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 communication(s) filed on 02 July 2026 and Supplemental Amendment filed on 12 August 2026.
Claims 1, 3, 6, 8-9, 10-12, 14-15 and 20 are amended.
Claim 2 is cancelled.
Claim(s) 1 and 3-20 is/are currently pending and have been examined.
Response to Arguments
Applicant's arguments filed 02 July 2026 and 12 August 2026 have been fully considered but they are not persuasive.
Claim Objections
The claims have been amended to address the objection(s)/rejection(s) presented in the prior Office Action. Accordingly, Examiner withdraws the corresponding objection(s)/rejection(s).
Rejections Under 35 U.S.C. §101
Step 2A Prong One
Applicant argues that the claims do not relate to commercial or legal interactions. Examiner respectfully disagrees. Step 2A Prong 1 requires examiners to evaluate whether a claim recites a judicial exception as the applicant cited. The elements which examiner identified in Step 2A Prong 1 are those which describe the noted abstract idea which means that the claim recites an abstract idea. “The mere inclusion of a judicial exception such as a mathematical formula (which is one of the mathematical concepts identified as an abstract idea in MPEP § 2106.04(a)) in a claim means that the claim "recites" a judicial exception under Step 2A Prong One.” See MPEP 2106.04(II)(A)(2). “When performing the analysis at Step 2A Prong One, it is sufficient for the examiner to provide a reasoned rationale that identifies the judicial exception recited in the claim and explains why it is considered a judicial exception (e.g., that the claim limitation(s) falls within one of the abstract idea groupings). Therefore, there is no requirement for the examiner to rely on evidence, such as publications or an affidavit or declaration under 37 CFR 1.104(d)(2), to find that a claim recites a judicial exception. Cf. Affinity Labs of Tex., LLC v. Amazon.com Inc., 838 F.3d 1266, 1271-72, 120 USPQ2d 1210, 1214-15 (Fed. Cir. 2016) (affirming district court decision that identified an abstract idea in the claims without relying on evidence); OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1362-64, 115 USPQ2d 1090, 1092-94 (Fed. Cir. 2015) (same); Content Extraction & Transmission LLC v. Wells Fargo Bank, N.A., 776 F.3d 1343, 1347, 113 USPQ2d 1354, 1357-58 (Fed. Cir. 2014) (same).” See MPEP 2106.07(a)(III). The omitted element(s) (if any) are elements in addition to the abstract idea (i.e. they are not abstract) which require further analysis under Step 2A Prong 2 in order to determine if they cause the recited abstract idea to be integrated into a practical application. See MPEP 2106.07(a)(II). The omitted element(s) (if any) are later enumerated under Step 2A Prong 2 as additional elements. The claims recite and/or describe a judicial exception.
Step 2A Prong Two
Applicant argues that the claims recite technical improvement to token management by controlling the access, release and swapping of tokens based on triggering events. Examiner respectfully disagrees. The MPEP clarifies how additional elements can impose meaningful limits on a recited judicial exception:
“Consideration of improvements is relevant to the eligibility analysis regardless of the technology of the claimed invention. That is, the consideration applies equally whether it is a computer-implemented invention, an invention in the life sciences, or any other technology. See, e.g., Rapid Litigation Management v. CellzDirect, Inc., 827 F.3d 1042, 119 USPQ2d 1370 (Fed. Cir. 2016), in which the court noted that a claimed process for preserving hepatocytes could be eligible as an improvement to technology because the claim achieved a new and improved way for preserving hepatocyte cells for later use, even though the claim is based on the discovery of something natural. Notably, the court did not distinguish between the types of technology when determining the invention improved technology. However, it is important to keep in mind that an improvement in the abstract idea itself (e.g. a recited fundamental economic concept) is not an improvement in technology. For example, in Trading Technologies Int’l v. IBG, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019), the court determined that the claimed user interface simply provided a trader with more information to facilitate market trades, which improved the business process of market trading but did not improve computers or technology.” (MPEP 2106.05(a)(II))
Drawing attention to the emphasized section, an improvement in the judicial exception itself is not an improvement in technology. In the current case, regardless of whether or not applicant’s invention improves the recited judicial exception, improving a method, algorithm, or process of a judicial exception absent of any technological modification, would be an improvement to the judicial exception (e.g. via the improvement in the efficiency of the judicial exception), but does not improve computers or technology.
Applicant argues that the claimed concept is used in conjunction with a particular machine that is integral to the claim. Examiner respectfully disagrees. “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. See Affinity Labs v. DirecTV, 838 F.3d 1253, 1262, 120 USPQ2d 1201, 1207 (Fed. Cir. 2016) (cellular telephone); TLI Communications LLC v. AV Auto, LLC, 823 F.3d 607, 613, 118 USPQ2d 1744, 1748 (Fed. Cir. 2016) (computer server and telephone unit). Similarly, "claiming the improved speed or efficiency inherent with applying the abstract idea on a computer" does not integrate a judicial exception into a practical application or provide an inventive concept. Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 1367, 115 USPQ2d 1636, 1639 (Fed. Cir. 2015)” (See MPEP 2106.05(f)). The use of generic computing components in the instant application to increase the speed or efficiency of the recited judicial exception does not afford the claim eligibility.
Step 2B
Applicant argues no evidence was provided for Step 2B of the analysis as required. Examiner respectfully disagrees. “Although the conclusion of whether a claim is eligible at Step 2B requires that all relevant considerations be evaluated, most of these considerations were already evaluated in Step 2A Prong Two. Thus, in Step 2B, examiners should:
• Carry over their identification of the additional element(s) in the claim from Step 2A Prong Two;
• Carry over their conclusions from Step 2A Prong Two on the considerations discussed in MPEP §§ 2106.05(a) - (c), (e) (f) and (h):
• Re-evaluate any additional element or combination of elements that was considered to be insignificant extra-solution activity per MPEP § 2106.05(g), because if such re-evaluation finds that the element is unconventional or otherwise more than what is well-understood, routine, conventional activity in the field, this finding may indicate that the additional element is no longer considered to be insignificant; and
• Evaluate whether any additional element or combination of elements are other than what is well-understood, routine, conventional activity in the field, or simply append well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception, per MPEP § 2106.05(d)” (See MPEP 2106.05(II)).
In both the prior and instant Office Action, the conclusions from Step 2A Prong Two are equally applied in Step 2B which further re-evaluates additional elements which are considered to be insignificant extra-solution activity and evaluates these elements as per MPEP §2106.05(d) to be well-understood, routine, and conventional activity. Said elements which are considered to be insignificant extra-solution activity (if any) are evaluated as well-understood, routine, and conventional as per the evidentiary requirements detailed in MPEP §2106.07(a)(III) utilizing option (B) via citation to one or more of the court decisions discussed in MPEP §2106.05(d)(II). Thus, there are no further elements to evaluate under Step 2B. Most considerations relating to any additional elements were already evaluated in Step 2A Prong Two and thus do not require further re-evaluation in Step 2B.
Applicant argues that the Office Action fails to consider the additional elements in combination in a way that deviates from what is routine or conventional. Examiner respectfully disagrees. In order for additional elements to provide more than what is well-understood, routine, and conventional, the additional elements must in combination provide additional functionality that is not present when considering the elements individually. Examiner notes that the additional elements do not in combination provide for additional functionality.
Rejections Under 35 U.S.C. §103
The claims have been amended to address the objection(s)/rejection(s) presented in the prior Office Action. Accordingly, Examiner withdraws the corresponding objection(s)/rejection(s).
Arguments provided on 12 August 2026
Applicant argues that the claims are directed to technical improvements in automated data analytics using AI and machine learning, monitoring, synchronization, and access management by blockchain and smart contracts. The MPEP clarifies how additional elements can impose meaningful limits on a recited judicial exception:
“Consideration of improvements is relevant to the eligibility analysis regardless of the technology of the claimed invention. That is, the consideration applies equally whether it is a computer-implemented invention, an invention in the life sciences, or any other technology. See, e.g., Rapid Litigation Management v. CellzDirect, Inc., 827 F.3d 1042, 119 USPQ2d 1370 (Fed. Cir. 2016), in which the court noted that a claimed process for preserving hepatocytes could be eligible as an improvement to technology because the claim achieved a new and improved way for preserving hepatocyte cells for later use, even though the claim is based on the discovery of something natural. Notably, the court did not distinguish between the types of technology when determining the invention improved technology. However, it is important to keep in mind that an improvement in the abstract idea itself (e.g. a recited fundamental economic concept) is not an improvement in technology. For example, in Trading Technologies Int’l v. IBG, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019), the court determined that the claimed user interface simply provided a trader with more information to facilitate market trades, which improved the business process of market trading but did not improve computers or technology.” (MPEP 2106.05(a)(II))
Drawing attention to the emphasized section, an improvement in the judicial exception itself is not an improvement in technology. In the current case, regardless of whether or not applicant’s invention improves the recited judicial exception, improving a method, algorithm, or process of a judicial exception absent of any technological modification, would be an improvement to the judicial exception (e.g. via the improvement in the efficiency of the judicial exception), but does not improve computers or technology.
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.
Step 1 of the 101 Analysis:
Claims 1 and 3-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. The claims recites a computer-implemented method, system, and non-transitory computer-readable medium for blockchain-based software-as-a-service platform for automatically coordinating reverse transactions. These are a process, machine, and article of manufacture which are within the four categories of statutory subject matter.
Step 2A Prong 1 of the 101 Analysis:
The following limitations and/or similar versions are recited in claim(s) 1, 15 and 20:
Claim(s) 1, 15 and 20:
“receiving,…, historical data related to a set of different entities;”
“filtering the received data in accordance with specific criteria to determine a filtered subset of the entities each associated with data regarding a shared interest type;”
“generating a set of profiles associated with predictions for the subset of entities based on use of a first…model to make the predictions for each of the entities in the subset based on the historical data;”
“generating a new profile for at least one of the entities when the first…model updates one of the predictions for the at least one entity;”
“verifying statuses of the subset of the investing entities by reference to an immutable record of identity documents stored…;”
“generating a smart contract based on the terms and commitments associated with the one or more of the subset of entities, wherein the smart contract…:”
“actively monitor…data in accordance with the terms and commitments associated with the one or more of the subset of entities;”
“identify that one of the changes pertains to a key milestone among conditions for adjusting risk based on the profiles of the subset of entities, wherein identifying the key milestone is based on data received by the …network and validated…;”
“… swap at least one of … tokens for one or more risk mitigation tokens associated with the at least one entity of the subset of entities;”
“codify a conditional hold on token access to… tokens until all key milestones of the conditions specified by the smart contract are determined to have been met.”
Claim(s) 1 and 20:
“…generating a custom set of filing documents for the at least one entity in accordance with the new profile for the at least one entity;”
Claim 15:
“…generating a custom set of filing forms for the at least one entity in accordance with the new profile for the at least one entity;”
These limitations, as drafted, are a process that, under its broadest reasonable interpretation, describes Commercial or Legal Interactions but for the recitation of generic computer components. That is, other than reciting “over a Software as a Service network”, “on the blockchain”, “a communication interface that communicates over a communication network with a Software as a Service network platform…with a blockchain”, “a processor that executes instructions stored in memory, wherein the processor executes the instructions to:”, or “A non-transitory computer-readable storage medium having instructions embodied thereon, the instructions executable by a computing system to perform a method of managing deal data using blockchain, the method comprising:” nothing in the claims’ elements precludes the steps from practically describing Commercial or Legal Interactions. For example, but for the recited computer language, the limitations in the context of this claim describes Business Relations. A Business Relation is described when performing and reporting private equity transactions. If a claim limitations, under their broadest reasonable interpretation, describes Commercial or Legal Interactions but for the recitation of generic computer components, then it falls within the “Certain Methods of Organizing Activity” grouping of abstract ideas.
Accordingly, the independent claims recite an abstract idea.
Step 2A Prong 2 of the 101 Analysis:
This judicial exception is not integrated into a practical application. In particular, the independent claim(s) recite the following (or similar) additional elements:
Claim(s) 1, 15 and 20:
“…over a Software as a Service network…”
“…machine-learning…”
“…machine-learning…”
“automatically…”
“…on the blockchain;”
“securely recording on the blockchain an auditable record of terms and commitments associated with one or more of the verified entities;”
“…is recorded on the blockchain and executable to…”
“…real-time…”
“continuously synchronize the data to reflect one or more changes in accordance with the active monitoring;”
“…Software as a Service…by the blockchain;”
“automatically…blockchain…”
“…the blockchain…”
Claim 15:
“a communication interface that communicates over a communication network with a Software as a Service network platform…with a blockchain;”
“a processor that executes instructions stored in memory, wherein the processor executes the instructions to:”
Claim 20:
“A non-transitory computer-readable storage medium having instructions embodied thereon, the instructions executable by a computing system to perform a method of managing entity data using blockchain, the method comprising:”
The computer components (software as a service (SaaS), automation, communication interface, processor, computing system, memory, and non-transitory computer-readable medium) are recited at a high level of generality (i.e. as a generic SaaS, generic automation, a generic communication interface, a generic processor, generic computing system, and generic storage) such that it amounts to no more than mere instructions to implement the judicial exception on a computer or by using a computer merely as a tool to perform an existing process. These element(s) in combination do not add anything that is not already present when the steps are considered separately. Simply implementing an abstract idea on a computer as a tool to perform an existing process is not indicative of integration into a practical application (See MPEP § 2106.05(f).)
The securely recording and synchronizing step(s) are recited at a high-level of generality (i.e., as generally recording and generally synchronizing) such that they amounts to no more than mere data gathering which is adding insignificant extra-solution activity. These element(s) in combination do not add anything that is not already present when the steps are considered separately. Simply adding insignificant extra-solution activity is not indicative of integration into a practical application (See MPEP § 2106.05(g).)
The use of blockchain, machine learning and real-time processing is implemented at a high level of generality (i.e. as simply using the technologies) such that it amounts to no more than generally linking the use of the judicial exception to a particular technological environment or field of use. These element(s) in combination do not add anything that is not already pre-sent when the steps are considered separately. Generally linking the use of the judicial exception to a particular technological environment or field of use is not indicative of integration into a practical application (See MPEP § 2106.05(h).)
Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
The independent claims are directed to an abstract idea.
Step 2B of the 101 Analysis:
The claims 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 identified in Step 2A Prong 2 (if any) amount to no more than mere instructions to implement the judicial exception on a computer or no more than mere data gathering or data outputting which only adds insignificant extra solution activity to the judicial exception. Accordingly, the Examiner in accordance with MPEP §2106.05(II):
• Carries over their identification of the additional element(s) in the claim from Step 2A Prong Two;
• Carries over their conclusions from Step 2A Prong Two on the considerations discussed in MPEP §§ 2106.05(a) - (c), (e) (f) and (h):
• Re-evaluates any additional element or combination of elements that was considered to be insignificant extra-solution activity per MPEP § 2106.05(g), because if such re-evaluation finds that the element is unconventional or otherwise more than what is well-understood, routine, conventional activity in the field, this finding may indicate that the additional element is no longer considered to be insignificant.
The claim elements which recite additional elements are:
Claim(s) 1, 15 and 20:
“…over a Software as a Service network…”
“…machine-learning…”
“…machine-learning…”
“automatically…”
“…on the blockchain;”
“securely recording on the blockchain an auditable record of terms and commitments associated with one or more of the verified entities;”
“…is recorded on the blockchain and executable to…”
“…real-time…”
“continuously synchronize the data to reflect one or more changes in accordance with the active monitoring;”
“…Software as a Service…by the blockchain;”
“automatically…blockchain…”
“…the blockchain…”
Claim 15:
“a communication interface that communicates over a communication network with a Software as a Service network platform…with a blockchain;”
“a processor that executes instructions stored in memory, wherein the processor executes the instructions to:”
Claim 20:
“A non-transitory computer-readable storage medium having instructions embodied thereon, the instructions executable by a computing system to perform a method of managing entity data using blockchain, the method comprising:”
Examiner incorporates the corresponding rationale provided in Step 2A Prong Two herein by carrying over their conclusions from Step 2A Prong Two on the considerations discussed in MPEP §§ 2106.05(a) – (c), (e), (f) and (h).
These element(s) in combination do not add anything that is not already present when the steps are considered separately. Adding insignificant extra-solution activity cannot provide an inventive concept when the activities are well-understood routine and conventional. The courts have recognized the following computer functions as well-understood, routine, and conventional functions when they are claimed in a merely generic manner:
(for recording and synchronizing various data) Storing and retrieving information in memory, (See MPEP § 2106.05(d)(II)).
The independent claims are not patent eligible.
Dependent Claim(s) 3-14 and 16-19 recite limitations that are similar to the abstract idea noted in the independent claims because they further narrow the independent claim(s) which recite one or more judicial exceptions. Accordingly, these claim elements do not serve to confer subject matter eligibility to the claims since they recite abstract ideas.
Claims 5 and 19 further recite setting up a chat room. The use of a chat room is implemented at a high level of generality (i.e. as simply using the technology) such that it amounts to no more than generally linking the use of the judicial exception to a particular technological environment or field of use. These element(s) in combination do not add anything that is not already pre-sent when the steps are considered separately. Generally linking the use of the judicial exception to a particular technological environment or field of use is not indicative of integration into a practical application (See MPEP § 2106.05(h).)
The claims 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 identified in Step 2A Prong 2 (if any) amount to no more than mere instructions to implement the judicial exception on a computer or no more than mere data gathering or data outputting which only adds insignificant extra solution activity to the judicial exception. Accordingly, the Examiner in accordance with MPEP §2106.05(II):
• Carries over their identification of the additional element(s) in the claim from Step 2A Prong Two;
• Carries over their conclusions from Step 2A Prong Two on the considerations discussed in MPEP §§ 2106.05(a) - (c), (e) (f) and (h):
• Re-evaluates any additional element or combination of elements that was considered to be insignificant extra-solution activity per MPEP § 2106.05(g), because if such re-evaluation finds that the element is unconventional or otherwise more than what is well-understood, routine, conventional activity in the field, this finding may indicate that the additional element is no longer considered to be insignificant.
The claim elements which recite additional elements are:
Claim 5:
“setting up an online chat room for the subset of the entities;”
Claim 19:
“set up a chat room for the subset of the entities;”
Examiner incorporates the corresponding rationale provided in Step 2A Prong Two herein by carrying over their conclusions from Step 2A Prong Two on the considerations discussed in MPEP §§ 2106.05(a) – (c), (e), (f) and (h).
These element(s) in combination do not add anything that is not already present when the steps are considered separately. Adding insignificant extra-solution activity cannot provide an inventive concept when the activities are well-understood routine and conventional. These additional element recite do not recite any insignificant extra-solution activity.
The claims are not patent eligible.
Examiner’s Note
Examiner notes that a search was performed but did NOT result in a combination of prior art that rendered the claims obvious.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Khatib et al. (US 2020/0099530 A1) as the closest prior art of record discloses a deal platform stored on blockchain whereby a machine learning model may aid users in predicting successful deals and managing deals in progress. Khatib discloses acquisition deal workflow that defines various tasks (i.e. key milestones) that must be completed before a next step can be performed in a merger.
Detres et al. (US 2020/0389301 A1) discloses a smart contract may include an escrow service (i.e. a conditional hold on access to tokens until deal conditions specified by the smart contract are determined to have been met) where the tokens are released when at least two of three people agree on release.
Saraniecki et al. (US 2022/0261791 A1) discloses exchange of risk offset tokens from a token asset.
Tietzen et al. (US 2019/0392489 A1) discloses accepting donations and using said donation data to determine which regulations should apply. Tietzen further discloses real and/or near-real time usage information can be received and transmitted.
Molinari et al. (US 2017/0011460 A1) discloses embedding security data in tokens that may be exchanged to remove counter party risk and foster investor protection.
Salisbury (WO 2024081348 A1) discloses tokenizing property assets in order to execute smart contracts and record property transactions.
Nguyen-Hoang et al. (“Advancing Scholarship Management: A Blockchain-Enhanced Platform With Privacy-Secure Identities and AI-Driven Recommendations”) discloses applying blockchain for audit grant distribution.
THIS ACTION IS MADE FINAL. 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 ADAM J HILMANTEL whose telephone number is (571)272-8984. The examiner can normally be reached M-F 8:30AM-5:00PM.
Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Abhishek Vyas can be reached at (571) 270-1836. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/ADAM HILMANTEL/Examiner, Art Unit 3691
