DETAILED ACTION
Status of Claims
1. This office action is in response to arguments filed 6/23/2026.
2. Claims 1-20 are pending.
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 1-27
Claims 1-27 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
Step 1: Claims 1-7 are directed to a method; claims 8-14 are directed to a device (system); claims 15-20 are directed to a machine-readable medium – each of which is one of the statutory categories of inventions.
Step 2A: A claim is eligible at revised Step 2A unless it recites a judicial exception and the exception is not integrated into a practical application of the application.
Prong 1: Prong One of Step 2A evaluates whether the claim recites a judicial exception (an abstract idea enumerated in the 2019 PEG, a law of nature, or a natural phenomenon).
Groupings of Abstract Ideas:
I. MATHEMATICAL CONCEPTS
A. Mathematical Relationships
B. Mathematical Formulas or Equations
C. Mathematical Calculations
II. CERTAIN METHODS OF ORGANIZING HUMAN ACTIVITY
A. Fundamental Economic Practices or Principles (including hedging, insurance, mitigating risk)
B. Commercial or Legal Interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations)
C. Managing Personal Behavior or Relationships or Interactions between People (including social activities, teaching, and following rules or instructions)
III. MENTAL PROCESSES.
Concepts performed in the human mind (including an observation, evaluation, judgment, opinion).
See MPEP 2106.04 (a) (2) Abstract Idea Groupings [R-10.2019]
The limitations of the independent claim 1, 8 and 15 – receiving a request from a user to generate a virtual card number and a payment restriction on the virtual card number; generating the virtual card number, wherein the virtual card number is not a same number as a card number of the user, the virtual card number generated based upon a digital identification of the user, a digital identification of a payee, and a random value; transmitting the virtual card number and the payment restriction to a payment processor; and causing the virtual card number in a transaction with the payee –constitute Fundamental Economic Practices/Principles and/or Commercial/Legal Interactions and/or Managing Interactions between People all of which are subcategories of the abstract idea grouping Certain Methods of Organizing Human Activity.
The dependent claims further limit the abstract idea to – type of payment restriction; cryptogram using virtual payment number; transaction with a merchant; invalidating virtual card number; providing mobile ID and virtual payment number to payment processor; contacting payment processor to associate virtual card number with user card number – that also constitute Certain Methods of Organizing Human Activity.
Hence under Prong One of Step 2A, claims 1-20 recite a judicial exception.
Prong 2: Prong Two of Step 2A evaluates whether the claim recites additional elements that integrate the judicial exception into a practical application of the exception.
Limitations the courts have found indicative that an additional element (or combination of elements) may have integrated the exception into a practical application include:
An improvement in the functioning of a computer, or an improvement to other technology or technical field, as discussed in MPEP §§ 2106.04(d)(1) and 2106.05(a);
Applying or using a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition, as discussed in MPEP § 2106.04(d)(2);
Implementing a judicial exception with, or using a judicial exception in conjunction with, a particular machine or manufacture that is integral to the claim, as discussed in MPEP § 2106.05(b);
Effecting a transformation or reduction of a particular article to a different state or thing, as discussed in MPEP § 2106.05(c); and
Applying or using the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception, as discussed in MPEP § 2106.05(e).
The courts have also identified limitations that did not integrate a judicial exception into a practical application:
Merely reciting the words “apply it” (or an equivalent) with the judicial exception, or merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea, as discussed in MPEP § 2106.05(f);
Adding insignificant extra-solution activity to the judicial exception, as discussed in MPEP § 2106.05(g); and
Generally linking the use of a judicial exception to a particular technological environment or field of use, as discussed in MPEP § 2106.05(h).
Additional elements recited by the claims, beyond the abstract idea, include: mobile wallet application; user interface element; virtual card number; mobile payment cryptogram; second computing device; NFC; machine readable medium. Examiner finds that any additional element(s), beyond the judicial exception, has been recited at a high level of generality such that the claim limitations amount to no more than mere instructions to apply the exception using generic components (see MPEP 2106.05(f)) or insignificant data gathering activities (see MPEP 2106.05(g)).
The combination of additional elements does not purport to improve the functioning of a computer or effect an improvement in any other technology or technical field. Instead, the additional elements do no more than use the computer as a tool and/or link the use of the judicial exception to a particular technological environment or field of use. The focus of the claims is not on improvement in computers, but on certain independently abstract ideas – receiving a request from a user to generate a virtual card number and a payment restriction on the virtual card number; generating the virtual card number, wherein the virtual card number is not a same number as a card number of the user, the virtual card number generated based upon a digital identification of the user, a digital identification of a payee, and a random value; transmitting the virtual card number and the payment restriction to a payment processor; and causing the virtual card number in a transaction with the payee – that merely uses generic computers as tools. Steps that do no more than spell out what it means to “apply it on a computer” cannot confer patent eligibility. Indeed, nothing in claim 1 improves the functioning of the computer, makes it operate more efficiently, or solves any technological problem. See Trading Techs. Int’l, Inc. v. IBG LLC, 921 F.3d 1378, 1384-85 (Fed. Cir. 2019).
Hence, under Prong Two of Step 2A, the additional elements, when considered individually or in combination, do not integrate the judicial exception into a practical application.
Hence, the claims are ineligible under Step 2A.
Step 2B:
In Step 2B, the evaluation consists of whether the claim recites additional elements that amount to an inventive concept (aka “significantly more”) than the recited judicial exception.
As discussed in Prong Two, the additional elements in the claims amount to no more than mere instructions to apply the exception using generic components, which is insufficient to provide an inventive concept.
When considered individually or as an ordered combination, the additional elements fail to transform the abstract idea of – receiving a request from a user to generate a virtual card number and a payment restriction on the virtual card number; generating the virtual card number, wherein the virtual card number is not a same number as a card number of the user, the virtual card number generated based upon a digital identification of the user, a digital identification of a payee, and a random value; transmitting the virtual card number and the payment restriction to a payment processor; and causing the virtual card number in a transaction with the payee – into significantly more.
See MPEP 2106.05(f) Mere Instructions To Apply An Exception [R-10.2019].
(2) Whether the claim invokes computers or other machinery merely as a tool to perform an existing process. Use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) or simply adding a general purpose computer or computer components after the fact to an abstract idea (e.g., a fundamental economic practice or mathematical equation) does not integrate a judicial exception into a practical application or provide significantly more.
Hence, the claims are ineligible under Step 2B.
Therefore, the claim(s) are rejected under 35 U.S.C. 101 as being directed to a judicial exception without significantly more.
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 1-20
Claims 1-20 are rejected under 35 U.S.C. 103 as being unpatentable over Johnson (WO2025064399A1) in view of Kumawayat (US20190034914A1).
Claim 1:
A computer-implemented method for generating and utilizing virtual card numbers within a mobile wallet, the method comprising:
receiving, by a mobile wallet application, a request from a user, through a user interface element, to generate a virtual card number and a payment restriction on the virtual card number;
(See Johnson: Page 2 (“a request to create a virtual payment card for the individual is received by the payment platform”)
(See Johnson: Page 13 (“Use limits may restrict the use of the virtual payment card to a period of time, geographical area, one or more vendors, a total or per-purchase spending limit, spending limits per category, e.g., dining limits per day or per meal, etc.”)
generating, by the mobile wallet application, [ … the virtual card number, wherein the virtual card number is not a same number as a card number of the user, (the virtual card number generated based upon a digital identification of the user, a digital identification of a payee, and a random value) …];
(See Johnson: Page 2 (“In response to the request, the payment platform generates a virtual card number (VCN) and forwards the VCN to a mobile application executing on a mobile device associated with the individual”)
transmitting, by the mobile wallet application, the virtual card number and the payment restriction to a payment processor; and
(See Johnson: Page 2 (“In response to the request, the payment platform generates a virtual card number (VCN) and forwards the VCN to a mobile application executing on a mobile device associated with the individual”)
causing use, by the mobile wallet application, of the virtual card number in a transaction with the payee.
(See Johnson: Claim 4 (“responsive to the digitization data (818), pushing (820) the digitization data to a digital wallet application (165) deployed on the mobile device (160), thereby allowing the individual (162) to make the purchase the NFC payment terminal using the VCN (167).”)
Johnson does not specifically disclose:
the virtual card number generated based upon a digital identification of the user, a digital identification of a payee, and a random value;
However, Kumawat discloses the above limitation
(See Kumawat: Para
[0016] (“The term “virtual card account number”, in various implementations disclosed herein, refers to a randomly generated number for making financial transactions, such as purchases from a merchant”)
[0017] (“The virtual card account number may be a 16 digit number resembling a typical credit or debit card account number, where a portion of this 16 digit number (typically the leading 6 digits) is fixed as it is needed to identify the issuer of the virtual card account number, while the remainder is randomly generated.”)
Therefore, it would have been obvious to a person having ordinary skills in the art before the effective filing date of the invention to modify the above noted disclosure of Johnson as it relates to corporate payments using virtual payment cards to include the above noted disclosure of Kumawat as it relates to offline payment using virtual card number. The motivation for combining the references would have been to enable employees or contractors to carry out offline transactions on behalf of an organization subject to use restrictions.
Claims 8, 15 are similar to claim 1 and hence rejected on similar grounds.
Claim 2:
wherein the payment restriction includes at least one of a spending limit, an expiration date, or a merchant-specific usage restriction.
(See Johnson: Page 13 (“Use limits may restrict the use of the virtual payment card to a period of time, geographical area, one or more vendors, a total or per-purchase spending limit, spending limits per category, e.g., dining limits per day or per meal, etc.”)
Claims 9, 16 are similar to claim 2 and hence rejected on similar grounds.
Claim 3:
creating a mobile payment cryptogram utilizing the virtual card number; and
(See Johnson: Pages 15, 17)
transmitting the cryptogram to a second computing device using near-field communications (NFC).
(See Johnson: Claim 4)
Claims 10, 17 are similar to claim 3 and hence rejected on similar grounds.
Claim 4:
where the second computing device is a point-of-sale device of a merchant.
(See Johnson: Page 15)
Claims 11, 18 are similar to claim 4 and hence rejected on similar grounds.
Claim 5:
receiving an indication from a UI of the mobile wallet, that the virtual card number is to be invalidated; and
(See Kumawat: Para [0023])
sending a command to invalidate the virtual card number to the payment processor.
(See Kumawat: Para [0028])
Claims 12, 19 are similar to claim 5 and hence rejected on similar grounds.
Claim 6:
receiving, from a transacting party computing device, a mobile ID of a transacting party; and
(See Kumawat: Para [0027])
providing the mobile ID to the payment processor along with the virtual card number, the payment processor only allowing transactions with the virtual card number from the transacting party when the mobile ID is provided to the payment processor with the transaction.
(See Johnson: Claim 3)
Claims 13, 20 are similar to claim 6 and hence rejected on similar grounds.
Claim 7:
wherein generating, by the mobile wallet application, the virtual card number comprises contacting the payment processor to associate the virtual card number with the card number of the user.
(See Johnson: Page 6)
Claim 14 is similar to claim 7 and hence rejected on similar grounds.
Response to Arguments
Applicant's arguments filed 6/25/2026 have been fully considered but they are not persuasive.
101
Applicant argues citing para [0010], [0011] that the traditional virtual card systems are typically restricted to online purchases rendering them unusable or inconvenient for in-person transactions.
Examiner finds this unpersuasive because the fact that traditional virtual card systems are typically restricted to online purchases rendering them unusable or inconvenient for in-person transactions – is not a technical problem but business problem. Similarly, lacking the ability to set granular restrictions such as merchant specific usage or precise spending limits which can leave users vulnerable to fraud – are again business problems and not technical in nature.
Applicant argues citing para [0013] – [0015] that the application describes a particular technical improvement for accomplishing the, including a bitstream of the digital identification as input into cryptographic generation algorithm and verifying the resulting value at the payment processor which is an improvement to the security of the mobile payment technology.
Examiner finds this unpersuasive because the arguments are not commensurate with the scope of the claims none of the which recite the above-mentioned features.
Claims 1-20 do not recite (i) an improvement to the functionality of a computer or other technology or technical field; (ii) a “particular machine” to apply or use the judicial exception; (iii) a particular transformation of an article to a different thing or state; or (iv) any other meaningful limitation. See MPEP 2106.05 (a)-(c), (e)-(h). Hence, the additional elements, when considered individually or as an ordered combination, fail to integrate the abstract idea into a practical application or provide significantly more. See MPEP 2106.05(f)
103
Applicant argues that the cited references does not teach the limitation “generating, by the mobile wallet application, the virtual card number, wherein the virtual card number is not a same number as a card number of the user, (the virtual card number generated based upon a digital identification of the user, a digital identification of a payee, and a random value).”
Examiner respectfully disagrees.
Kumawat discloses: Para
[0016] (“FIG. 1 shows a block diagram of a system 100 which enables payment using a virtual card account number at a payment terminal 118. The term “virtual card account number”, in various implementations disclosed herein, refers to a randomly generated number for making financial transactions, such as purchases from a merchant, a cashback program (where an extra amount added into purchases made at the merchant is obtained in cash, in lieu of having to withdraw the cash from an ATM (automated teller machine) or bank). An account number (hereafter also referred to as an “originating account number”) is needed, to which the randomly generated number is linked, where it is the originating account number that is used to fund the financial transaction. The originating account number is thus an identifier for an account that is opened with a financial institution for banking services like deposit or withdrawal of funds and includes, but is not limited to, a deposit account, a current account or a credit card account.”)
[0017] (“The virtual card account number avoids having to reveal the originating account number to the merchant, which provides ease of mind to customers who wish to protect their financial details. The virtual card account number may be a 16 digit number resembling a typical credit or debit card account number, where a portion of this 16 digit number (typically the leading 6 digits) is fixed as it is needed to identify the issuer of the virtual card account number, while the remainder is randomly generated. It may have a credit or fund limit set by the issuer or the account holder. The virtual card account may have an expiry date such that it can no longer be used to perform a transaction after the expiry date. The expiry date may be set by the issuer of the virtual card account number or the account holder. When the virtual card account number expires, any remaining unused funds or credit in the virtual card account are credited back to the originating account number.”)
[0024] (“The issuer server 106 is realised by one or more computers (for example, server terminals) that are used to administer data communication with an issuer, such data communication being related to financial services provided by the issuer. These services include creatiing a virtual card account number based on one or more accounts registered to a customer and processing financial transactions that are made using the virtual card account number. These accounts include a deposit account, a current account or a credit card account. The deposit account and current account are traditional banking accounts where funds may be withdrawn up to an amount of existing funds and funds deposited. The credit card account is one issued on behalf of card networks such as MasterCard® or Visa®, where funds may be utilised up to a credit limit.”)
Based on para [0016], the virtual card number is linked to the originating account number. Based on para [0017], a portion (e.g. 6 digits) of the virtual card number resembles typical credit or debit card account number while the remaining portion is randomly generated. Therefore, since the virtual card number is a combination of a portion of credit/debit card number and a random number, it clearly is not the same as a card number of the user. Based on para [0024], Kumawat also discloses creating a virtual card account number based on one or more accounts registered to a customer – which indicates that the virtual card number is based on cardholder account number(s) and the financial institution identification.
Applicant’s argument, citing para [0021], [0034], that the payee is the merchant whose digital identification may be merchant id – is not commensurate with the scope of the claims because the claims do not specify the payee as a merchant. The claim language does not preclude the issuer number as the digital payee identifier. However, Examiner also points out that Page 8 of Johnson discloses transaction between merchant (not shown), issuer bank and merchant’s acquirer bank.
Therefore, based on the above disclosure, Johnson teaches that the virtual card number is not the same number as the card number of the user, and is generated based on a digital identification of the user, digital identification of the payee, and a random value.
For the above reasons, the Applicant’s arguments are not persuasive.
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.
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/ARUNAVA CHAKRAVARTI/Primary Examiner, Art Unit 3692
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