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 .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 12/12/2025 has been entered.
Response to Amendment
Applicant’s “Amendment” filed on 12/12/2025 has been considered.
Claims 1, 11, and 21 are amended. Claims 9, 19, and 29 are canceled. Claims 1-6, 8, 10-16, 18, 20-26, 28, and 30 remain pending in this application and an action on the merits follow.
Information Disclosure Statement
The information disclosure statement (IDS) submitted on 01/02/2026 is in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner.
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 1-6, 8, 10-16, 18, 20-26, 28, and 30 are rejected under 35 USC 101. The claimed invention is directed to non-statutory subject matter because claims 1, 11, and 21 are directed to an abstract idea without significantly more. Claims 2-6, 8, 10, 12-16, 18, 20, 22-26, 28, and 30 fail to remedy these deficiencies.
The claims 1, 11, and 21 recite interfacing an intermediate platform with a practice management system, interfacing the intermediate platform with an accounting system, obtaining payment information, maintaining a rules database that defines a plurality of contract types and one or more GAAP-adhering waterfalling rules, providing the payment information to the accounting system, and effectuating a reconciliation procedure, extracting transaction data from the practice management system, extracting transaction data from the accounting system, the transaction data including the one or more GAAP-adhering journal entries, and verifying that each transaction in the practice management system has a corresponding GAAP-adhering journal entry.
The Claims 1, 11, and 21 recite interfacing, maintaining, providing, effectuating, extracting, and verifying steps as drafted, are processes that under broadest reasonable interpretation, cover performance of managing personal behavior, but for the recitation of generic computer components. That is, other than reciting “A computing system including a processor and memory, a rule database, an intermediate platform, a practice management system, and an accounting system”, nothing in the claim element precludes the steps from practically being performed by organizing human activity. For example, but for the “A computing system including a processor and memory, a rule database, an intermediate platform, a practice management system, and an accounting system” in the context of these claims encompasses a person manually interfaces/communicates an intermediate platform with a practice management system, interfaces/communicates the intermediate platform with an accounting system, maintains a plurality of contract type and waterfalling rules, provides the payment information, effectuates a reconciliation procedure by extracting transaction data from the account system and the practice management system to verify that each transaction in the practice management system has a corresponding journal entry. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation by managing personal behavior but for the recitation of generic computer components, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claims recite an abstract idea.
This judicial exception is not integrated into a practical application because obtaining step is recited at a high level of generality (i.e., as a general means of collecting payment information step) and amounts to mere data gathering, which is a form of insignificant extra-solution activity. This judicial exception is not integrated into a practical application because the claims as a whole merely describe how to generally “apply” the concept of interfacing, obtaining, maintaining, providing, effectuating, extracting, and verifying in a computer environment. The claimed computer components such as the computing system including the processor and the memory, the rule database, the intermediate platform, the practice management system, and the accounting system are recited at a high level of generality and are merely invoked as tools to perform interfacing, obtaining, maintaining, providing, effectuating, extracting, and verifying steps. Simply implementing the abstract idea on a generic computer is not a practical application of the abstract idea. Accordingly, this additional element does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. The claims 1, 11, and 21 are directed to an abstract idea.
The claims 1, 11 and 21 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 using the computing system including the processor and the memory, the rule database, the intermediate platform, the practice management system, and the accounting system to perform interfacing, obtaining, maintaining, providing, effectuating, extracting, and verifying steps amount to no more than mere instructions to apply the exception using generic computer components. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Therefore, the claim does not amount to significantly more than the recited abstract idea (Step 2B: NO). The claims 1, 11, and 21 are not patent eligible.
Claims 2-6, 8, 10, 12-16, 18, 20, 22-26, 28, and 30, disclose insignificant helpful content to further describe content, such as a first application, a second application, an orthodontics practice management system, the payment information is utilizable to reconcile cash inflows, periodically obtaining payment information, and processing the payment information, which are merely descriptive content to further limit the abstract idea but not make it less abstract. Thus, the claims 2-6, 8, 10, 12-16, 18, 20, 22-26, 28, and 30 are directed to an abstract idea.
This judicial exception is not integrated into a practical application because descriptive content in claims 2-6, 8, 10, 12-16, 18, 20, 22-26, 28, and 30 further limit the abstract idea but not make it less abstract. Thus, the claims 2-6, 8, 10, 12-16, 18, 20, 22-26, 28, and 30 are directed to an abstract idea.
There are no additional claim element limitations recited in the claims 2-6, 8, 10, 12-16, 18, 20, 22-26, 28, and 30. Therefore, the claim does not amount to significantly more than the recited abstract idea (Step 2B: NO). The claims 2-6, 8, 10, 12-16, 18, 20, 22-26, 28, and 30 are not patent eligible.
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 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.
Claims 1-6, 8, 10-16, 18, 20-26, 28, and 30 are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Patent Application Publication No. 2017/0300642 to Colabella et al., in view of U.S. Patent Application Publication No. 2008/0201246 to Casey et al., in view of U.S. Patent Application Publication No. 2017/0236217 to Suggula et al., and further in view of U.S. Patent No. 10,311,412 to Josephs et al.
With regard to claims 1, 11, and 21, Colabella discloses a computing system including a processor and memory configured to perform operations comprising (Fig. 1, a computer):
interfacing an intermediate platform with a practice management system (Fig. 1, paragraph 30-31 and 35, When the Payment Bridge is initially set up and configured. The Payment Bridge application server stores a unique integration key for a variety of different practice management software systems);
interfacing the intermediate platform with an accounting system (paragraph 7, 14, 30-31 and 35, The Payment Bridge application server stores a unique integration key for a variety of different practice management software systems. payments made through the Payment Bridge automatically populate the relevant bookkeeping fields of the practice management software. Examiner notes that the practice management software include functionality of an accounting system.);
obtaining, on the intermediate platform, payment information from the practice management system, wherein this payment information concerns one or more contracts administered on the practice management system (paragraphs 49 and 62, This form is used to create a contract with a patient to leave their card on file for a payment plan or a charge later down the road. We have now integrated this form electronically into the Payment Bridge. We can now also pull information from the software before the transaction is even made. For example, if a patient has an outstanding balance of $30 for a co-pay in the merchants Practice Management Software, before bi-directional integration the merchant would have had to manually enter the $30 and relevant patient information into our system. With bi-directional integration we can have the system pull information such as outstanding balance, patient name, patient account number and more into our system upon generating a payment.); and
providing the payment information to the accounting system so that AR inflows defined within the payment information can be acknowledged for GAAP adherence purposes (paragraphs 7 and 62-63, The Payment Bridge includes software for enabling payment processing on an automated and highly reliable level which integrates with the payment parameters of practice management software such that payments made through the Payment Bridge automatically populate the relevant bookkeeping fields of the practice management software. process the payment and then allow our system to automatically post the payment back into their software. For example, the most common parameter to use for bi-directional integration is the payment amount due. The merchant's practice management software will have a recorded balance for the patient of how much they owe, this will be updated into the browser tab and allow Payment Bridge to automatically fill in the payment amount upon the start of the transaction, saving the end-user the time to enter it in themselves.).
However, Colabella does not disclose maintaining a rules database that defines a plurality of contract types and one or more GAAP-adhering waterfalling rules concerning the plurality of contract types; and wherein providing the payment information to the accounting system includes processing the one or more GAAP-adhering waterfalling rules concerning a respective contract type for the one or more contracts into one or more GAAP-adhering journal entries defining an initial payment as deferred revenue; and effectuating a reconciliation procedure to ensure that changes made within the practice management system are replicated onto the accounting system by: extracting transaction data from the practice management system, extracting transaction data from the accounting system, the transaction data including the one or more GAAP-adhering journal entries, and verifying that each transaction in the practice management system has a corresponding GAAP-adhering journal entry.
However, Casey teaches maintaining a rules database that defines a plurality of contract types and one or more GAAP-adhering waterfalling rules concerning the plurality of contract types (a waterfall may use a sequence of hurdles and a declining total distributable capital balance approach, in that, for each hurdle or step within the waterfall agreement, the total distributable capital balance of the joint venture (or property where applicable) reduces by the amount, shared between members, of the previous hurdle. a waterfall may be used to determine capital distributions. The hurdles sets portion 226 may define one or more hurdle sets for one or more waterfalls to determine one or more distributions in accordance with the distribution plans set forth in one or more joint venture agreements. each type of Capital Contribution (identified by an account within the chart of accounts) is defined within the contractual joint venture agreement., paragraphs 81-83, 110, and 338).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Colabella to include, maintaining a rules database that defines a plurality of contract types and one or more GAAP-adhering waterfalling rules concerning the plurality of contract types, as taught in Casey, in order to receive information associated with a joint venture, determine an amount of a distribution based at least in part on the information (Casey, paragraph 8).
However, Suggula teaches providing the payment information to the accounting system includes processing the one or more GAAP-adhering waterfalling rules concerning a respective contract type for the one or more contracts into one or more GAAP-adhering journal entries defining an initial payment as deferred revenue (Revenue arrangements provide a benefit of time savings by enabling a rule-based approach to triggering the start of amortization or other revenue recognition operations. Hence an organization or enterprise needs to ensure the accurate and timely recognition/processing of revenue, the process of which is subject to multiple accounting standards/guidance (e.g., US GAAP and IFRS). As discussed above, the functionality is provided to automatically assign such contingencies (using user configurable rules) to the revenue arrangements so that revenue is deferred until those contingencies are completed or fulfilled. The fourth triggered event 474 may be the allocation of a cost when the trackable event is accomplished. Deferring a cost requirement in the revenue arrangement allows a seller to consider some of the costs incurred to obtain/fulfill a sales contract as capitalized in order to amortize over a certain period of time. In an embodiment, the triggered action may be to (1) identify how much cost should be immediately recognized vs. amortized and to (2) identify how to “allocate” deferred cost across multiple trackable elements (similar to revenue allocation). Then, (3) identify the actual start/end date of deferred cost amortization, or its amortization pattern. The system supports multiple general ledger (GL) books to enable the user to maintain one or more of country specific accounting needs, enable consolidation of subsidiary accounts, or achieve the elimination of Intercompany journals, and the like., paragraphs 23, 61, 62, and 64).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Colabella to include, providing the payment information to the accounting system includes processing the one or more GAAP-adhering waterfalling rules concerning a respective contract type for the one or more contracts into one or more GAAP-adhering journal entries defining an initial payment as deferred revenue, as taught in Suggula, in order to offer an opportunity to tie a trackable event to a revenue element, and as a result, to trigger commencement of amortization or another revenue recognition operation (Suggula, paragraph 4).
However, Josephs teaches effectuating a reconciliation procedure to ensure that changes made within the practice management system are replicated onto the accounting system by: extracting transaction data from the practice management system, extracting transaction data from the accounting system, the transaction data including the one or more GAAP-adhering journal entries, and verifying that each transaction in the practice management system has a corresponding GAAP-adhering journal entry (depositing the check in the provider's bank account and forwarding the remittance advice information to the provider in paper or electronic format. The information may be entered into an accounts receivable system. The provider must then periodically reconcile the accounts receivable information with the deposits in the provider's bank. The purpose of the reconciliation is to ensure that the payments posted to the accounts receivable system can be matched with the actual deposits made to the provider's bank. At step 424, the remittance advice may be sent to the Provider or other recipient for updating an accounts receivable system, patient accounting system and/or a practice management system. At step 426, the Processor may generate a payment confirmation message to the Payer (e.g., Insurer) to verify that payment has been made. The Processor may also generate and transmit a confirmation message to the Provider (e.g., doctor, hospital, etc.) to verify payment and remittance advice have been received. In addition, the payment and the remittance advice may be reconciled. The system associated with the healthcare provider comprises one or more of an accounts receivable system, patient accounting system and practice management system and wherein accounts receivable data is updated; automatically linking, with the programmed computer processor, the payment data and the remittance advice to facilitate reconciliation of one or more payments, wherein the payment data and the remittance advice are associated with an identifier; generating, via the programmed computer processor, an interactive interface via the communication network for monitoring and interacting with the payment data and the remittance advice, the interactive interface enables the healthcare provider to view and time future payments that have been initiated by the insurer payer to manage cash and receivables, fig, 4, col. 2, lines 16-41 and col 13, lines 32-44 and claim 1).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the combination of references to include, effectuating a reconciliation procedure to ensure that changes made within the practice management system are replicated onto the accounting system by: extracting transaction data from the practice management system, extracting transaction data from the accounting system, the transaction data including the one or more GAAP-adhering journal entries, and verifying that each transaction in the practice management system has a corresponding GAAP-adhering journal entry, as taught in Josephs, in order to ensure that the payments posted to the accounts receivable system can be matched with the actual deposits made to the provider's bank (Josephs, col. 2, lines 38-41).
With regard to claims 2, 12, and 22, Colabella discloses interfacing an intermediate platform with a practice management system includes: configuring a first application program interface on the practice management system to enable interfacing with the intermediate platform (paragraph 30-31 and 35).
With regard to claims 3, 13, and 23, Colabella discloses interfacing the intermediate platform with an accounting system includes: configuring a second application program interface on the accounting system to enable interfacing with the intermediate platform (paragraph 7, 14, 30-31 and 35).
With regard to claims 4, 14, and 24, Colabella discloses the practice management system includes: an orthodontics practice management system (paragraph 11, a wide variety of medical or dental practice management software).
With regard to claims 5, 15, and 25, the combination of references substantially discloses the claimed invention, however, the combination of references does not disclose the payment information provided to the accounting system is utilizable to reconcile AR inflows defined within the payment information with cash inflows defined within an external bank account.
However, Josephs teaches the payment information provided to the accounting system is utilizable to reconcile AR inflows defined within the payment information with cash inflows defined within an external bank account (Providers bear the cost of processing the incoming mailed payment, manually depositing the check, and manually entering the data from the remittance advice into their accounts receivable system (also known as a patient accounting system or practice management system). The information may be entered into an accounts receivable system. The provider must then periodically reconcile the accounts receivable information with the deposits in the provider's bank, col. 1, lines 30-35 and col. 2, lines 33-41).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the combination of references to include, the payment information provided to the accounting system is utilizable to reconcile AR inflows defined within the payment information with cash inflows defined within an external bank account, as taught in Josephs, in order to ensure that the payments posted to the accounts receivable system can be matched with the actual deposits made to the provider's bank (Josephs, col. 2, lines 38-41).
With regard to claims 6, 16, and 26, Colabella discloses obtaining, on the intermediate platform, payment information from the practice management system includes: periodically obtaining, on the intermediate platform, payment information from the practice management system (abstract, updating the practice management software to reflect payment by credit card when the charge is accepted by the credit card processing system. Examiner notes that credit card transaction can be processed periodically in a batch (e.g., daily)).
With regard to claims 8, 18, and 28, Colabella discloses processing the payment information obtained from the practice management system to remove Personally Identifiable Information (PII) from the payment information (paragraph 37, eliminates sensitive cardholder data from the payment device).
With regard to claims 10, 20, and 30, Colabella discloses effectuating a reconciliation procedure to ensure that changes made within the accounting system are replicated onto the practice management system (paragraphs 12-14, a Payment Bridge which acts as a plug-in providing a simple user interface that accepts payments while simultaneously updating client ledgers and bookkeeping ledgers in the practice management software being utilized by the healthcare professional.).
Response to Arguments
Applicants' arguments filed on 12/12/2025 have been fully considered but they are not fully persuasive especially in light of the previously references applied in the rejections.
Applicants remark that “the combination of references does not disclose effectuating a reconciliation procedure to ensure that changes made within the practice management system are replicated onto the accounting system by: extracting transaction data from the practice management system, extracting transaction data from the accounting system, the transaction data including the one or more GAAP-adhering journal entries, and verifying that each transaction in the practice management system has a corresponding GAAP-adhering journal entry”.
Examiner directs Applicants' attention to the office action above.
Conclusion
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/ARIEL J YU/Primary Examiner, Art Unit 3627
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