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 .
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 a judicial exception without reciting additional elements that integration the judicial exception into a practical application or amount to significantly more than the judicial exception.
Step 1 – Statutory class?
Claims 1-20 recite statutory classes of invention – i.e. claims 1q-29 are directed to machines and claim 20 is directed to a process.
Notably the office’s eligibility framework identifies, among the enumerated groupings of abstract ideas, “certain methods of organizing human activity” including fundamental economic practices and commercial or legal interactions. That group also encompasses claims directed to business relations, contractual relationships, sales activities, and related commercial transactions. The following analysis encompasses such a framework.
Step 1 – statutory class of invention?
Claims 1-20 are directed to one of the statutory classes of invention and therefore pass Step 1.
Step 2A, Prong One – abstract idea?
Independent claims 1, 10, & 20 recite the abstract idea of validating a ticket for redemption and administering a corresponding credit based on the ticket’s value and redemption status.
Claim 1 is representative of the independent claims and recites:
receiving a ticket for redemption;
identifying a ticket identifier;
searching records for ticket creations and ticket redemptions associated with the ticket identifier;
determining whether a creation record exists and whether a redemption record does not exist; and if so
establishing credit equal to the ticket value.
Under the broadest reasonable interpretation, these limitations recite a commercial interaction involving redemption of an instrument having monetary or credit value. The limitations further recite maintaining and consulting records to determine whether the instrument was issued, whether it has already been redeemed, and whether the holder is entitled to the corresponding payment or credit.
Such activity is analogous to longstanding ticket, voucher, coupon, gaming ticket, and payment redemption practices. For example, a merchant or cashier may inspect a ticket identifier and an issuance record, determine the ticket’s value, check whether the ticket was previously redeemed, refuse duplicate or unissued tickets, and provide corresponding credit if the ticket is valid and unredeemed. The claimed use of a ticket identifier, issuance record, redemption record, validation conditions, and credit therefore constitutes a commercial interaction and an economic practice.
The claims also recite a mental process aspect of comparing ticket status information, whether a creation record is found and a redemption record is not found, to a rule for determining whether to authorize redemption. The office identifies observations, evaluations, judgements, and opinions as mental process concepts.
Therefore, the abstract idea may be characterized as: verifying whether a ticket is valid and unredeemed and providing or denying a credit based on the verification.
The claims’ references to a system blockchain, ticket creation transaction, or ticket redemption transaction do not alter the character of the claimed abstract idea at Step 2A, Prong One. Under the claim’s broad language, these elements are records of ticket issuance and/or redemption statuses used to administer the ticket redemption transaction.
Dependent claims 2-19 and 11-19 do not remove the claims from the abstract idea grouping.
For example, claims 2 & 11 further creatin and recording redemption records is bookkeeping or recordkeeping associated wit the redemption interaction. Claims 3 & 12 recite preventable double redemption, which is a commercial validation rule. Claims 4 & 13 recite rejecting unissued or unrecognized tickets which is another validation rule. Claims 5 & 14 recite predefined rules. Claims 6, 7, 15, & 15 recite further ticket validation and payment authorization rules. Claims 8, 17, & 19 recite specificity as to the location of the records kept. Claims 9 & 18 recite identity as to physical or virtual tickets. Claims 9 & 18 recite a form of commercial instrument. Thus, the dependent claims merely add further recordkeeping, validation rules, transaction authorizations, and various field of use limitations that further provide specificity to the abstract idea.
Step 2A, Prong Two – practical application?
The claims do not integrate the abstract idea into a practical application.
The additional elements include a generic electronic device or gaming system, at least one processor, at least one memory, a ticket reader, electronic communications, a system blockchain, a blockchain network including participating devices, transaction records, smart contracts, and/or in some claims a local blockchain.
Under the broadest reasonable interpretation, these additional elements merely provide generic technological tools for performing ticket validation, maintaining redemption records, and administering credits. The claims do not recite a particular technical implementation of a distributed ledger or a technical improvement in blockchain network functionality.
The claims recite that a “system blockchain” supports participating devices and is searched for ticket creation and redemption transactions, however, the claims do not recite: (i) a particular blockchain data structure, block structure, transaction format, cryptographic scheme, validation protocol, or node architecture, (ii) how participating devices create, validate, propagate, order, confirm, or store transactions, (iii) a technique for reconciling inconsistent redemption requests, (iv) a technique for presenting a race condition in which two devices attempt to redeem the same ticket, (v) a technical mechanism for confirming a transaction’s finality, (vi) a particular interpolation between the system and local blockchains, (vii) a particular mechanism for extracting, reading, encrypting, authenticating, or verifying ticket identifiers, (viii) a specific data integrity improvement, or (ix) a particular configuration of the electronic device, ticket reader, process, memory and/or network interface as some non-exhaustive examples of integration into a practical application.
The claims therefore use blockchain terminology at a high level of abstraction as a repository of issuance and redemption records. Merely using blockchain to gather and store data, without claiming a particular technological configuration or improvement, does not by itself supply a practical application. Federal Circuit treatment of a blockchain based physical item tracking claim similarly reflects that use of conventional components to identify or track an item, gather data, and store data did not itself transform the claimed abstract activity into eligible subject matter. See Rady v. The Boston Consulting Group, Inc., No. 2022-2218 (Fed. Cir. Mar. 27, 2024).
Claim 1 also recites receiving a ticket via ticket reader but does not identify a particular reading configuration, as such the reading is used merely as a generic input device for obtaining ticket information.
Likewise, the claims broadly recite a processor and memory receive ticket data, but only perform generic computing functions and do not purport to improve the functioning of the processor, memory, ticket reader, communications network, or gaming system.
Similarly, “smart contract” recitations do not use the claimed computing and blockchain elements in a manner that meaningfully limits the ticket redemption abstract idea.
Therefore, the claims are directed to the abstract idea(s) detailed above.
Step 2B – significantly more?
The additional elements do not amount to significantly more than the judicial exception.
Individually, the recited processor, memory, electronic device electronic gaming system, ticket reading, blockchain network, system blockchain, local blockchain, transaction records, smart contracts, and communications are claimed only by their generic functions. The claims do not recite a particular nonconventional arrangement, a particular technological configuration, or a specific technical technique that improves operation of an underlying computer or technical field.
As an ordered combination, the claims amount to the conventional sequence of: receive ticket information, obtain ticket identifier, check issuance and redemption records, determining whether redemption is permitted, create or transmit a record of redemption, and provide or deny credit.
The additional blockchain related recitations merely directed the issuance and redemption records be stored or queried in a distributed ledger and that the commercial validation rule be executed through a smart contract. The claims neither recite nor require a particular nonconventional distributed ledger architecture, technical mechanism, or improvement to blockchain technology.
Therefore, the claims, individually and as an ordered combination, merely implement the abstract idea using generic computer and blockchain components. They do not recite an inventive concept or significantly more than the abstract idea.
For at least these reasons, claims 1-20 are patent ineligible in view of 35 U.S.C. 101.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. See attached Notice of References Cited (PTO-892).
Any inquiry concerning this communication or earlier communications from the examiner should be directed to MILAP SHAH whose telephone number is (571)272-1723. The examiner can normally be reached Monday - Friday, 9:30-6PM.
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/MILAP SHAH/Primary Examiner, Art Unit 3715
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