information about eTerminal Disclaimers, refer to www.uspto.gov/patents/process/file/efs/guidance/eTD-info-I.jsp.
Claims 1-20 are rejected on the ground of non-statutory double patenting as being unpatentable over claims 1-20 of U.S. Patent 12,147,953 (‘953 patent). Although the claims at issue are not identical, they are not patentably distinct from each other. Claim 1 from the instant application and claim 1 of the ‘953 patent each teach a network interface configured to communicate with an external computing system via API calls, one or more processors and memory having instructions, generating a security token associated with a first computing system, the security token indicating that the external computing system is authorized to submit API calls containing security token and payment data to a second computing system, wherein the first computing system provides a third-party client application to the second computing system wherein payment data is submitted for approval to initiate a payment request. Claim 1 of the instant application also recites providing the third-party application to a third computing system for determination through an API call submitting the security token that the third computing system is authorized to receive the payment data and initiate an action associated with the request. The additional recitations in Claim 1 do not make the claims between ‘953 patent and the instant application patently distinct.
Claims 1-20 are rejected on the ground of non-statutory double patenting as being unpatentable over claims 1-20 of U.S. Patent 11,756,011 (‘011 patent). Although the claims at issue are not identical, they are not patentably distinct from each other. Claim 1 from the instant application and claim 1 of the ‘011 patent each teach a network interface configured to communicate with an external computing system via API calls, one or more processors and memory having instructions, generating a security token associated with a first computing system, the security token indicating that the external computing system is authorized to submit API calls containing security token and payment data to a second computing system, wherein the first computing system provides a third-party client application to the second computing system wherein payment data is submitted for approval to initiate a payment request. Claim 1 of the instant application also recites providing the third-party application to a third computing system for determination through an API call submitting the security token that the third computing system is authorized to receive the payment data and initiate an action associated with the request. Claim 1 of the ‘011 patent also recites, in relation to the submit-payment API call, the payment data identifying a payee and payment amount, and in relation to the indication of approval of the payment, receipt of a visually-perceptible icon to approve the payment. These additional elements recited respectively in Claim 1 of the instant application and the ‘011 patent do not make the claims patently distinct.
Subject Matter Eligibility
Based on the MPEP 2106:
Under Step 2A, Prong 1:
The claims recite the abstract idea of communicating payment data between systems in order to process a request for an action which involves commercial interactions including agreements in the form of contracts, legal obligations and business relations.
Under Step 2A Prong 2:
The claimed invention has been deemed to recite limitations that integrate the identified abstract idea into a practical application.
In particular, Claim 1 recites “an account administration system, comprising: one or more processors and a memory having instructions that, when executed by the one or more processors, cause the one or more processors to, individually or collectively: generate a security token indicating that a first computing system is authorized to submit API calls to a second computing system, wherein the first computing system provides a third-party application to a third computing system; transmit the security token to the first computing system; receive a first API call from the first computing system, the first API call including the security token and payment data, wherein the payment data is submitted for approval within an operating environment of the third-party application; determine based on the security token that the first computing system is authorized to submit API calls; in response to determining that the first computing system is authorized to submit API calls, initiate a secure session with the third computing system; transmit, to the third computing system through the secure session, the payment data and a request for approval of an action associated with the payment data; and in response to an indication of approval of the request, initiate the action associated with the request.”
These are meaningful limitations that as an ordered combination that are more than mere instructions to apply the abstract idea using a computer and are more than
generally linking the use of the abstract idea to a particular technological
environment or field of use and are indicative of a practical application. Further, as an
ordered combination, the claims are also not well-understood, routine or conventional.
Therefore, Claims 1-20 are deemed to be patent eligible.
No Prior Art Rejection
Based on prior art search results, no prior art reference taken as a whole or in combination anticipates or renders obvious the claimed subject matter. Therefore, there is no prior art rejection provided for Claims 1-20.
The closest prior art of record, U.S. 9,922,381 B2, Isaacson et al. discloses a Atty. Dkt. No. 052873-1062payment token that is created by a user device/browser. The payment token includes payment data for the specified card and merchant. It does not indicate that the external third-party client computing system is authorized to submit API calls to the service provider computing system via the API gateway. Further, Isaacson does not disclose a service provider computing system that transmits the security token to the third-party client computing system using the network interface and where the security token is stored in memory of the third-party client computing system for transmission to the service provider computing system.
The closest prior art of record, U.S. 2019/0096005 A1, Drury et al. discloses automated provisioning which enables a mutual customer to establish an intelligent and automated connection between an accounting software system and their financial institution.
The closest prior art of record, U.S. 2017/0076274 A1, Royyurue et al. discloses, a method of remotely activating a transaction device includes receiving, at a computing system, a mobile device identifier from a mobile application executed on a mobile device.
The closest prior art of record, U.S. 2016/0267449 A1, Forzley discloses, a system and method for facilitating payment for online services where a financial institution provides an existing infrastructure for payment or electronic funds transfer from a customer’s bank account to a service provider.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to GEORGE PROIOS whose telephone number is (571)272-4573. The examiner can normally be reached M-F 8-5.
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/GEORGE N. PROIOS/Examiner, Art Unit 3694
/BENNETT M SIGMOND/Supervisory Patent Examiner, Art Unit 3694