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 .
Status of Claims
This action is in reply to the amended claims filed on 5/1/2026, wherein:
Claims 1, 3, 9, 11, 13 and 19 have been amended;
Claims 2, 4-8, 10, 12, 14-18, and 20, remain as original;
Claims 21-30 have been cancelled;
Claims 1-20 are currently pending and have been examined.
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. The claims recite a device and method for payment management which is considered a judicial exception because it falls under Certain Methods of Organizing Human Activity such as commercial or legal interactions, including agreements in the form of contracts; and marketing, or sales activities, or behaviors. This judicial exception is not integrated into a practical application as discussed below and the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception as discussed below.
This rejection follows the 2019 Revised Patent Subject Matter Eligibility Guidance, 84 Fed Reg 4, January 7, 2019, pp. 50-57 (“2019 PEG”)(MPEP 2106).
Analysis
Step 1 (Statutory Categories) – 2019 PEG pg. 53 (See MPEP 2106.03)
Claims 1-20 are directed to the statutory category of a process, machine, or manufacture.
Step 2A, Prong 1 (Do the claims recite an abstract idea?) – 2019 PEG pg. 54 (See MPEP 2106.04(a)-(c))
For independent claims 1 and 11, the claims recite an abstract idea of: payment management. The steps of independent claim 1 recite the abstract idea (in bold below) of: A method comprising: at a device comprising one or more processors: providing, via a payment portal interface, access for a partner device to an on-boarding integration platform; receiving partner data from the partner device via the payment portal interface, wherein the partner data comprises at least one of a platform offer or a payment product corresponding to a partner associated with the partner device, the platform offer specifying at least one of a market, a currency, a product and a product capability supported by the partner and the payment product including at least one of an accepted form of payment, a form of payment verification, an authentication protocol and a fraud check supported by the partner; generating, based on the received partner data and a payment management platform algorithm, at least one payment management interface tool associated with the partner, wherein the at least one payment management interface tool comprises user integration instructions defining a workflow integration environment and including one or more of an application program interface (API) tool, an API documentation tool, a script, a network configuration tool, a network connectivity tool, and test use cases; receiving an integration request from the partner device via the payment portal interface, wherein the integration request comprises integration data entered via the partner device and based on the defined workflow integration environment corresponding to the user integration instructions of the generated at least one payment management interface tool; and in response to receiving a provider search request from a user device, the provider search request including at least one marketplace criterion matching the partner data, providing, based on the integration data, the partner data for display at the user device via the payment portal interface. Independent claim 11 recites similar steps that recite the abstract idea. Independent claims 1 and 11, as drafted, are a process that, under the broadest reasonable interpretation, covers Certain Methods of Organizing Human Activity, since they recite fundamental economic principles or practices including mitigating risk. If the claim limitations, under the broadest reasonable interpretation, covers methods of organizing human activity but for the recitation of additional elements including generic computer components, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Other than reciting the abstract idea, the independent claims recite additional elements including generic computer components such as “a device comprising one or more processors; a payment portal interface; a partner device; an on-boarding integration platform; a payment management platform algorithm; an application program interface (API) tool, and API documentation tool, a script, a network configuration tool, a network connectivity tool, a payment management interface tool; a user device; and a device comprising: a non-transitory computer-readable storage medium comprising program instructions executed by one or more processors”, and nothing in the claims precludes the steps from being performed as a method of organizing human activity. Accordingly, the independent claims recite an abstract idea.
Dependent claims 2-10, and 12-20 recite similar limitations as claims 1 and 11; and when analyzed as a whole are held to be patent ineligible under 35 U.S.C 101 because the additional recited limitations only refine the abstract idea further. Other than reciting the abstract idea, the dependent claims recite similar additional elements including generic computer components as the independent claims, such as “the payment management interface tool; the payment portal interface; the API; a certification engine portal; the partner device; a user device; a link; the on-boarding integration platform; a front-end API, the device; and the one or more processors”. If a claim limitation, under its broadest reasonable interpretation, covers commercial or legal interactions, but for the recitation of generic computer components, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas.
Step 2A, Prong 2 (Does the claim recite additional elements that integrate the judicial exception into a practical application?) – 2019 PEG pg. 54 (See MPEP 2106.04(d)-(c))
This judicial exception is not integrated into a practical application. In particular, independent claims 1 and 11 only recite the additional elements of “a device comprising one or more processors; a payment portal interface; a partner device; an on-boarding integration platform; a payment management platform algorithm; an application program interface (API) tool, and API documentation tool, a script, a network configuration tool, a network connectivity tool, a payment management interface tool; a user device; and a device comprising: a non-transitory computer-readable storage medium comprising program instructions executed by one or more processors”. A plain reading of the Figures and associated descriptions in the specification reveals that generic processors may be used to execute the claimed steps. The additional elements are recited at a high level of generality (i.e., as a generic processor performing generic computer functions) such that it amounts to no more than mere instructions to apply the exception using generic computer components (See MPEP 2106.05(f)) and limits the judicial exception to a particular environment (See MPEP 2106.05(h)). Mere instructions to apply an exception using a generic computer component and limiting the judicial exception to a particular environment doesn’t integrate the abstract idea into a practical application in Step 2A. Accordingly, these additional elements do not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Hence, independent claims 1 and 11 are directed to an abstract idea.
Dependent claims 2-10, and 12-20, recite similar additional elements as the independent claims including generic computer components, such as “the payment management interface tool; the payment portal interface; the API; a certification engine portal; the partner device; a user device; a link; the on-boarding integration platform; a front-end API, the device; and the one or more processors”. The judicial exception is not integrated into a practical application because the additional elements in the dependent claims are also recited at a high-level of generality such that it amounts to more no more than mere instructions to apply the exception using generic computer components. Therefore, the additional elements do not integrate the abstract idea into a practical application because they also do not impose any meaningful limits on practicing the abstract idea. Also, the claims do not affect an improvement to another technology or technical field; the claims do not amount to an improvement of the functioning of a computer system itself; the claims do not effect a transformation or reduction of a particular article to a different state or thing; and the claims do not move beyond a general link of the use of an abstract idea to a particular technological environment.
Step 2B (Does the claim recite additional elements that amount to significantly more than the judicial exception?) – 2019 PEG pg. 56 (See MPEP 2106.05)
Independent claims 1 and 11 do not include additional elements 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 recited additional elements amount to no more than mere instructions to apply the exception using a generic computer component (See MPEP 2106.05(f)) and limits the judicial exception to the particular environment of computers (See MPEP 2106.05(h)). The additional elements of the instant underlying process, when taken in combination, together do not offer substantially more than the sum of the function of the elements when each is taken alone. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept in Step 2B.
In addition, the dependent claims 2-10, and 12-20 do not include additional elements 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 elements of the dependent claims to perform the claimed limitations, amounts to no more than mere instructions to apply the exception using a generic computer component (See MPEP 2106.05(f)). Similar to the independent claims, mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Also, for the same reasoning as the independent claims, the additional elements of the limitations of the dependent claims, when considered individually and as an ordered combination, together do not offer significantly more than the sum of the functions of the elements when each is taken alone and the dependent claims as a whole, do not amount to significantly more than the abstract idea itself. For these reasons, the dependent claims also are not patent eligible.
Subject Matter Overcoming 35 USC §102/§103
Claims 1-20 would be allowable if rewritten to overcome the rejections under 35 U.S.C. 101 set forth in this Office Action.
The following is an examiner’s statement of reasons for subject matter of independent claims 1 and 11 overcoming the prior art rejections under 35 USC §102/§103.
The closest prior art of record is US 12,450,530 to Cruikshank et al. (hereinafter referred to as Cruikshank), US 2025/0209396 to Thakur et al. (hereinafter referred to as Thakur), US 8745641 to Coker (hereinafter referred to as Coker), and US 20030018585 to Butler et al. (hereinafter referred to as Butler). Allowable subject matter is indicated because none of the prior art of record, alone or in combination, appears to teach or fairly suggest or render obvious the combination set forth in independent claims 1 and 11. For independent claim 11, the prior art of Cruikshank, Thakur, Coker, and Butler specifically do not disclose: “receiving partner data from the partner device via the payment portal interface, wherein the partner data comprises at least one of a platform offer or a payment product corresponding to a partner associated with the partner device, the platform offer specifying at least one of a market, a currency, a product and a product capability supported by the partner and the payment product including at least one of an accepted form of payment, a form of payment verification, an authentication protocol and a fraud check supported by the partner; generating, based on the received partner data and a payment management platform algorithm, at least one payment management interface tool associated with the partner, wherein the at least one payment management interface tool comprises user integration instructions defining a workflow integration environment and including one or more of an application program interface (API) tool, an API documentation tool, a script, a network configuration tool, a network connectivity tool, and test use cases; receiving an integration request from the partner device via the payment portal interface, wherein the integration request comprises integration data entered via the partner device and based on the defined workflow integration environment corresponding to the user integration instructions of the generated at least one payment management interface tool; and in response to receiving a provider search request from a user device, the provider search request including at least one marketplace criterion matching the partner data”. Similar reasoning and rationale applies to independent claim 11. Dependent claims 2-10, and 12-20 are allowable over the prior art by virtue of their dependency on an allowed claim.
Response to Arguments
Applicant’s arguments with respect to claims 1-20 have been fully considered by the Examiner. With respect to the Applicant’s arguments regarding the previous rejection of independent claims 1 and 11 under 35 USC 103, the Applicant argues that the prior art fails to disclose the limitations of the amended claims. Examiner finds Applicant’s arguments persuasive and the previous prior art rejections are withdrawn as further indicated above. Applicant’s arguments with respect to the rejection of claims 1-20 under 35 USC 101 have been fully considered by the Examiner. However, the Examiner does not find the Applicant’s arguments persuasive, and therefore the rejections of claims 1-20 under 35 USC 101 are maintained.
The Applicant argues that under Prong 1 of Step 2A of the 2019 PEG, the claims do not recite an abstract idea because the claims are directed to a technical process directed at statutory subject matter in the field networked computer systems and the amended claims provide an improvement for integration of external partners at a payment portal interface using automated generation of structured tool drive workflows. Applicant further argues on page 7 of their Remarks that the claimed invention’s automatic generation of integration tools and workflows automate a previously manual technical process similar to McRO and provide a technical solution. Applicant also argues on page 8 of their Remarks that the claims integrates any alleged abstract idea into a practical application because they control system behavior through specific technical mechanisms to generate automated integration tools and do not merely use a computer. Applicant further argues on page 8 of their Remarks that the claims limitations are indicative of an inventive concept under Step 2B of the 2019 PEG because the claimed limitations when combined together and considered as a whole are not routine and conventional, and achieve an improvement of computer functionality that reduces integration efforts and associated processing which standardizing partner onboarding and deployment.
Examiner respectfully disagrees with Applicant’s argument that the claimed limitations do not recite and abstract idea. Under Prong 1 of the 2019 PEG, the claims do fall under the abstract idea of Certain Method of Organizing Human Activity. If a claim limitation, under its broadest reasonable interpretation, covers commercial or legal interactions, but for the recitation of additional elements including generic computer components, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Under the broadest reasonable interpretation, the claims recite commercial or legal interactions, including agreements in the form of contracts; and marketing, or sales activities, or behaviors.
Examiner respectfully disagrees with Applicant’s argument that Applicant’s claims are directed to patent eligible subject matter similar to McRO. The claims in McRO were held patent eligible because the claims were directed at specific rules that resulted in an improvement to the technology of computer generated lip synchronization. The McRO court indicated that it was the incorporation of the particular claimed rules in computer animation that "improved [the] existing technological process." The claims at issue in McRO described a specific way (use of particular rules to set morph weights and transitions through phonemes) to solve the problem of producing accurate and realistic lip synchronization and facial expressions in animated characters, allowing the computer to perform a function not previously performable by a computer. In the instant application, the Examiner fails to see where the technological improvement is because the limitations are directed towards steps performed on a computer, and the functioning of the additional elements or technological processes themselves are not improved as a whole. Furthermore, the patent claims here are not directed to a specific implementation to a solution to a problem in the software arts of improving computer animation through the use of specific rules, therefore McRO has no applicability.
Examiner respectfully disagrees with Applicant’s argument that the claimed limitations are indicative of integration into a practical application under Prong 2 of Step 2A. Using a computer to: receive partner data, generate a workflow and an API, receive an integration request with user entered data, receive a provider search request, and provide data for display; is nothing more than executing instructions to apply the exception to a computer. This is interpreted by the Examiner as using a computer as a tool to perform an abstract idea (See MPEP 2106.05(f)). The additional elements of “a device comprising one or more processors; a payment portal interface; a partner device; an on-boarding integration platform; a payment management platform algorithm; an application program interface (API) tool, and API documentation tool, a script, a network configuration tool, a network connectivity tool, a payment management interface tool; a user device; and a device comprising: a non-transitory computer-readable storage medium comprising program instructions executed by one or more processors” are recited at a high level of generality such that it amounts to no more than mere instructions to apply the exception using generic computer components (See MPEP 2106.05(f)). There is no improvement to the claimed computer elements, or to any other technology or technical field. The only improvements identified in the specification are generic speed and efficiency improvements inherent in applying the use of a computer to any task. Therefore, the claimed limitations do not meet the criteria or considerations as indicative of integration into a practical application.
Examiner respectfully disagrees with Applicant’s further argument under Step 2B of the PEG, that the amended claim limitations recite additional elements that amount to an inventive concept that renders the claims patent eligible because the claims provide for improvements to the technical field and are not routine and convention. As stated previously, using a computer to: receive partner data, generate a workflow and an API, receive an integration request with user entered data, receive a provider search request, and provide data for display; is nothing more than executing instructions to apply the exception to a computer. The additional elements amount 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. In addition, the claimed limitations under MPEP 2106.05(d)(ii) amount to well-understood routine and conventional activities of: receiving and transmitting data over a network, the performance of repetitive calculations, electronic recordkeeping, storing and retrieving information in memory, and presenting results of an analysis. Therefore, the rejections of the claims pursuant to 35 USC 101 are maintained.
Conclusion
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 Paul Schwarzenberg whose telephone number is (313) 446-6611. The examiner can normally be reached on Monday-Thursday (7:30-6:30).
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/PAUL S SCHWARZENBERG/Primary Examiner, Art Unit 3695 7/7/2026
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