DETAILED ACTION
This Office action is in reply to correspondence filed 13 August 2026 in regard to application no. 18/982,202. Claims 6 and 8 have been cancelled. Claims 1-5, 7 and 9-17 are pending and are considered below.
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 .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 14 July 2026 has been entered.
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 1-5, 7 and 9-17 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. The claims lie within statutory categories of invention, as each is directed to a method (process), device (machine), or non-transitory computer readable medium (manufacture). The claim(s) recite(s) generating a request in no particular manner but simply based on certain data, sending a result to someone, gathering data, sending more data including data pertaining to a service to be performed, processing a payment, gathering additional data, and sending additional data.
As the whole point of this is to manage payment information, it recites a fundamental business practice and a commercial interaction; merchants have been managing payment information for decades, including before there was any such thing as a computer. Further, in the absence of computers, these are steps that can be performed mentally and/or by the use of paper records.
A merchant can create a service code by simply assigning a number to a particular customer request, can perform whatever service was requested, and can send and receive invoices and payments with identifiers on them. None of this presents any practical difficulty and none requires any technology beyond pen and paper.
This judicial exception is not integrated into a practical application because aside from the bare inclusion of a generic computer, discussed below, nothing is done beyond what was set forth above, which does not go beyond generally linking the abstract idea to the technological environment of generic, networked computers. See MPEP § 2106.05(h).
As the claims only manipulate data pertaining to invoices, payments and the like, they do not improve the "functioning of a computer" or of "any other technology or technical field". See MPEP § 2106.05(a). They do not apply the abstract idea "with, or by use of a particular machine", MPEP § 2106.05(b), as the below-cited Guidance is clear that a generic computer is not the particular machine envisioned.
They do not effect a "transformation or reduction of a particular article to a different state or thing", MPEP § 2106.05(c). First, such data, being intangible, are not a particular article at all. Second, the claimed manipulation is neither transformative nor reductive; as the courts have pointed out, in the end, data are still data.
They do not apply the abstract idea "in some other meaningful way beyond generally linking [it] to a particular technological environment", MPEP § 2106.05(e), as the lack of technical and algorithmic detail in the claims is SO as not to go beyond such a general linkage.
The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional claim limitations, considered individually and as an ordered combination, are insufficient to elevate an otherwise-ineligible claim.
Claim 16, which has the most, includes a processor, memory storing instructions, and a network interface. These elements are recited at a high degree of generality and the specification is explicit, ¶ 149, that nothing more than a "general-purpose computer" is required.
It only performs generic computer functions of nondescriptly manipulating data and sharing data with persons and/or other devices. Generic computers performing generic computer functions, without an inventive concept, do not amount to significantly more than the abstract idea.
The type of information being manipulated does not impose meaningful limitations or render the idea less abstract. Steps performed by external, unclaimed elements such as the management platform have no effect on this analysis as they are considered but given no patentable weight. The claim elements when considered in ordered combination - a generic computer performing a chronological sequence of abstract steps - do nothing more than when they are analyzed individually. The other independent claims are simply different embodiments but are likewise directed to a generic computer performing, essentially, the same process.
The dependent claims further do not amount to significantly more than the abstract idea: claims 2 and 3 are simply further descriptive of the type of information being manipulated. Claims 4, 5, 7, 9, 12, 14 and 15 simply recite further, abstract manipulation of data. Claims 10 and 13 simply specify storing and/or outputting data; claim 11 simply recites additional input.
The claims are not patent eligible. The Examiner has thoroughly reviewed the originally-filed application, including the specification and drawing sheets, and finds nothing likely sufficient to overcome this rejection.
For further guidance please see MPEP § 2106.03 – 2106.07(c) (formerly referred to as the “2019 Revised Patent Subject Matter Eligibility Guidance”, 84 Fed. Reg. 50, 55 (7 January 2019, revised October 2019)).
Response to Arguments
Applicant's arguments filed 14 July 2026 have been fully considered but they are not persuasive. The Examiner respectfully disagrees with the applicant that the steps – which steps are not clear – cannot be performed mentally or with pens and paper.
The mere fact that computers are used, with ubiquitous components such as processors, memory and a network interface, does not alter the analysis as to what the claims recite, and the use of computers is not, per se, sufficient. See MPEP § 2106.04(III), pointing out that the courts do not “distinguish between claims that recite mental processes performed by humans and claims that recite mental processes performed on a computer.”
The Examiner has never said, and does not say now, that the present claims recite mathematical formulas, etc., so arguments to the contrary are not relevant. Again, the Examiner does not see how it would be the least bit difficult for a human, mentally or with pen and paper, to perform any part of the claimed process, and the Examiner has explained the specific “methods of organizing human activity” recited in the claim and is not persuaded by conclusory statements to the contrary.
In regard to the question of integration into a practical application, processing invoices is a business and not a technical problem, and it does not become a technical problem merely because computers are used.
In regard to the “significantly more” inquiry, the lack of a rejection under § 103 is simply not relevant. This inquiry focuses on the additional, that is, non-abstract claim elements, and there is no additional element present in any claim beyond a generic computer with generic computer components.
The claims are not patent eligible and the rejection is maintained.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to SCOTT C ANDERSON whose telephone number is (571)270-7442. The examiner can normally be reached M-F 9:00 to 5:30.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Bennett Sigmond can be reached at (303) 297-4411. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/SCOTT C ANDERSON/ Primary Examiner, Art Unit 3694
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