Prosecution Insights
Last updated: October 23, 2026
Application No. 18/977,484

SYSTEMS AND METHODS FOR SPACE-BASED TRANSACTIONS

Final Rejection §101§102
Filed
Dec 11, 2024
Priority
Feb 25, 2020 — provisional 62/981,457 +2 more
Examiner
ROSEN, ELIZABETH H
Art Unit
Tech Center
Assignee
JPMorgan Chase Bank, N.A.
OA Round
2 (Final)
46%
Grant Probability
Moderate
3-4
OA Rounds
1y 6m
Est. Remaining
96%
With Interview

Examiner Intelligence

Grants 46% of resolved cases
46%
Career Allowance Rate
108 granted / 235 resolved
-14.0% vs TC avg
Strong +50% interview lift
Without
With
+49.9%
Interview Lift
resolved cases with interview
Typical timeline
3y 5m
Avg Prosecution
47 currently pending
Career history
303
Total Applications
across all art units

Statute-Specific Performance

§101
34.2%
-5.8% vs TC avg
§103
30.5%
-9.5% vs TC avg
§102
7.1%
-32.9% vs TC avg
§112
21.0%
-19.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 235 resolved cases

Office Action

§101 §102
DETAILED ACTION Status of Application This action is a Final Rejection. This action is in response to the amendment and response filed on August 4, 2026. Claims 1-11 have been canceled. Claims 12 and 21 have been amended. Claims 12-29 are pending and rejected. The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . 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 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. Response to Arguments Regarding the rejection under 35 U.S.C. § 101, Applicant argues that the claims do not recite certain methods of organizing human activity because “[t]here is no recitation of hedging, insurance, mitigating risk, agreements in the form of contracts, legal obligations, advertising, marketing or sales activities or behaviors, business relations, or managing social activities, teaching, and following rules or instructions between people.” Remarks at 10. However, as explained in the rejection, the claims are directed to a foreign exchange transaction, which is a commercial or legal interaction such as a sales activity or behavior or a business relation. Applicant further argues that “the claims integrate any alleged judicial exception into a practical application using the additional elements of ‘determining, by the first space-based user computer processor, that will be incapable of executing the foreign exchange transaction’ and ‘transferring, first space-based computer processor, the foreign exchange transaction to the second space-based computer processor, wherein the second space-based computer processor is configured to execute the foreign exchange transaction.’ None of the alleged abstract ideas contemplate these additional elements. These elements together recite a meaningful way of using the alleged judicial exception beyond generally linking the use of the judicial exception to a particular technological environment.” Remarks at 11. However, these limitations are broad and recited at a high level. Transferring a transaction to another processor does not integrate the abstract idea into a practical application. Applicant further argues that it is “far from routine and conventional for a first space-based device to transfer a payment to a second space-based device in response to the transfer of a service.” Remarks at 11. The rejection does not assert that the additional elements are well-understood, routine, or conventional. Additionally, transferring a payment or other transaction from one computer to another can be done by computers in any location. Except for stating that the devices are space-based, there is nothing else about the transaction in claim 12, for example, that requires more than performing a transaction that could otherwise be performed on land-based devices. Therefore, the abstract idea is merely being linked to space-based devices. As such, the rejection under 35 U.S.C. § 101 is maintained. Claim Objections Claim 12 is objected to for the following reason: Claim 12 recites “identifying, by the first space-based user and using a first space-based user computer processor, a second space-based user as a counterparty to the foreign exchange transaction, wherein the second space-based user is associated with a second space-based device comprising a second space-based computer processor.” Because there is a prior reference to “a first space-based user computer processor,” it appears that Applicant intended to instead recite “the first space-based user computer processor” in this limitation. Appropriate correction is required. Claim 12 is objected to for the following reason: Claim 12 recites “transferring, first space-based computer processor, the foreign exchange transaction to the second space-based computer processor, wherein the second space-based computer processor is configured to execute the foreign exchange transaction.” There appears to be a typographical error in this limitation. For examination purposes, it is being interpreted as “transferring, by the first space-based computer processor….” Appropriate correction is required. 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 12-29 are rejected under 35 U.S.C. § 101 as being directed to non-statutory subject matter because the claimed invention is directed to an abstract idea without significantly more. Step 1: Does the Claim Fall within a Statutory Category? (see MPEP 2106.03) Yes, with respect to claims 12-20, which recite a method and, therefore, are directed to the statutory class of process. Yes, with respect to claims 21-29, which recite a non-transitory computer readable medium and, therefore, are directed to the statutory class of manufacture. Step 2A, Prong One: Is a Judicial Exception Recited? (see MPEP 2106.04(a)) The following claims (Claims 12-20 are representative) identify the limitations that recite the abstract idea in regular text and that recite additional elements in bold: 12. A method for conducting space-based foreign exchange transactions, comprising: determining, by a first space-based user and using a first space-based user computer processor on a first space-based device, that a foreign exchange transaction is needed; identifying, by the first space-based user and using a first space-based user computer processor, a second space-based user as a counterparty to the foreign exchange transaction, wherein the second space-based user is associated with a second space-based device comprising a second space-based computer processor; agreeing, by the first space-based user and using the first space-based user computer processor, to a foreign exchange rate with the second space-based user; determining, by the first space-based user computer processor, that it will be incapable of executing the foreign exchange transaction; transferring, first space-based computer processor, the foreign exchange transaction to the second space-based computer processor, wherein the second space-based computer processor is configured to execute the foreign exchange transaction; and writing, by the second space-based computer processor and to a distributed ledger platform, the foreign exchange transaction and the foreign exchange rate, wherein a smart contract executes the foreign exchange transaction using the foreign exchange rate and updates balances in a first space-based user electronic wallet and a second space-based user electronic wallet. 13. The method of claim 12, wherein the foreign exchange transaction is associated with a pending or potential transaction with the second space-based user. 14. The method of claim 12, wherein the foreign exchange transaction is associated with a pending or potential transaction with a third space-based user. 15. The method of claim 12, wherein the foreign exchange transaction is for stablecoins in a first currency for stablecoins in a second currency. 16. The method of claim 12, wherein the foreign exchange rate is retrieved from a space-based oracle. 17. The method of claim 12, wherein the foreign exchange rate is programmatically determined. 18. The method of claim 12, wherein the foreign exchange rate is based on a bilateral agreement between the first space-based user and the second space-based user. 19. The method of claim 12, wherein the first space-based device and/or the second space-based device are satellites. 20. The method of claim 12, further comprising: transferring, by the first space-based user and using the first space-based user computer processor, a balance of the first space-based user electronic wallet to an Earth-based user electronic wallet. Yes. But for the recited additional elements as shown above in bold, the remaining limitations of the claim recite certain methods of organizing human activity. The claim limitations identified as abstract idea are directed to a foreign exchange transaction. This type of method of organizing human activity is a fundamental economic practice because it involves a payment and an exchange of value, and it is a commercial or legal interaction such as a sales activity or behavior or a business relation. Thus, the claims recite an abstract idea. Step 2A, Prong Two: Is the Abstract Idea Integrated into a Practical Application? (see MPEP 2106.04(d)) No. The claims as a whole merely use a computer as a tool to perform the abstract idea. The technology related components (i.e., additional elements that are in bold above) are recited at a high level of generality and are merely invoked as tools to perform the abstract idea. For example, the claimed invention is shown in Figure 3 and described in paragraphs 0073-0090 of Applicant’s Specification. Both the claims and Applicant’s Specification describe the additional elements at a very high level such that the claimed foreign exchange transaction is merely being linked to a particular technological environment, i.e., space based devices. Additionally, the claimed computer processors of the first and second space based devices are being used as tools to implement the foreign exchange transaction. Simply implementing the abstract idea using a programmed general purpose consumer device is not a practical application of the abstract idea. Additionally, there is no improvement to the functioning of a computer or technology. Therefore, the abstract idea is not integrated into a practical application. Step 2B: Does the Claim Provide an Inventive Concept? (see MPEP 2106.05) No. As discussed with respect to Step 2A, Prong 2, the additional elements in the claims, both individually and in combination, amount to no more than tools to perform the abstract idea. Merely performing the abstract idea using a computer cannot provide an inventive concept. Therefore, the claims do not provide an inventive concept. As such, the claims are not patent eligible. 35 U.S.C. §§ 102 and 103 The Office action does not include a rejection under 35 U.S.C. §§ 102 or 103. This particular combination of limitations was not found in or made obvious by the prior art. Per paragraph 0027 of Applicant’s Specification, the claimed space-based devices were construed as devices such as satellites or space stations that are located in space and not on Earth. Additionally, paragraph 0053 of the Specification distinguishes between Earth-based and space-based users. The claims are novel and non-obvious for reasons similar to parent application number 18/468,191 and in light of the Specification and an updated search of the prior art. Double Patenting The Double Patenting rejection is withdrawn in light of the Terminal Disclaimer that was filed and approved on August 4, 2026. Relevant Prior Art The following references are relevant to Applicant’s invention: Metzger et al., U.S. Patent Application Publication Number 2019/0289018 A1. This reference teaches a system for managing data storage in a satellite platform. Shasha, U.S. Patent Application Publication Number 2020/0220732 A1. This reference teaches cubesats that are equipped with a hardware security module and receive transactions from users. Coleman et al., U.S. Patent Application Publication Number 2020/0028908 A1. This reference teaches distributed storage management in a spaceborne or airborne environment. Boyle, Alan. “How Satellites and Blockchain go Together”, Geekwire, https://www.geekwire.com/2019/satellites-blockchain-go-together/, (Feb. 1, 2019). Boyle discusses combining blockchain technology with satellites. J. d. La Beaujardiere, R. Mital and R. Mital, "Blockchain Application Within A Multi-Sensor Satellite Architecture," IGARSS 2019 - 2019 IEEE International Geoscience and Remote Sensing Symposium, Yokohama, Japan, 2019, pp. 5293-5296, doi: 10.1109/IGARSS.2019.8898117. This reference teaches the use of blockchain within satellite architectures. Ge, Shen. “Usage of Cryptocurrency with Satellites,” https://www.linkedin.com/pulse/usage-cryptocurrency-satellites-shen-ge-pmp-cssgb-%E8%91%9B%E5%B1%BE- (Dec. 23, 2017). This reference teaches satellite data storage for use with cryptocurrency. Gruner, U.S. Patent Application Publication Number 2014/0244499 A1. This reference teaches off-shore money transfer transactions that use satellite systems. Email Communications Per MPEP 502.03, Applicant may authorize email communications by filing Form PTO/SB/439, available at https://www.uspto.gov/sites/default/files/documents/sb0439.pdf, via the USPTO patent electronic filing system. 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 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 ELIZABETH H ROSEN whose telephone number is (571) 270-1850 and email address is elizabeth.rosen@uspto.gov. The examiner can normally be reached Monday - Friday, 10 AM ET - 7 PM ET. 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, Michael Anderson, can be reached at 571-270-0508. 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. /ELIZABETH H ROSEN/Primary Examiner, 3693
Read full office action

Prosecution Timeline

Dec 11, 2024
Application Filed
May 13, 2026
Non-Final Rejection mailed — §101, §102
Aug 04, 2026
Response Filed
Oct 09, 2026
Final Rejection mailed — §101, §102 (current)

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Prosecution Projections

3-4
Expected OA Rounds
46%
Grant Probability
96%
With Interview (+49.9%)
3y 5m (~1y 6m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 235 resolved cases by this examiner. Grant probability derived from career allowance rate.

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