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 .
This is the Final Office Action in response to the Amendment filed on May 21, 2026, for Application No. 18/950,408 filed on November 18, 2024, title: “Automated Transfer Of Enriched Transaction Account Data To A Submitted Record Of Charge”.
Status of the Claims
Claims 1-20 were pending. By the 05/21/2026 Response, claims 1, 5, 8-15, 17 and 19 have been amended, no claim has been added or cancelled. Accordingly, claims 1-20 are pending in this application and have been examined.
Priority
This Application is a CON of US Application No. 18/187,289 filed on 03/21/2023 (Patented No. 12,182,784) which is a CON of US Application No. 16/732,860 filed on 01/02/2020 (Patented No. 11,631,069) which is a CON of US Application No. 14/621,152 filed on 02/12/2015 (Patented No. 10,535,050). For the purpose of examination, the 02/12/2015 is considered to be the effective filing date.
Double Patenting
The nonstatutory 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 nonstatutory 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 nonstatutory 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 filing of a terminal disclaimer by itself is not a complete reply to a nonstatutory double patenting (NSDP) rejection. A complete reply requires that the terminal disclaimer be accompanied by a reply requesting reconsideration of the prior Office action. Even where the NSDP rejection is provisional the reply must be complete. See MPEP § 804, subsection I.B.1. For a reply to a non-final Office action, see 37 CFR 1.111(a). For a reply to final Office action, see 37 CFR 1.113(c). A request for reconsideration while not provided for in 37 CFR 1.113(c) may be filed after final for consideration. See MPEP §§ 706.07(e) and 714.13.
The USPTO Internet website contains terminal disclaimer forms which may be used. Please visit www.uspto.gov/patent/patents-forms. The actual 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/apply/applying-online/eterminal-disclaimer.
Claims 1-20 are rejected on the ground of nonstatutory double patenting as being unpatentable over claims 1-17 of US Patent No. 12,182,784 and claims 1-20 of U.S. Patent No. 10,535,050 and in view of Moulton (US Publication No. 2006/0169767). Although the claims at issue are not identical, they are not patentably distinct from each other because the examined claims are broader than the reference claims in the patents and anticipated by the reference claims. The examined claims recite substantially the same limitations as the reference claims in the patents with minor variations that would have been obvious to one of ordinary skill in the art. The application and the patents are directed to the same invention of automated transfer of enriched transaction account data to a submitted record of charge. The application and the patents have the same inventors and are commonly owned. Therefore, this rejection is deemed necessary.
Patent No. 18/950,408
Patent No. 12,182,784
Claim 1, A method, comprising:
Claim 1, A method, comprising:
accessing, by a client device, a list of pending charges from a remote computing device, wherein the list of pending charges includes a pending charge of a transaction before the transaction is listed on a record of posted charges, and wherein the list of pending charges is associated with and corresponds to a transaction account of a user;
displaying, by a client device, a list of pending charges via a display of the client device;
displaying the list of pending charges via a display of the client device of the user;
based on an authorization of a transaction, uploading enriched data associated with a pending charge to a remote computing device, wherein the uploading occurs before the transaction is listed on a record of posted charges,
based on an authorization of the transaction, uploading enriched data associated with the pending charge by the user via a user interface of the client device to the remote computing device, wherein the uploading occurs before the transaction is listed on the record of posted charges, and wherein the enriched data is stored in an authorization data enrichment storage database of the remote computing device;
responsive to the enriched data being moved from an of the remote computing device of the remote computing device, linking the enriched data stored in the posted charge data enrichment database to corresponding posted transactions;
viewing by the client device at least one of the enriched data stored in the authorization data enrichment storage database or the enriched data stored in a posted charge data enrichment database of the remote computing device, wherein the enriched data stored in the posted charge data enrichment database is linked to corresponding posted transactions in response to the enriched data being moved from the authorization data enrichment storage database to the posted charge data enrichment database; and
display, via the client device, one or more of the enriched data stored in the authorization data enrichment storage or the enriched data stored in the posted charge data enrichment databases; and
see Moulton, para. 48.
receiving, by the client device, one or more one or more
receiving by the client device at least one of a reminder, an expense report, or account management information from the remote computing device, wherein the at least one of the reminder, the expense report, or the account management information is generated by the remote computing device using the enriched data.
Patent No. 18/950,408
Patent No. 10,535,050
Claim 1, A method, comprising:
Claim 1, A method, comprising:
authorizing, by a computer-based system, a transaction between a merchant and a transaction account holder;
displaying, by a client device, a list of pending charges via a display of the client device;
transmitting, by the computer-based system, a notification to at least one of the merchant or the transaction account holder that the transaction has been initiated and a pending charge has been created;
based on an authorization of a transaction, uploading enriched data associated with a pending charge to a remote computing device, wherein the uploading occurs before the transaction is listed on a record of posted charges,
receiving, by the computer-based system, a link to enrichment data from at least one of the merchant or the transaction account holder to be associated with the pending charge;
responsive to the enriched data being moved from an of the remote computing device of the remote computing device, linking the enriched data stored in the posted charge data enrichment database to corresponding posted transactions;
providing, by the computer-based system, access to the enrichment data via the link to the enrichment data,
display, via the client device, one or more of the enriched data stored in the authorization data enrichment storage or the enriched data stored in the posted charge data enrichment databases; and
see Moulton, para. 48.
receiving, by the client device, one or more one or more
wherein the link to the enrichment data includes functionality for downloading at least one of documents, reminder needs, warranties, itineraries, reminders, deadlines or product manuals;
associating, by the computer-based system, the link to the enrichment data with the pending charge; and
storing, by the computer-based system, the link to the enrichment data in an enrichment data database.
Claims 1-20 are rejected on the ground of nonstatutory double patenting as being unpatentable over claims 1-20 of US Patent No. 11,631,069, in view of Chelst (US Publication No. 2014/0108210), and further in view of Moulton (US Publication No. 2006/0169767).
Here claim 1 of the Application has a narrow scope than the claims of the Patents because the Application specifically says, “receiving by the client device at least one of a reminder, an expense report, or account management information from the remote computing device, wherein the at least one of the reminder, the expense report, or the account management information is generated by the remote computing device using the enriched data.”. The patent discloses all the limitations except the “receiving” feature. However, Chelst teaches the “receiving” feature (Chelst, para. 91-97; Figures 8-9). Therefore, claim 1 of the application is rejected on the ground of nonstatutory double patenting as being unpatentable over claim 1 of the patent in view of Chelst reference. Claim 8 of the application recites a system and claim 15 of the application recites computer program with the comparable elements and limitations. Hence, these claims also are rejected under the same rationale provided in claim 1.
Dependent claims 2-7, 9-14, and 16-20 of the Application are also rejected as being unpatentable over the dependent claims of the patent. Although the claims at issue are not identical, they are not patentably distinct from each other because the claims of the application recite substantially the same limitations as the claims of the patent with minor variations that would have been obvious to one of ordinary skills in the art. The application and patent are directed to the same invention of automated transfer of enriched transaction account data to a submitted record of charge. Also, the application and the patent have the same inventors and are commonly owned. Therefore, this rejection is deemed necessary.
Patent No. 18/950,408
Patent No. 11,631,069
Claim 1, A method, comprising:
Claim 1, A method, comprising:
receiving, from a computing device and by a client device, a notification of an authorized charge for a transaction, the authorized charge representing a charge prior to accessing a record of submitted charges from a merchant;
accessing, by the client device, a list of authorized charges from the computing device, the list of authorized charges including the authorized charge for the transaction;
displaying, by a client device, a list of pending charges via a display of the client device;
rendering, by the client device on a display, a user interface to display the list of authorized charges and obtain a selection of enriched data associated with the transaction;
obtaining, by the client device, the selection of the enriched data associated with the transaction;
based on an authorization of a transaction, uploading enriched data associated with a pending charge to a remote computing device, wherein the uploading occurs before the transaction is listed on a record of posted charges,
uploading, to the computing device by the client device, the enriched data to be associated with the authorized charge for the transaction; and
responsive to the enriched data being moved from an of the remote computing device of the remote computing device, linking the enriched data stored in the posted charge data enrichment database to corresponding posted transactions;
rendering, by the client device, the user interface to display the enriched data in association with the transaction as a posted charge, the posted charge representing the authorized charge being converted to the posted charge based at least in part on the merchant posting the authorized charge to the computing device of a transaction account provider.
display, via the client device, one or more of the enriched data stored in the authorization data enrichment storage or the enriched data stored in the posted charge data enrichment databases; and
see Moulton, para. 48.
receiving, by the client device, one or more one or more
see Chelst, para. 91-97 and Figures 8-9.
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 an abstract idea without significantly more.
Step 1:
Under the 2019 Revised PEG, Step 1 analysis, the claims are reviewed to determine whether they fall within the four statutory categories of patentable subject matter (i.e., process, machine, manufacture, or combination of matter).
Claims 1-7 recite a method for automated transfer of enriched transaction account data to a submitted record of charge (as indicated by the title of the Application). Claims 8-14 recite a system and claims 15-20 recite a computer program with comparable elements and limitations for implementing the method. Therefore, the claims recite a process, machine, and manufacture which fall within the four statutory categories of invention (Step 1-Yes, the claims are statutory).
Step 2A Prong 1:
Under the 2019 Revised PEG, Step 2A, Prong 1, the claims are reviewed to determine whether they recite a judicial exception by identifying if the claim limitations fall in one of the enumerated abstract idea groupings (i.e., organizing human activity, mathematical concepts, and mental processes) that amount to a judicial exception to patentability.
Claim 1, A method, comprising:
displaying, by a client device, a list of pending charges via a display of the client device;
based on an authorization of a transaction, uploading enriched data associated with a pending charge to a remote computing device, wherein the uploading occurs before the transaction is listed on a record of posted charges;
responsive to the enriched data being moved from the authorization data enrichment storage of the remote computing device to a posted charge data enrichment database of the remote computing device, linking the enriched data stored in the posted charge data enrichment database to corresponding posted transactions;
display, via the client device, one or more of the enriched data stored in the authorization data enrichment storage or the enriched data stored in the posted charge data enrichment database; and
receiving, by the client device, one or more of a reminder, an expense report, or account management information from the remote computing device, wherein the one or more of the reminder, the expense report, or the account management information is generated by the remote computing device using the enriched data.
The above limitations, as drafted, is a process that, under its broadest reasonable interpretation, covers a method of organizing human activity but for the recitation of generic computer components (e.g., a system comprising a client device, a display, a remote computing device, an authorization data enrichment storage, a posted charge data enrichment database, a memory with machine-readable instructions). More specifically, the claim recites fundamental economic principles or practices and/or commercial or legal interactions including the steps that allow transaction account holders to be able to attach additional data to a transaction in concert with the transaction being initiated and prior to the merchant posting the transaction (see abstract).
The claim recite a method of automated transfer of enriched transaction account data to a submitted record of charge by: displaying by a client device that includes a list of pending charges; uploading the enriched data associated with a pending charge to a remote computing device before the transaction is listed on a record of posted charges; linking the enriched data to correspond the posted transactions; displaying the enriched data stored either in the authorization data enrichment storage or in the posted charge data enrichment database; and receiving one of a reminder, an expense report, or account management information from the remote computing device. The claim recites a concept that corresponds to mitigating risk before authorizing a transaction, which is a fundamental economic practice (i.e., hedging, insurance, mitigating risk) and commercial interaction (i.e., agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations). This falls within a method of organizing human activity and is abstract idea in nature. See MPEP 2106.04(a)(2)III.C.2.
If a claim limitation, under its broadest reasonable interpretation, covers performance of a fundamental economic practice and/or commercial interaction, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
While claim 1 is addressed above, the analysis above can be applied to claim 8 where the processors and memories also serve as mere instructions to apply an exception using generic computer components. Similarly, the non-transitory computer-readable medium of claim 15 is an additional element that serves as mere instructions to apply an exception using a generic computer component and does not provide a practical application or significantly more that the judicial exception. Therefore, these claims also recite an abstract idea (Step 2A, Prong 1-Yes, the claims recite an abstract idea).
Step 2A, Prong 2:
Under the 2019 Revised PEG, Step 2A, Prong 2, the claims are reviewed to determine whether the judicial exception (i.e., abstract idea) is integrated into a practical application. In order to make this determination, the additional element(s), or combination of elements, are analyzed to determine if the claim as a whole integrates the recited judicial exception into a practical application of that exception. A claim that integrates a judicial exception into a practical application will apply, rely on, or use the judicial exception in a manner that imposes a meaningful limit on the judicial exception, such that the claim is more than a drafting effort designed to monopolize the judicial exception.
The claims include the additional elements, such as a system comprising a client device, a display, a remote computing device, an authorization data enrichment storage, a posted charge data enrichment database, a memory with machine-readable instructions to perform the displaying, uploading, linking, displaying, and receiving steps. The recited additional computer elements in all steps are recited at a high level of generality and are merely invoked as tools to perform the generic functions. The limitations are done by the generically recited computer system (see Publication No. 2025/0078054, paragraphs 40, 44-47, 50-53, 56-58, 62-65 and 67-68). The limitations are merely instructions to implement the abstract idea on a computer and require no than a generic computer to perform the generic computer functions including the steps of accessing, displaying, receiving, and uploading. Each claim limitation of the claims have been considered individually and in combination as ordered has been considered. No non-generic or non-conventional arrangement is found.
The judicial exception is not integrated into a practical application. In particular, the claim recites the additional elements of a computer and a database. The computer is recited at a high-level of generality (i.e., as a generic processor performing generic computer functions of receiving/transmitting communications, processing information, querying the database) such that it amounts to no more than mere instructions to apply the exception using a generic computer component. 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. The claims are directed to an abstract idea (Step 2A, Prong 2-No, the claims do not integrate the abstract idea into a practical application).
Step 2B:
Under the 2019 Revised PEG, Step 2A, Prong 2, the claims are reviewed to determine whether the claims provide an inventive concept (i.e., whether the claim(s) include additional elements, or combinations of elements, that are sufficient to amount to significantly more than the judicial exception (i.e., abstract idea)).
The independent claims do not include additional elements, considered both individually and as an ordered combination, 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 element of using a computer to perform the displaying, uploading, linking, displaying, and receiving functions as claimed amounts to no more than mere instructions to apply the exception using a generic computer component. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Therefore, the independent claims are not patent eligible.
Dependent claims 2-7, 9-14, and 16-20 depend on claims 1, 8, and 15, and therefore include all the limitations of claims 1, 8, and 15. Therefore, the dependent claims also recite the same abstract idea of automated transfer of enriched transaction account data to a submitted record of charge as discussed in the independent claims.
Claims 2, 9, and 16 recite the additional elements “wherein the enriched data comprises at least one of text, an image, a file, an expense tag, a document, or a note.” The limitations are additional detailed information about the enriched data and amount – the claims individually or in combination with others do not integrate the abstract idea into a practical application or provide an inventive concept to the abstract idea. The claims are not patent eligible.
Claims 3, 10, and 17 recite the additional elements “accessing, by the client device, the list of pending charges from the remote computing device, wherein the list of pending charges includes the pending charge of the transaction before the transaction is listed on the record of posted charges, and wherein the list of pending charges is associated with and corresponds to a transaction account of a user.” The limitations are accessing the list of pending charges from the remote computing device – the claims individually or in combination with others do not integrate the abstract idea into a practical application or provide an inventive concept to the abstract idea. The claims are not patent eligible.
Claims 4, 11, and 18 recite the additional elements “wherein the enriched data is attached to a posted charge for the transaction after the enriched data is uploaded.” The limitations are the enriched data is attached to posted charge – the claims individually or in combination with others do not integrate the abstract idea into a practical application or provide an inventive concept to the abstract idea. The claims are not patent eligible.
Claims 5, 12, and 19 recite the additional elements “comprising: sending, by the client device a dispute notification for a send pending charge associated with a second transaction to the remote computing device.” The limitations are sending a dispute notification for a send pending charge associated with a second transaction – the claims individually or in combination with others do not integrate the abstract idea into a practical application or provide an inventive concept to the abstract idea. The claims are not patent eligible.
Claims 6, 13, and 20 recite the additional elements “wherein the pending charge comprises: an authorization code for transferring the enriched data from the pending charge to a posted charge of the transaction.” The limitations are the additional detailed information for the pending charge – the claims individually or in combination with others do not integrate the abstract idea into a practical application or provide an inventive concept to the abstract idea. The claims are not patent eligible.
Claims 7 and 14 recite the additional elements “comprising: receiving, by the client device, a notification of the pending charge in response to an authorization of the transaction.” The limitations are receiving a notification of the pending charge in response to an authorization – the claims individually or in combination with others do not integrate the abstract idea into a practical application or provide an inventive concept to the abstract idea. The claims are not patent eligible.
The dependent claims do not include additional elements, considered both individually and as an ordered combination, 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 element of using a computer to perform the displaying, uploading, linking, displaying, and receiving functions as claimed amounts to no more than mere instructions to apply the exception using a generic computer component. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Therefore, the dependent claims also are not patent eligible.
The focus of the claims is on using a computing device and a client device to automatically transfer of enriched transaction account data to a submitted record of charge. The claims are not directed to a new computing server, network, or system memory, nor do they provide a method for processing data that improves existing technical processes. The focus of the claims is not on improving computer-related technology, but on an independent abstract idea that uses computers as tools. The claims do not add a specific limitation or combination of limitations that are not well-understood, routine, conventional activity in the field. Accordingly, when viewed as a whole, the claims do no more than generally linking the use of the judicial exception to a particular technological environment or field of use. No inventive concept is found in the claims. Therefore, the claims do not add significantly more (i.e., an inventive step) to the abstract idea (Step 2B-No, the claims are not significantly more than the abstract idea).
Claim Rejections - 35 USC § 103
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
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.
The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
Determining the scope and contents of the prior art.
Ascertaining the differences between the prior art and the claims at issue.
Resolving the level of ordinary skill in the pertinent art.
Considering objective evidence present in the application indicating obviousness or nonobviousness.
Claims 1-20 are rejected under 35 U.S.C. 103 as being unpatentable over Chelst (US Pub. No. 2014/0108210) (hereinafter “Chelst”) in view of Moulton (US Pub. No. 2006/0169767) (hereinafter “Moulton”) and further in view of Chisholm (US Pub. No. 2012/0130897) (hereinafter “Chisholm”).
As per Claim 1, Chelst teaches a method, comprising:
Chelst in view of Moulton teaches the following limitations:
displaying, by a client device, a list of pending charges via a display of the client device (see Chelst, para. 70 “receiving an image of the receipt”, 71-73; Figure 4/element 402. See Moulton, para. 48 “posted charges and pending charges”);
Chelst in view of Moulton and Chisholm teaches the following limitations:
based on an authorization of a transaction, uploading enriched data associated with a pending charge to a remote computing device (see Chisholm, Abstract “a method for enriching the data associated with financial transaction card transactions”. See Chelst, para. 70-73; Figure 4. See Moulton, para. 48 “posted charges and pending charges”; Figure 1);
Chelst in view of Moulton teaches the following limitations:
responsive to the enriched data being moved from an authorization data enrichment storage of the remote computing device to a posted charge data enrichment database of the remote computing device, linking the enriched data stored in the posted charge data enrichment database to corresponding posted transactions (see Chelst, para. 70-73; Figure 4. See Moulton, para. 48 “posted charges and pending charges”; Figure 1);
displaying, via the client device, one or more of the enriched data stored in the authorization data enrichment storage or the enriched data stored in the posted charge data enrichment database (see Moulton, para. 48 “The UI 110 provides an intuitive, visual and easy-to-use display of items, including, but not limited to, consolidated real-time account information, payment options, posted charges and pending charges. This allows the user real-time access to all database-posted transactions as well as current pending charges. ...”); and
receiving, by the client device, one or more of a reminder, an expense report, or account management information from the remote computing device, wherein the one or more of the reminder, the expense report, or the account management information is generated by the remote computing device using the enriched data (see Chelst, para. 91-97; Figures 8-9. See Moulton, para. 48 “posted charges and pending charges”; Figure 1).
Chelst discloses every limitation except the limitation “enriched data”. However, Chisholm teaches such limitation (see abstract). Chelst in view of Chisholm does not disclose the limitation “pending charges and posted charges”. However, Moulton teaches such limitation (see para. 48). It would have been obvious to one of ordinary skill in the art at the time of the invention was filed to incorporate the features, as taught by Chisholm and Moulton, in the method of Chelst in order to facilitate a better way for expense management. Since Chelst, Chisholm, and Moulton are all directed to transaction management, one of ordinary skill in the art would have been motivated to combine the prior arts to achieve the claimed invention and that there would have been a reasonable expectation of success.
As per Claim 2, Chelst further teaches wherein the enriched data comprises at least one of: text, an image, a file, an expense tag, a document, or a note (see Chelst, para. 70-73; Figure 4/elements 402-404).
As per Claim 3, Chelst in view of Moulton further teaches comprising: accessing, by the client device, the list of pending charges from the remote computing device, wherein the list of pending charges includes the pending charge of the transaction before the transaction is listed on the record of posted charges, and wherein the list of pending charges is associated with and corresponds to a transaction account of a user (see Chelst, para. 70 “receiving an image of the receipt”, 71-73; Figure 4/element 402. see Moulton, para. 48 “posted charges and pending charges”).
It would have been obvious to one of ordinary skill in the art at the time of the invention was filed to incorporate the features, as taught by Moulton, in the method of Chelst in order to facilitate a better way for expense management (see Chelst, para. 8).
As per Claim 4, Chelst in view of Moulton further teaches wherein the enriched data is attached to a posted charge for the transaction after the enriched data is uploaded (see Chelst, para. 70-73; Figure 4. see Chisholm, Abstract “a method for enriching the data associated with financial transaction card transactions”. see Moulton, para. 48 “posted charges and pending charges”; Figure 1).
It would have been obvious to one of ordinary skill in the art at the time of the invention was filed to incorporate the features, as taught by Moulton, in the method of Chelst in order to facilitate a better way for expense management (see Chelst, para. 8).
As per Claim 5, Chelst further teaches comprising: sending, by the client device a dispute notification for a send pending charge associated with a second transaction to the remote computing device (see Chelst, para. 75).
As per Claim 6, Moulton further teaches wherein the pending charge comprises: an authorization code for transferring the enriched data from the pending charge to a posted charge of the transaction (see Moulton, para. 87 “The POS terminal sends an authorization request to the database to obtain authorization for the transaction. The database communicates the authorization request to the financial institution associated with the account designated by the user. The financial institution authorizes the transaction and sends an authorization code indicating that the transaction is authorized to the database. The database sends the authorization code to the POS terminal.”; Figure 5).
It would have been obvious to person of ordinary skill in the art at the time of the invention was filed to combine the teachings of Chelst and Moulton with the motivation of providing the authorization code for transferring the enriched data from the pending charge to a posted charge of the transaction in order to achieve the claimed invention (see Chelst, para. 8).
As per Claim 7, Moulton further teaches comprising: receiving, by the client device, a notification of the pending charge in response to the authorization of the transaction (see Moulton, para. 87 “The POS terminal sends an authorization request to the database to obtain authorization for the transaction. The database communicates the authorization request to the financial institution associated with the account designated by the user. The financial institution authorizes the transaction and sends an authorization code indicating that the transaction is authorized to the database. The database sends the authorization code to the POS terminal.”; Figure 5).
It would have been obvious to person of ordinary skill in the art at the time of the invention was filed to combine the teachings of Chelst and Moulton with the motivation of providing the notification feature for the pending charge in response to the authorization of the transaction in order to achieve the claimed invention (see Chelst, para. 8).
As per Claim 8, this claim written in system form corresponds to claim 1 and has the same elements and limitations. Hence, it is rejected under the rationale provided in claim 1.
As per Claim 9, this claim written in system form corresponds to claim 2 and has the same elements and limitations. Hence, it is rejected under the rationale provided in claim 2.
As per Claim 10, this claim written in system form corresponds to claim 3 and has the same elements and limitations. Hence, it is rejected under the rationale provided in claim 3.
As per Claim 11, this claim written in system form corresponds to claim 4 and has the same elements and limitations. Hence, it is rejected under the rationale provided in claim 4.
As per Claim 12, this claim written in system form corresponds to claim 5 and has the same elements and limitations. Hence, it is rejected under the rationale provided in claim 5.
As per Claim 13, this claim written in system form corresponds to claim 6 and has the same elements and limitations. Hence, it is rejected under the rationale provided in claim 6.
As per Claim 14, this claim written in system form corresponds to claim 7 and has the same elements and limitations. Hence, it is rejected under the rationale provided in claim 7.
As per Claim 15, this claim written in computer program form corresponds to claim 1 and has the same elements and limitations. Hence, it is rejected under the rationale provided in claim 1.
As per Claim 16, this claim written in computer program form corresponds to claim 2 and has the same elements and limitations. Hence, it is rejected under the rationale provided in claim 2.
As per Claim 17, this claim written in computer program form corresponds to claim 3 and has the same elements and limitations. Hence, it is rejected under the rationale provided in claim 3.
As per Claim 18, this claim written in computer program form corresponds to claim 4 and has the same elements and limitations. Hence, it is rejected under the rationale provided in claim 4.
As per Claim 19, this claim written in computer program form corresponds to claim 5 and has the same elements and limitations. Hence, it is rejected under the rationale provided in claim 5.
As per Claim 20, this claim written in computer program form corresponds to claim 6 and has the same elements and limitations. Hence, it is rejected under the rationale provided in claim 6.
Response to Arguments
Double Patenting
In view of Applicant’s 05/21/2026 comments, the rejection is MAINTAINED.
Claim Rejections - 35 USC § 101
Applicant's arguments filed on 05/21/2026 have been fully considered but they are not persuasive.
Applicant argues that the enrichment data view interface 146 provides a practical application because it produces a specific, concrete improvement in how transaction account holders interact with their financial transaction data. The Applicant argues in pages 9-10 of the Remarks:
“Without the enrichment data view interface 146, enrichment data uploaded by transaction account holder 110, merchant 120, or third party 130 through the enrichment data capture interface 144 and stored in data enrichment storage database 150 would remain inaccessible to the holder. The enrichment data view interface 146 solves this problem by connecting, over path 179A or path 179B, to both the pending-charge enrichment data and the posted-charge enrichment data (step 152), and making that data available to transaction account holder 110 for viewing (step 116). Critically, the specification describes in ¶ 33 that this viewing may occur before posting (path 178A), meaning the holder does not have to wait for the full charge posting lifecycle to complete before accessing enrichment information such as receipts, documents, tags, notes, warranties, itineraries, reminders, deadlines, or product manuals that were attached at the authorization or pending stage.
This is not an abstract idea applied to a computer generically. Rather, the enrichment data view interface 146 is a specific technical component within the transaction account processing system 140 that occupies a defined position in the system architecture: the enrichment data view interface 146 is downstream of the enrichment data capture interface 144, downstream of the automated data transfer of step 151, and distinct from the reminder dispatch path of step 147. The enrichment data view interface 146 operates along specifically identified paths (179A, 179B, 178A) to bridge the gap between stored enrichment data and the holder's ability to access it across two transaction lifecycle stages (pending and posted). The result is a concrete improvement to the functioning of the transaction account processing system 140 itself, because enrichment data that would otherwise sit unused in storage is surfaced to the holder at the point when it is most useful, including before the charge has even been posted.”
Response:
The Examiner notes that the technical detailed arguments presented in the 05/21/2026 Response (see the cited paragraphs above) are not recited in the present claims or in the newly added limitation “display, via the client device, one or more of the enriched data stored in the authorization data enrichment storage or the enriched data stored in the posted charge data enrichment database;”. Since the Examiner performs the analysis according to what is recited in the claims, the Examiner interprets that Applicant argues that the newly added limitation provides a practical application or integrates the abstract idea into a practical application. The Examiner respectfully disagrees. The newly added limitation is basically no more than displaying data (the enriched data stored in either the authorization data enrichment storage or the posted charge data enrichment database). The newly added limitation further narrow the scope of the claims, but does not change the 101 analysis. As explained in the December 16, 2014, Interim Eligibility Guidance from the USPTO (in reference to the buySAFE, Inc. v. Google, Inc. Decision), further narrowing the details of an abstract idea does not change the 101 analysis since a narrower abstract idea does not make it any less abstract. Therefore, Applicant’s amendments and arguments are not persuasive and the rejection of the claims under 35 USC § 101 is MAINTAINED.
Claim Rejections - 35 USC § 103
Applicant's arguments filed on 05/21/2026 have been fully considered but they are not persuasive. Applicant’s newly added limitation is disclosed in the Moulton reference in paragraph 48 of Publication No. 2006/0169767-A1. Therefore, Applicant’s amendments and arguments are not persuasive and the rejection of the claims under 35 USC § 103 is MAINTAINED.
Conclusion
Claims 1-20 are rejected.
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). 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 nonprovisional extension fee (37 CFR 1.17(a)) 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 HAI TRAN whose telephone number is (571)272-7364. The examiner can normally be reached Monday-Friday, 9-5.
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, Christine M. Behncke can be reached at 571-272-8103. 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.
HAI TRAN
Primary Examiner
Art Unit 3695
/HAI TRAN/Primary Examiner, Art Unit 3695
Prosecution Insights