DETAILED ACTION
Introduction
This Office action is responsive to the communications filed January 21, 2026. Claims 1, 8, and 15 were amended. Claims 1-20 are pending.
Response to Arguments
1. Applicant has amended the claims, thereby overcoming the double patenting rejection.
2. As per the 35 U.S.C. 101 rejection, Applicant argues that the claimed subject matter “is integrated into the decidedly practical application of providing secure transactions using transaction tokens generated by a trusted management entity, which are persistent and verifiable across a plurality of different entities, coupled with embedding reconciliation-relevant information in the tokens and requiring explicit user approval before issuing tokens.” It is asserted that the claims improve reliability, auditability, and security of transaction workflows to prevent fraudulent transaction, thereby not directed to an abstract idea.
However, the Examiner respectfully disagrees. As indicated in the Office action, the claims are directed to an abstract idea of providing a transaction token, which is categorized under certain methods of organizing human activity. Additionally, the particulars or algorithms to improve the technology are not described in the claims/specification.
3. Applicant’s arguments, see p. 11, with respect to the 35 U.S.C 112(b) rejection have been fully considered and are persuasive. The 35 U.S.C. 112(b) rejection of claims 4, 11, and 18 has been withdrawn.
4. Applicant’s arguments with respect to the 35 U.S.C. 103 rejection of the claims have been considered, but are moot in light of the new ground of rejection necessitated by the amendment.
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.
In the instant case, claims 1-7 are directed to a method. Claims 8-14 a non-transitory computer readable medium while claims 15-20 are directed to a computing device. Therefore, these claims fall within the four statutory categories of invention.
For example, claim 1 recites an abstract idea of providing a transaction token, which enables a reconciliation procedure to be carried out. The claim under its broadest reasonable interpretation recites limitations grouped within the “certain methods of organizing human activity” grouping of abstract ideas. The certain methods of organizing human activity abstract idea grouping is defined as concepts related to fundamental economic principles or practices, commercial or legal interactions including agreements in the form of contracts, legal obligations, advertising, marketing or sales activities or behaviors, and business relations. See MPEP § 2106.04(a)(2), subsection II. The claim limitations reciting the abstract idea are grouped within the “certain methods of organizing human activity” grouping of abstract ideas as they relate to providing a transaction token, which enables a reconciliation procedure to be carried out. More specifically, the following the bolded claim elements recite additional elements while the other claim elements recite the abstract idea. according to MPEP 2106.04(a).
A method for managing transaction tokens to facilitate reconciliation procedures, the method comprising, by a transaction framework implemented on a computing device:
receiving, from a software application executing on the computing device, a first request to perform a transaction;
providing, to a management entity, separate from the software application executing on the computing device, a second request to generate a transaction token for the transaction;
receiving the generated transaction token from the management entity in response to providing the second request to generate the transaction token for the transaction;
displaying a user interface (UI) that indicates the transaction will be performed independent from the management entity, wherein the UI includes a first option to approve the transaction, and a second option to cancel the transaction;
receiving, via the UI, a selection of the first option to approve the transaction; and
in response to receiving the selection of the first option to approve the transaction,
providing the transaction token to the software application or a developer entity associated with the software application, wherein, when the transaction is performed, the transaction token enables a reconciliation procedure to be carried out.
Independent claims 8 and 15 recites similar language.
This judicial exception is not integrated into a practical application because, when analyzed under prong two of step 2A of the Alice/Mayo test (See MPEP 2106.04(d)), the additional element(s) of the claim(s) such as the transaction token, UI, computing device, and software application are merely used as tools to perform an abstract idea and/or generally link the use of a judicial exception to a particular technological environment. Specifically, these additional elements perform the steps or functions of providing a transaction token, which enables a reconciliation procedure to be carried out. Viewed as a whole, the use of transaction token, UI, computing device, and software application as tools to implement the abstract idea and/or generally linking the use of the abstract idea to a particular technological environment does not integrate the abstract idea into a practical application because it requires no more than a computer or computer networks performing functions that correspond to acts required to carry out the abstract idea. The additional elements do not involve improvements to the functioning of a computer, or to any other technology or technical field (MPEP 2106.05(a)), and the claims do not apply or use the abstract idea in some other meaningful way beyond generally linking the use of the abstract idea to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception (MPEP 2106.05(e) and Vanda Memo). Therefore, the claims do not, for example, purport to improve the functioning of a computer. Nor do they effect an improvement in any other technology or technical field. Accordingly, the additional elements do not impose any meaningful limits on practicing the abstract idea, and the claims are directed to an abstract idea.
The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when analyzed under step 2B of the Alice/Mayo test (See MPEP 2106.05), the additional element(s) of the transaction token, UI, computing device, and software application to perform the steps amounts to no more than using generic hardware or software to automate and/or implement the abstract idea of providing a transaction token, which enables a reconciliation procedure to be carried out. Viewed as a whole, the combination of elements recited in the claims merely recite the concept of providing a transaction token, which enables a reconciliation procedure to be carried out. Therefore, the use of these additional elements does no more than employ the computer as a tool to automate and/or implement the abstract idea. The use of a computer or processor to merely automate and/or implement the abstract idea cannot provide significantly more than the abstract idea itself (MPEP 2106.05 (f) & (h)). Therefore, the claim is not patent eligible.
The dependent claims further describe the abstract idea such as identifying a user account, receiving the verification from the management entity, performing a second transaction that is based on the transaction and providing a report.
The dependent claims do not include additional elements that integrate the abstract idea into a practical application or that provide significantly more than the abstract idea. Therefore, the dependent claims are also not patent eligible.
Claim Rejections - 35 USC § 103
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.
Claims 1, 8, and 15 are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Publication No. 2017/0091759 to Selfridge et al. (“Selfridge”)
As per claim 1, Selfridge discloses receiving, from a software application executing on the computing device, a first request to perform a transaction (abstract – receive a transaction request; paragraph [0012]- mobile application… receive request from customer);
providing, to a management entity, separate from the software application executing on the computing device, a second request to generate a transaction token for the transaction, wherein the transaction token includes information relevant to facilitate reconciliation procedures (paragraph [0007] – processing device…to receive request from customer to generate the payment token);
receiving the generated transaction token for the transaction from the management entity in response to providing the second request to generate the transaction token for the transaction ; receiving, via the UI, a selection of the first option to approve the transaction (paragraph [0032] -user may request a token…tokenization service provides a token to the user);
displaying a user interface (UI), wherein the UI includes a first option to approve the transaction, and a second option to cancel the transaction (paragraph [0006] – prompt the customer to approve or deny the transaction); and
in response to receiving the selection of the first option to approve the transaction,
providing the transaction token to the software application or a developer entity associated with the software application, wherein, when the transaction is performed, the transaction token enables a reconciliation procedure to be carried out (paragraphs [0006] – prompt the customer to approve…in response to the alert indicating the transaction request to the customer, an approval communication from the customer approving the transaction and approve and settle the transaction; [0057] – receiving a request form the customer to generate a payment token, prompt the customer… implement the limitation on the use of the token…[0059] token management interface.. may serve as a dashboard for initiating generation and communication of tokens).
As for display indicating the transaction will be performed independent from the management entity, this is considered non-functional descriptive material and is not functionally involved in the steps recited. Selfridge discloses the alert on the UI may be intended solely for information purposes (paragraph [0053]), which may include notifying the customer that the transaction will be performed independent form the management entity. The displaying step would be performed the same regardless of what data is shown. Thus, this descriptive material will not distinguish the claimed invention from the prior art in terms of patentability, see In re Gulack, 703 F.2d 1381, 1385, 217 USPQ 401, 404 (Fed. Cir. 1983); In re Lowry, 32 F.3d 1579, 32 USPQ2d 1031 (Fed. Cir. 1994).
Claims 8 and 15 are rejected on the same rationale as claim 1.
Claims 2-4, 6, 9-11, 13, 16-18, and 20 are rejected under 35 U.S.C. 103 as being unpatentable over Selfridge as applied to claim 1 above, and further in view of US Publication No. 2024/0396884 to Lin et al. (“Lin”).
As per claim 2, Selfridge discloses in response to receiving the first request to perform the transaction: identifying a user account associated with the computing device; interfacing with the management entity to receive a verification that the user account is valid (abstract; paragraphs [0006]- authenticate the customer through an online baking session or a mobile application;[0055]).
Additionally, Lin discloses in response to receiving the first request to perform the transaction: identifying a user account associated with the computing device; interfacing with the management entity to receive a verification that the user account is valid; and receiving the verification from the management entity (paragraphs [0028], [0042], [0043] and abstract).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to include the elements of Lin into Selfridge as they relate to token generation. Hence, since the claimed invention is merely a combination of old elements, and in the combination each element merely would have performed the same function as it did separately, one of ordinary skill in the art would have recognized that the results of the combination were predictable.
As per claim 3, Lin discloses request includes: a session identifier associated with the second request, a unique identifier associated with the software application, transaction type information that defines whether the transaction will take place through the software application or through at least one webpage that is loaded in a web browser application executing on the computing device, and storefront information that includes locale, currency, tax, and commission information associated with the software application, the computing device, the transaction, or some combination thereof ( paragraphs [0036] and [0060] – application profile). Also, the examiner notes that this information in the request is considered non-functional descriptive material and is not functionally involved in the steps recited. The providing a second request step would be performed the same regardless of what data is included in the request. Thus, this descriptive material will not distinguish the claimed invention from the prior art in terms of patentability, see In re Gulack, 703 F.2d 1381, 1385, 217 USPQ 401, 404 (Fed. Cir. 1983); In re Lowry, 32 F.3d 1579, 32 USPQ2d 1031 (Fed. Cir. 1994).
As per claim 4, Selfridge and Lin do not expressly disclose hiding the UI in response to receiving, via the UI, the selection of first option to approve the transaction. However, it is known in the art that when a user selects an option on the UI, it will move to another display such a pop-up or load to another screen. The Examiner notes that such display is a matter of design choice (see In re Seid, 161, F.2d 229, 231, 73 USPQ 431, 433 (CCPS 1947).
As per claim 6, Selfridge and Lin disclose wherein the transaction framework comprises an Application Programming Interface (API) that is communicatively coupled to: at least the software application and at least the management entity (see claim 1 above and Lin at Fig. 1).
Claims 9-11, 13, 16-18, and 20 are rejected on the same rationale as claims 2-4 and 6.
Claims 5, 7, 12, 14, and 19 are rejected under 35 U.S.C. 103 as being unpatentable over Selfridge as applied to claims 1, 8, and 15 above, and further in view of 2023/214975 to Wang et al. (“Wang”).
As per claim 5, Selfridge discloses the reconciliation procedure (see claim 1 above). The reference does not expressly disclose performing a second transaction that is based on the transaction; and providing, to the developer entity, a report that includes information associated with at least the second transaction.
Wang discloses wherein the reconciliation procedure comprises: performing a second transaction that is based on the transaction; and providing, to the developer entity, a report that includes information associated with at least the second transaction (paragraphs [0067], [0105], and [0107]).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to include the elements of Wang into Selfridge. Hence, since the claimed invention is merely a combination of old elements, and in the combination each element merely would have performed the same function as it did separately, one of ordinary skill in the art would have recognized that the results of the combination were predictable.
As per claim 7, Wang discloses prior to displaying the UI: verifying that the transaction token is valid (see paragraphs [0084] and [0086]).
Claims 12 and 19 are rejected on the same rationale as claim 5.
Claims 14 is rejected on the same rationale as claim 7.
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 JALATEE WORJLOH whose telephone number is (571)272-6714. The examiner can normally be reached Monday-Friday 6:00am-2:00pm.
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/Jalatee Worjloh/Primary Examiner, Art Unit 3697
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