DETAILED ACTION
Status of the Claims
The following is a non-final Office Action in response to claims filed 08 January 2025.
Claims 1-20 are pending.
Claims 1-20 have been examined.
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Priority
Applicant’s claim for the benefit of a provisional Application 63/618,596 under 35 U.S.C. 119(e) or under 35 U.S.C. 120, 121, or 365(c) is acknowledged.
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 is/are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. The claims are directed to a process (an act, or series of acts or steps), a machine (a concrete thing, consisting of parts, or of certain devices and combination of devices), and a manufacture (an article produced from raw or prepared materials by giving these materials new forms, qualities, properties, or combinations, whether by hand labor or by machinery). Thus, each of the claims falls within one of the four statutory categories (Step 1). The claims recite a method (process), system, and apparatus, however, the claim(s) recite(s) preparing and reporting beneficial ownership information which is an abstract idea of organizing human activities.
The limitations of “receiving registration details for the business entity from a representative of the business entity; electing a management protocol for the one or more types of BOI data from a set of management elections; querying for the one or more types of BOI data via a plurality of data input fields having a corresponding BOI data query for collecting a set of business entity details pertaining to the business entity; optionally transferring the management protocol from the representative to another representative of the business entity; preparing a BOI report; and filing the BOI report with FinCEN,” as drafted, is a process that, under its broadest reasonable interpretation, covers organizing human activities--fundamental economic principles or practices (including hedging, insurance, mitigating risk); commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations); managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions) but for the recitation of generic computer components (Step 2A Prong 1). That is, other than reciting “A computer implemented method for Beneficial Ownership Information (BOI) reporting with Financial Crime Enforcement Network (FinCEN), comprising: providing a cloud-based system for managing, collecting and filing one or more types of BOI data for a business entity; accessing the cloud-based system with a computer system, displaying on a screen of the computer system one or more webpages of the cloud-based system, and executing with the computer system the cloud-based system processes of:,” (or “A computer implemented system for Beneficial Ownership Information (BOI) reporting with Financial Crime Enforcement Network (FinCEN), comprising: a cloud-based system for managing, collecting and filing one or more types of BOI data for a business entity; a tangible computer readable medium comprising computer executable instructions tangibly embodied thereon which, when executed, cause a processor of a computer system to access the cloud-based system with the computer system, display on a screen of the computer system one or more webpages of the cloud-based system, and execute with the computer system the cloud-based system of:” in claim 8 or “A tangible computer readable storage medium comprising computer executable instructions tangibly embodied thereon which, when executed, cause a processor of a computer system to access a cloud-based system with the computer system, display on a screen of the computer system one or more webpages of the cloud-based system, and execute with the computer system the cloud-based system of managing, collecting and filing one or more types of BOI data for a business entity, the method comprising:” in claim 14) nothing in the claim element precludes the step from the methods of organizing human interactions grouping. For example, but for the “one or more cloud-based processors” or “processor of a computer system” language, “receiving,” “electing,” “querying,” “optionally transferring,” “preparing,” and “filing” in the context of this claim encompasses the user manually obtaining beneficial ownership information to be prepared and filed which is a business relation/fundamental economic practice/commercial or legal interaction. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation as one of the methods of organizing human activities, but for the recitation of generic computer components, then it falls within the “Certain Methods of Organizing Human Activities” grouping of abstract ideas. Accordingly, the claim(s) recite(s) an abstract idea (Step 2A, Prong One: YES).
This judicial exception is not integrated into a practical application (Step 2A Prong Two). In particular, the claim only recites one additional element – using one or more cloud-based processors or processor of a computer system to perform the steps. The processor in the steps is recited at a high-level of generality (i.e., as a generic processor performing a generic computer function of electronic data storage, query, and retrieval) such that it amounts no more than mere instructions to apply the exception using a generic computer component. Specifically the claims amount to nothing more than an instruction to apply the abstract idea using a generic computer or invoking computers as tools by adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea - see MPEP 2106.04(d)(I) discussing MPEP 2106.05(f). The claims recitation of the “providing a cloud-based system for managing, collecting and filing one or more types of BOI data for a business entity; accessing the cloud-based system with a computer system, displaying on a screen of the computer system one or more webpages of the cloud-based system” “a cloud-based system for managing, collecting and filing one or more types of BOI data for a business entity; a tangible computer readable medium comprising computer executable instructions tangibly embodied thereon which, when executed, cause a processor of a computer system to access the cloud-based system with the computer system, display on a screen of the computer system one or more webpages of the cloud-based system” and “cause a processor of a computer system to access a cloud-based system with the computer system, display on a screen of the computer system one or more webpages of the cloud-based system, and execute with the computer system the cloud-based system of managing, collecting and filing one or more types of BOI data for a business entity” is/are only generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.04(d)(I) discussing MPEP 2106.05(h). Accordingly, the combination of these additional elements does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. The claim is directed to an abstract idea, even when considered as a whole (Step 2A Prong Two: NO).
The claim does not include a combination of additional elements that are sufficient to amount to significantly more than the judicial exception (Step 2B). As discussed above with respect to integration of the abstract idea into a practical application (Step 2A Prong 2), the combination of additional elements of using a processor to perform the steps 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, when considering the additional elements alone, and in combination, there is no inventive concept in the claim. As such, the claim(s) is/are not patent eligible, even when considered as a whole (Step 2B: NO).
Claims 2, 9, and 16 recite(s) the additional limitation(s) further including some sort of payment acceptance, which is still directed towards the abstract idea previously identified and is not an inventive concept that meaningfully limits the abstract idea. Again, as discussed with respect to claims 1, 8, and 14, the claims are simply limitations which are no more than mere instructions to apply the exception using a computer or with computing components. Accordingly, the additional element(s) does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Even when considered as a whole, the claims do not integrate the judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B.
Claims 3-4, 10-11, 15, and 18 recite(s) the additional limitation(s) further limiting the transfer and label of the representative, which is still directed towards the abstract idea previously identified and is not an inventive concept that meaningfully limits the abstract idea. Again, as discussed with respect to claims 1, 8, and 14, the claims are simply limitations which are no more than mere instructions to apply the exception using a computer or with computing components. Accordingly, the additional element(s) does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Even when considered as a whole, the claims do not integrate the judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B.
Claim 5 recite(s) the use of “machine learning or artificial intelligence protocols” in the limitations also merely indicates a field of use or technological environment in which the judicial exception is performed. Although the additional element “machine learning or artificial intelligence protocols” limits the identified judicial exceptions, this type of limitation merely confines the use of the abstract idea to a particular technological environment (machine learning/artificial intelligence) and thus fails to add an inventive concept to the claims. See MPEP 2106.05(h). Again, as discussed with respect to claims 1, 8, and 14, the claims are simply limitations which are no more than mere instructions to apply the exception using a computer or with computing components. Accordingly, the additional element(s) does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Even when considered as a whole, the claims do not integrate the judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B.
Claims 6-7, 12-13, and 19-20 recite(s) the additional limitation(s) further limiting the data collection and reporting to being automated, which is still directed towards the abstract idea previously identified and is not an inventive concept that meaningfully limits the abstract idea. Again, as discussed with respect to claims 1, 8, and 14, the claims are simply limitations which are no more than mere instructions to apply the exception using a computer or with computing components. Accordingly, the additional element(s) does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on
Claims 1-20 are therefore not eligible subject matter, even when considered as a whole.
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:
1. Determining the scope and contents of the prior art.
2. Ascertaining the differences between the prior art and the claims at issue.
3. Resolving the level of ordinary skill in the pertinent art.
4. Considering objective evidence present in the application indicating obviousness or nonobviousness.
Claim(s) 1-4 and 6-20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Wilson et al. (US PG Pub. 2024/0281562) and further in view of Mulligan (US Patent No. 7,467,107).
As per claims 1, 8, and 14, Wilson discloses computer implemented method for Beneficial Ownership Information (BOI) reporting with Financial Crime Enforcement Network (FinCEN), a computer implemented system for Beneficial Ownership Information (BOI) reporting with Financial Crime Enforcement Network (FinCEN)a tangible computer readable storage medium comprising computer executable instructions tangibly embodied thereon which, when executed, cause a processor of a computer system to, the method comprising (rules promulgated by FinCEN under the CTA, Wilson ¶15-¶16; interface, Fig. 3A-3D; servers, client device, ¶20):
providing a cloud-based system for managing, collecting and filing one or more types of BOI data for a business entity (The governmental requirements reporting system 100 allows an individual 102 to connect to one or more cloud-based servers 110 over one or more networks 120 and create a secure individual account to contain their general info and PII. The individual 102 may utilize a computing device 104 to connect to the cloud-based server(s) 110 over the network(s) 120, Wilson ¶20);
accessing the cloud-based system with a computer system, displaying on a screen of the computer system one or more webpages of the cloud-based system, and executing with the computer system the cloud-based system processes of (The computing device 104 may represent any computing device, components, or systems that allow the individual 102 to access the functions of the governmental requirements reporting system 100, such as a mobile computing device, laptop or desktop computer, and the like. The computing device 104 may execute a client app 108 to access the governmental requirements reporting system 100. The client app 108 may comprise a mobile app executing on a mobile computing device, client-side portions of a web application executing in a web browser of a laptop or desktop computer, and the like. The network(s) 120 may comprise any combination of networking infrastructure that connects the computing device 104 to the cloud-based server(s) 110, such as LANs, WANs, 5G or LTE cellular data networks, and/or the Internet. The cloud-based server(s) 110 may represent virtualized computing resources available in the cloud, such as Amazon EC2 Cloud Computing services. In further embodiments, the cloud-based server(s) 110 may represent one or more of conventional web server, application server, and/or other application hosting environments executing on one more server computers, Wilson ¶20):
receiving registration details for the business entity from a representative of the business entity (The beneficial owners (individuals 102) may utilize the link to access the governmental requirements reporting system, create accounts, provide individual general information and PII, and provide consent to have their PII included in the company's required reports. The administrator 106 may have access to the status, general information, and consent provided by each individual 102 in the company account data as well as whether, e.g., identifying document(s) have been provided, Wilson ¶23; The governmental requirements reporting data 112 may further include company account data 128 associated with the company. The company account data 128 may include general company info (e.g., company name, company type, organization state, company ID, company address, etc.), a list of related individuals 102 and their roles (e.g., company members including beneficial owners, company administrator, billing contact, registered agent, etc.), the consent of each beneficial owner, the status of provision of identifying documents for each beneficial owner, and the like, ¶25);
querying for the one or more types of BOI data via a plurality of data input fields having a corresponding BOI data query for collecting a set of business entity details pertaining to the business entity (If, at step 208, all of the necessary information (e.g., legal name, date of birth, residential address, unique identifying number, identifying document(s), etc.) has been received from each required individual 102 associated with the company (e.g., beneficial owners), then the routine 200 proceeds to step 210, where the governmental requirements reporting system 100 facilitates filing of governmental requirements reports with the individual PII 122 of each required individual, Wilson ¶32);
optionally transferring the management protocol from the representative to another representative of the business entity (After the initial report is filed, if any item of previously reported data changes, the reporting company must file an amendment with the data change within 30 calendar days after the date of the change. Because the purpose of the CTA is to fight money laundering, there are steep penalties for failures to comply. A failure to file on time may result in a $500 per day fine, up to a maximum fine of $10,000. A willful failure to file (or willfully filing false information) may be punished as a felony by up to two years imprisonment. CTA violations that take place in connection with other financial crimes (such as money laundering) can result in enhanced penalties of up to ten years imprisonment) (Examiner notes the change or update to include a transfer of the management protocol from one entity, or representative thereof, to another, Wilson ¶17);
preparing a BOI report (According to embodiments, the governmental requirements reporting system 100 further has the capability to format the information stored for the company members (individuals 102), including each individual's PII, in the necessary format for governmental filings required by the government and, upon approval by the administrator 106 and/or the company's attorney, submit the filings securely over the networks 120 to an electronic governmental report submission system 130. In further embodiments, the governmental requirements reporting system 100 may facilitate paper based filings for compliance with the government reporting requirements, Wilson ¶24); and
filing the BOI report with FinCEN (According to embodiments, the governmental requirements reporting system 100 further has the capability to format the information stored for the company members (individuals 102), including each individual's PII, in the necessary format for governmental filings required by the government and, upon approval by the administrator 106 and/or the company's attorney, submit the filings securely over the networks 120 to an electronic governmental report submission system 130. In further embodiments, the governmental requirements reporting system 100 may facilitate paper based filings for compliance with the government reporting requirements, Wilson ¶24).
While Wilson discloses the ability to set up an account for an unlimited amount of companies and related individuals based upon their legal interest in the applicable reporting company(s) (“Let’s Set Up Your Account,” Wilson Fig. 3A; GUI diagrams for user interface and dashboard, Wilson ¶13 and ¶22), Wilson does not expressly disclose but/or does not expressly disclose electing a management protocol for the one or more types of BOI data from a set of management elections.
However, Mulligan teaches electing a management protocol for the one or more types of BOI data from a set of management elections (Written procedures identified by the compliance manual generator 170 may include procedures such as, for example, record keeping procedures, personal trading procedures, Patriot Act and/or AML procedures, disaster recovery procedures, procedures for detecting and/or preventing insider trading, procedures for ensuring compliance with ethical requirements, procedures relating to administration of brokerage/placement fee policies, procedures relating to principal and agency cross transactions, procedures relating to ERISA investment policies, and procedures relating to proxy voting. The compliance manual generator 170 may also identify a set of industry best practice standards to be observed by employees of the fund manager 101 involved in fund management. Because the fund manager 101 may manage multiple funds, the compliance manual generator 170 may be used to generate a compliance manual for each fund managed. he above-described steps of identifying, compiling, and formatting the one or more procedures to be followed by the fund manager 101 based upon the received data, collectively referred to as "compliance manual customization," are now described according to various embodiments. Based upon the fund manager's 101 answers provided in response to questions contained on the second and fourth web-based GUI screens 320, 340 ("Manager" and "Manual" screens, respectively) of the questionnaire 300 discussed above in connection with FIG. 3, one of multiple (e.g., eight) possible manual types may be identified as a "best fit" for the fund manager 101. In an embodiment, the answers to two multiple-choice questions may be used to identify one of the eight possible manual options based a comparison of the answers to a set of industry best practice standards, Mulligan Col. 9 lines 33-64).
Both the Mulligan and Wilson references are analogous in that both are directed towards/concerned with compliance reporting within the financial industry. Before the effective filing date of the claimed invention, it would have been obvious to a person of ordinary skill in the art to use Mulligan’s ability to provide customizable reporting as a service for a fee in Wilson’s reporting system to improve the system and method with reasonable expectation that this would result in a reporting management system that is able to provide the most accurate and applicable reporting requirements.
The motivation being that in order to ensure compliance with regulations, fund managers have historically needed to expend much time, money, and effort to develop and maintain a compliance infrastructure and associated business practices. For instance, necessary legal research and preparation of documentation (e.g., required reports and documentation of compliance practices) may be extensive, time-consuming, and labor-intensive. Additionally, to respond to rapidly changing regulatory environments, fund managers may need to seek costly on-site assistance from outside counsel and/or consultants. Given the attendant costs and complexities, some fund managers have not achieved full compliance with applicable regulations. Moreover, such costs and complexities may act as barriers to entry, preventing competent individuals from serving as fund managers, thus depriving investors of additional investment options in the marketplace (Mulligan Col. 1 lines 52-67).
As per claims 2, 9, and 16, Wilson and Mulligan disclose as shown above with respect to claims 1, 8, and 14. Mulligan further teaches accepting payment for filing the BOI report with FinCEN (Written procedures identified by the compliance manual generator 170 may include procedures such as, for example, record keeping procedures, personal trading procedures, Patriot Act and/or AML procedures, disaster recovery procedures, procedures for detecting and/or preventing insider trading, procedures for ensuring compliance with ethical requirements, procedures relating to administration of brokerage/placement fee policies, procedures relating to principal and agency cross transactions, procedures relating to ERISA investment policies, and procedures relating to proxy voting. The compliance manual generator 170 may also identify a set of industry best practice standards to be observed by employees of the fund manager 101 involved in fund management. Because the fund manager 101 may manage multiple funds, the compliance manual generator 170 may be used to generate a compliance manual for each fund managed. he above-described steps of identifying, compiling, and formatting the one or more procedures to be followed by the fund manager 101 based upon the received data, collectively referred to as "compliance manual customization," are now described according to various embodiments. Based upon the fund manager's 101 answers provided in response to questions contained on the second and fourth web-based GUI screens 320, 340 ("Manager" and "Manual" screens, respectively) of the questionnaire 300 discussed above in connection with FIG. 3, one of multiple (e.g., eight) possible manual types may be identified as a "best fit" for the fund manager 101. In an embodiment, the answers to two multiple-choice questions may be used to identify one of the eight possible manual options based a comparison of the answers to a set of industry best practice standards, Mulligan Col. 9 lines 33-64).
As per claim 3, Wilson and Mulligan disclose as shown above with respect to claim 1. Wilson further discloses wherein the representative of the business entity comprises: (1) a professional service provider; (2) a beneficial owner or a company applicant; or (3) a business entity representative that is not from groups (1) or (2) (legal interest in the applicable reporting company(s), Wilson ¶22; The beneficial owners (individuals 102) may utilize the link to access the governmental requirements reporting system, create accounts, provide individual general information and PII, and provide consent to have their PII included in the company's required reports. The administrator 106 may have access to the status, general information, and consent provided by each individual 102 in the company account data as well as whether, e.g., identifying document(s) have been provided, ¶23; The governmental requirements reporting data 112 may further include company account data 128 associated with the company. The company account data 128 may include general company info (e.g., company name, company type, organization state, company ID, company address, etc.), a list of related individuals 102 and their roles (e.g., company members including beneficial owners, company administrator, billing contact, registered agent, etc.), the consent of each beneficial owner, the status of provision of identifying documents for each beneficial owner, and the like, ¶25).
The Examiner also asserts that the representative of the business entity comprises: (1) a professional service provider; (2) a beneficial owner or a company applicant; or (3) a business entity representative that is not from groups (1) or (2) is simply a label for the representative of the business entity and adds little, if anything, to the claimed acts or steps and thus does not serve to distinguish over the prior art. Any differences related merely to the meaning and information conveyed through labels (i.e., the representative’s label or title) which does not explicitly alter or impact the steps of the method does not patentably distinguish the claimed invention from the prior art in terms of patentability (MPEP 2144.04).
As per claims 4, 10, 11, 15, and 18, Wilson and Mulligan disclose as shown above with respect to claims 1, 8, and 14. Wilson further discloses wherein the transferring the management protocol step further comprises: transferring data ownership, billing, and administration from a professional service provider representative to a beneficial owner representative of the business entity or a company applicant representative of the business entity (a list of related individuals 102 and their roles (e.g., company members including beneficial owners, company administrator, billing contact, registered agent, etc.), the consent of each beneficial owner, the status of provision of identifying documents for each beneficial owner, and the like, Wilson ¶25; amendments, changes, or updates thereof, ¶17; Upon detecting the change to the individual account data, the governmental requirements reporting system 100 may automatically notify the company administrator 106, and, depending on the nature of the governmental requirements, the administrator may thereafter cause the governmental requirements reporting system to generate and submit additional governmental filing(s) to the electronic governmental report submission system 130 as required by the governmental requirements in light of the data changed in the individual account 120A, ¶27) (Examiner notes the user making changes to their account as including any changes to ownership/billing/administration, as this would include the legal interest changes of the beneficial ownership).
As per claims 6, 12, and 19, Wilson and Mulligan disclose as shown above with respect to claims 1, 8, and 14. Wilson further discloses wherein the step of collecting the set of business entity details pertaining to the business entity further comprises: auto-collecting one or more portions of the set of business entity details via an autogenerated email with one or more of the plurality of data input fields having the corresponding BOI data query for any missing or unknown BOI information (The governmental requirements reporting system 100 may then utilize the basic contact information to notify each beneficial owner that they have been so designated, such as through an email invitation containing a link to the governmental requirements reporting system 100. The beneficial owners (individuals 102) may utilize the link to access the governmental requirements reporting system, create accounts, provide individual general information and PII, and provide consent to have their PII included in the company's required reports. The administrator 106 may have access to the status, general information, and consent provided by each individual 102 in the company account data as well as whether, e.g., identifying document(s) have been provided. The administrator 106 will not be able to see, however, the individual's PII. If the individual 102 does not consent, that fact will appear in the company account data. The administrator 106 may be prompted to consult an attorney to deal with any non-compliant individual 102, Wilson ¶23; Upon receiving personally identifiable information corresponding to each of the one or more individuals associated with the company, a governmental requirements report is generated by the governmental requirements reporting system in a format compliant with governmental requirements, the report comprising the personally identifiable information corresponding to each of the one or more individuals associated with the company, ¶5).
As per claims 7, 13, and 20, Wilson and Mulligan disclose as shown above with respect to claims 1, 8, and 14. Wilson further discloses wherein the step of collecting the set of business entity details pertaining to the business entity further comprises: auto-generating an email to the representative of the business entity with instructions for obtaining a FinCEN identifier and submitting directly to FinCEN one or more portions of the set of business entity details corresponding to any missing or unknown BOI information (The governmental requirements reporting system 100 may then utilize the basic contact information to notify each beneficial owner that they have been so designated, such as through an email invitation containing a link to the governmental requirements reporting system 100. The beneficial owners (individuals 102) may utilize the link to access the governmental requirements reporting system, create accounts, provide individual general information and PII, and provide consent to have their PII included in the company's required reports. The administrator 106 may have access to the status, general information, and consent provided by each individual 102 in the company account data as well as whether, e.g., identifying document(s) have been provided. The administrator 106 will not be able to see, however, the individual's PII. If the individual 102 does not consent, that fact will appear in the company account data. The administrator 106 may be prompted to consult an attorney to deal with any non-compliant individual 102, ¶23; Upon receiving personally identifiable information corresponding to each of the one or more individuals associated with the company, a governmental requirements report is generated by the governmental requirements reporting system in a format compliant with governmental requirements, the report comprising the personally identifiable information corresponding to each of the one or more individuals associated with the company, ¶5) (Examiner notes the reporting the received information as also the ability to report information as missing or null (i.e. left blank or not obtained)).
As per claim 17, Wilson and Mulligan disclose as shown above with respect to claim 14. Mulligan further teaches managing a set of decision protocols for the corresponding BOI data query with one or more active context prompts on a business entity management webpage (Written procedures identified by the compliance manual generator 170 may include procedures such as, for example, record keeping procedures, personal trading procedures, Patriot Act and/or AML procedures, disaster recovery procedures, procedures for detecting and/or preventing insider trading, procedures for ensuring compliance with ethical requirements, procedures relating to administration of brokerage/placement fee policies, procedures relating to principal and agency cross transactions, procedures relating to ERISA investment policies, and procedures relating to proxy voting. The compliance manual generator 170 may also identify a set of industry best practice standards to be observed by employees of the fund manager 101 involved in fund management. Because the fund manager 101 may manage multiple funds, the compliance manual generator 170 may be used to generate a compliance manual for each fund managed. he above-described steps of identifying, compiling, and formatting the one or more procedures to be followed by the fund manager 101 based upon the received data, collectively referred to as "compliance manual customization," are now described according to various embodiments. Based upon the fund manager's 101 answers provided in response to questions contained on the second and fourth web-based GUI screens 320, 340 ("Manager" and "Manual" screens, respectively) of the questionnaire 300 discussed above in connection with FIG. 3, one of multiple (e.g., eight) possible manual types may be identified as a "best fit" for the fund manager 101. In an embodiment, the answers to two multiple-choice questions may be used to identify one of the eight possible manual options based a comparison of the answers to a set of industry best practice standards, Mulligan Col. 9 lines 33-64) (Examiner interprets the customizable portions of Mulligan’s software as including the context active prompts on a webpage).
Claim(s) 5 is/are rejected under 35 U.S.C. 103 as being unpatentable over Wilson et al. (US PG Pub. 2024/0281562) and Mulligan (US Patent No. 7,467,107), further in view of Ma et al. (US PG Pub. 2023/0325852).
As per claim 5, Wilson and Mulligan disclose as shown above with respect to claim 1. The combination of Wilson and Mulligan do not expressly disclose initiating one or more machine learning or artificial intelligence protocols during the step of querying for the one or more types of BOI data via the plurality of data input fields having the corresponding BOI data query for collecting the set of business entity details pertaining to the company applicant or the owner of the business.
However, Ma teaches initiating one or more machine learning or artificial intelligence protocols during the step of querying for the one or more types of BOI data via the plurality of data input fields having the corresponding BOI data query for collecting the set of business entity details pertaining to the company applicant or the owner of the business (In an exemplary embodiment, the present disclosure describes a fully automated system that can monitor clients, collect all relevant information about them at the point of necessity, and satisfy all due diligence requirements. The system uses a sophisticated pipeline for sourcing and storing the data, and making it available to end users. To answer all relevant due diligence questions, the system uses Machine Learning, Natural Language Processing, and Computer Vision models, Ma ¶93).
The Ma, Mulligan, and Wilson references are analogous in that both are directed towards/concerned with compliance reporting within the financial industry. Before the effective filing date of the claimed invention, it would have been obvious to a person of ordinary skill in the art to use Ma’s ability to automate data collection in a due diligence disclosure in Mulligan and Wilson’s reporting system to improve the system and method with reasonable expectation that this would result in a reporting management system that is able to provide the most accurate and applicable reporting requirements.
The motivation being that because of the pervasiveness of the KYC questionnaire and the ongoing nature of the due diligence process, there are significant costs relating to resource usage and availability. In particular, the number of human employees that are required for performing the due diligence process is quite large, potentially in the hundreds or thousands. Accordingly, there is a need for a mechanism for automating a due diligence process for onboarding new customers with respect to Know Your Customer (KYC) procedures and regulatory requirements in a reliable and efficient manner, in order to reduce human effort and cost (Ma ¶8).
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant’s disclosure (additional art can be located on the PTO-892):
Katz et al. (US PG Pub. 2010/0004981) Dynamic Anti-money Laundering System And Methodology For Providing Situational-specific Risk Assessment Determinations.
Yamazaki et al. (US PG Pub. 20250094928) Information processing device.
Any inquiry concerning this communication or earlier communications from the Examiner should be directed to ANDREW B WHITAKER whose telephone number is (571)270-7563. The examiner can normally be reached on M-F, 8am-5pm, EST.
If attempts to reach the examiner by telephone are unsuccessful, the Examiner’s supervisor, Lynda Jasmin can be reached on (571) 272-6782. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/ANDREW B WHITAKER/Primary Examiner, Art Unit 3629