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 office action is in response to applicant's communication of January 21, 2026. The rejections are stated below. Claims 1-20 are pending and have been examined.
Response to Arguments
Applicant’s arguments concerning claims 1-20 rejected under 101 have been considered but are not persuasive. The claims, including amended claim 15, are directed to the abstract idea of organizing, analyzing, and resolving financial disputes based on historical behavior. This concept falls within the categories of fundamental economic practices and methods of organizing human activity that the Supreme Court has identified as abstract. The claims involves generating a query to retrieve an account description, creating a prompt, using a large language model to generate a resolution recommendation, and then approving or denying a chargeback. This process describes a basic mechanism for adjudicating a financial dispute. The Supreme Court in Alice held that claims directed to a method of mitigating settlement risk were abstract. Similarly, in Bilski v. Kappos, 561 U.S. 593 (2010), the Court held that claims directed to hedging risk were abstract. The present claims recite a parallel economic practice of resolving a chargeback dispute based on historical account behavior.
The claims also describe a mental process. Comparing a current transaction to historical patterns, generating a recommendation, and making an approve or deny decision are steps that can be performed in the human mind using reasoning and judgment. The Federal Circuit in Electric Power Grp., LLC v. Alstom S.A., 830 F.3d 1350, 1353 54 (Fed. Cir. 2016) explained that claims focused on collecting information, analyzing it, and displaying results were directed to an abstract idea because such operations could be performed by a human using pen and paper. The same principle applies here.
The claims fail Step 2B because they do not recite “significantly more” than the abstract idea itself. The additional elements, such as using a “first ML model,” a “second ML model comprising an LLM,” “pre calculated n dimensional vectors,” and a “database,” are described in the specification as performing functions that are standard for such components. The specification does not assert that any of these components operate in a new or unconventional manner. The steps of training a vector database LLM, producing vectors, storing them in a database, generating a query, retrieving a vector, generating a prompt, submitting the prompt to an LLM, and then approving or denying a chargeback based on the output are all steps that a person could perform using existing computing tools. The Supreme Court in Alice stated that “the mere recitation of a computer cannot transform a patent ineligible abstract idea into a patent eligible invention.” 573 U.S. at 225. The computer components recited in the claims are not claimed in a manner that creates a new type of computer or a new way of operating a computer. Instead, they are invoked to perform the abstract idea of dispute resolution.
Applicant argues that the specification describes technological improvements, such as “efficient and accurate fraud identification.” However, improvements in the speed or accuracy of performing an abstract business process, achieved by using a computer to execute that process, do not convert an abstract idea into patent eligible subject matter. The Federal Circuit in OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015) explained that “merely selecting information, analyzing it using mathematical techniques, and reporting or displaying the results of that analysis does not turn an abstract idea into patent eligible subject matter”. The claimed improvement is in the outcome of the business process, not in the functioning of the computer or network itself.
Applicant’s reliance on Enfish, Example 47, and Desjardins does not overcome the Alice framework as applied to the present claims. In Enfish, the Federal Circuit found claims eligible because they were directed to a specific improvement in computer functionality, namely a self referential table that provided faster searching and more efficient memory use compared to prior database structures. The present claims are not directed to any improvement in computer or machine learning model architecture. The claims do not recite a new type of large language model, a novel vector database structure, or a new training algorithm. They recite the use of a first ML model to generate a query, the use of an LLM to generate a recommendation, and the use of a database to store vectors. These are descriptions of using existing computing components to perform a dispute resolution process. The Enfish court distinguished claims that “are simply directed to the use of a computer as a tool” from claims that are directed to a specific improvement to computer capabilities. The present claims fall into the former category.
The Example 47 claim integrated the judicial exception into a practical application by changing the state of a network. The present claims do not integrate the exception into a practical application that changes the technical state of any machine; they merely report the result of an analysis.
The present claims are not directed to a machine learning training problem or to an improvement in how any model operates. The claims are directed to a dispute resolution method that uses machine learning models as tools. The specification’s description of benefits such as “faster” and “more accurate” dispute resolution are benefits to the business process, not technical benefits to the machine learning models themselves. The PTAB in Desjardins did not hold that any claim involving a machine learning model is eligible. It held that claims directed to an improvement in the training and operation of the model itself were eligible. The present claims are not of that nature.
Applicant’s remarks concerning claims 1-20 under U.S.C. 102 have been considered and are persuasive. Kramme does not disclose “generate, via a first machine learning (ML) model, a database query for chargeback dispute resolution for a financial transaction between a customer account and a merchant account; retrieve, using the database query, an account behavior description for one or both of the customer account or the merchant account; generate a dispute resolution prompt based on the account behavior description; submit the dispute resolution prompt to a second ML model comprising an LLM to generate a resolution recommendation”.
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 of financial chargeback dispute resolution without significantly more.
Claim 15 is directed to a method which is one of the four statutory categories of invention (Step 1: YES).
Claim 15 recites a “method to evaluate and recommend financial products for a plurality of customers using …, the method comprising:
… LLM on historical transaction data across a plurality of
accounts and account holders;
… a plurality of n-dimensional vectors corresponding to individual accounts and comprising account behavior descriptions;
… query for chargeback dispute resolution for a financial transaction between a customer account and a merchant account;
… query to search the plurality of n-dimensional vectors in the …, of the account behavior descriptions for one or both of the customer account or the merchant account;
… based on the one of the account
behavior descriptions;
… to a second ML model comprising an LLM to generate a resolution recommendation; and
approving a chargeback corresponding to the financial transaction based on the resolution recommendation by automatically refunding the customer, or denying the chargeback corresponding to the financial transaction based on the resolution recommendation by notifying an issuing bank that the chargeback was denied”.
These limitations describe an abstract idea of financial chargeback dispute resolution and corresponds to Certain Methods of Organizing Human Activity (fundamental economic principles such as mitigating risk). Accordingly, claim 15 recites an abstract idea (Step 2A: Prong 1: YES).
The claim also recites as additional elements such as “computer, one or more processor and/or transceivers, database, training a vector database, producing with the vector database LLM and storing in a database, generating, via a first machine learning (ML) model, a database, retrieving, using the database, generating a dispute resolution prompt, submitting the dispute resolution prompt submitting the dispute resolution prompt ” which do no more than implement the abstract idea and/or provide a particular technological environment. Therefore, claim 15 recites an abstract idea without a practical application (Step 2A - Prong 2: NO).
Further, as the additional elements of claim 15 do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field. Thus, claim 15 is not patent eligible (Step 2B: NO).
Claims 1 and 8 also recite the abstract idea of financial chargeback dispute resolution and corresponds to Certain Methods of Organizing Human Activity (fundamental economic practices step one of step 2A (MPEP 2106.04). Claim 1 includes the additional elements of “system, one or more processors, memory device storing computer-executable instructions thereon that, when executed by the one or more processors, cause the one or more processors, and database”. Claim 8 includes the additional elements of “non-transitory computer readable media including computer-executable instructions …, when executed by at least one processor, cause the at least one processor, and database. The additional elements do no more than serve as a tool to implement the abstract idea and/or link the abstract idea a particular technological environment. Therefore, as they do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment, they do not improve computer functionality or improve another technology or technical field.
Claims 2, 9, and 16 each recite “the one of the account behavior description including a description of previous financial transactions between the customer account or the merchant account” which further define the abstract idea.
Claims 3, 10, and 17 each recite “the previous financial transactions being associated with corresponding chargeback events” which further define the abstract idea.
Claims 4, 11, and 18 each recite “the one of the account behavior description including a sum of chargeback transaction events involving the customer account” which further define the abstract idea.
Claims 5, 12, and 19 each recite “the one of the account behavior description including a sum of chargeback transaction events involving the merchant account” which further define the abstract idea.
Claims 6, 13, and 20 each recite “the account behavior description being pre-calculated” which further define the abstract idea.
Claims 7 and 14 each recite “the dispute resolution prompt including a description of one or more of the following with respect to the customer account: first chargebacks, pre- arbitration cases, arbitration cases, second presentments, pre-compliance cases, compliance cases, and fee collection cases” which further define the abstract idea.
Conclusion
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 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 KEVIN T POE whose telephone number is (571)272-9789. The examiner can normally be reached on Monday-Friday 9:30am through 6pm EST.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Ryan Donlon can be reached on 571-270-3602. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/K.T.P/Examiner, Art Unit 3692 /KEVIN T POE/
/RYAN D DONLON/Supervisory Patent Examiner, Art Unit 3692 July 24, 2026
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