Prosecution Insights
Last updated: October 25, 2026
Application No. 19/096,904

VAULTLESS TOKENIZATION

Non-Final OA §103§112
Filed
Apr 01, 2025
Priority
Sep 01, 2022 — continuation of 12/287,902
Examiner
LEE, MICHAEL M
Art Unit
2436
Tech Center
2400 — Computer Networks
Assignee
Capital One Services LLC
OA Round
1 (Non-Final)
84%
Grant Probability
Favorable
1-2
OA Rounds
1y 1m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 84% — above average
84%
Career Allowance Rate
236 granted / 280 resolved
+26.3% vs TC avg
Strong +38% interview lift
Without
With
+37.5%
Interview Lift
resolved cases with interview
Typical timeline
2y 8m
Avg Prosecution
18 currently pending
Career history
306
Total Applications
across all art units

Statute-Specific Performance

§101
9.1%
-30.9% vs TC avg
§103
52.4%
+12.4% vs TC avg
§102
8.2%
-31.8% vs TC avg
§112
20.2%
-19.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 280 resolved cases

Office Action

§103 §112
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 . This is a non-final office action in response to applicant’s response without traverse filed on 08/10/2026 to the Requirement for Restriction/Election mailed 6/10/2026. Claims 1-10 are elected. Claims 1-10 are pending and considered. Priority This application is a Continuation of 17/901,575 filed 09/01/2022 (now US Patent No. 12287902B2). Information Disclosure Statement The information disclosure statement (IDS) submitted on 8/28/2026, have been considered. The submission is in compliance with the provisions of 37 CFR 1.97. Accordingly, initialed and dated copy of Applicant’s IDS form 1449 filed as stated above is attached to the instant Office Action. Claim Objections Claims 4, 7-10 are objected to because of the following informalities: Claim 4 lines 3-4, “the plurality of alphanumeric tables” may read “the plurality of randomly generated alphanumeric tables”. Similarly, claim 7 lines 3-4, lines 6-7; claim 8 lines 3-4, lines 6-7; claim 9 lines 3-4, lines 6-7; claim 10 lines 3-4, lines 6-7. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 2, 4-5, 7-10 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 2 line 3, 4 recites “the corresponding character strings”. There is insufficient antecedent basis for this limitation in the claim. It is not clear what the corresponding character strings is/are referring to. Similarly, claim 4 line 3. Claim 5 line 3 recites “shuffling a randomly determined number of rounds”. It is not clear what the scope of this limitation is. It is not clear what “shuffling” is referring to, i.e., the “shuffling” that generates the third character string, or, the “shuffling” that generates the fourth character string, etc. it is not clear what the object of the “shuffling” is. Claim 6 depends on claim 5, therefore is also rejected for the same reason set forth above. Claim 7 line 7 recites “the initial alphanumeric table”. There is insufficient antecedent basis for this limitation in the claim. Applicant may recite “the initial table”. Claim 7 line 8 recites “the next alphanumeric table”. There is insufficient antecedent basis for this limitation in the claim. Applicant may recite “the next table”. Similarly for claim 9 and claim 10. Claim 8 line 3 recites “the increment values”. There is insufficient antecedent basis for this limitation in the claim. Examiner Notes Examiner cites particular paragraphs, columns and line numbers in the references as applied to the claims below for the convenience of the applicant. Although the specified citations are representative of the teachings in the art and are applied to the specific limitations within the individual claim, other passages and figures may apply as well. It is respectfully requested that, in preparing responses, the applicant fully consider the references in entirety as potentially teaching all or part of the claimed invention, as well as the context of the passage as taught by the prior art or disclosed by the examiner. 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. The factual inquiries set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. Claims 1, 4-5 are rejected under 35 U.S.C. 103 as being unpatentable over Stanley et al (US20200374120A1, hereinafter, “Stanley”), in view of Hatcher et al (US20180062832A1, hereinafter, “Hatcher”). Regarding claim 1, Stanley teaches: A non-transitory computer-readable medium having instructions stored thereon that, when executed by at least one computing device (Stanley, discloses systems and methods for vaultless format-preserving tokenization, see [Abstract]. And [0069] computer readable medium), cause the at least one computing device to perform operations comprising: hashing a first character string of user information to generate a second character string of a fixed length ([0033] In sum, a secure tweak will be understood to include a value that has been generated using a unique set of information that is obtained from the cleartext input (or user-provided input), where this value has been encoded into a byte array, and the byte array has been subsequently encoded using a keyed hashing function (or another equivalent). Examiner further notes, it is well known in the arts that hashing produces hash value of fixed length, i.e., a hash refers to a function that converts an input (or 'message') into a fixed-size string of bytes); generating, for each character in the second character string, [a replacement alphanumeric digit] by sequentially shuffling each character in the second character string through a plurality of randomly generated alphanumeric tables to generate a third character string, wherein the plurality of randomly generated alphanumeric tables are identified [by one or more table indices] ([0028] the table encoding module 108 can shuffle contents of the unique lookup table using output of a random number generator… the table encoding module 108 can shuffle contents of the unique lookup table each time it is used or for each round of transposition used. In some embodiments, the shuffling of the lookup table can include shifting or mixing of transposition characters in the lookup table. And [0038] Any alphabet or other set of characters can be incorporated into a lookup table and shuffled to encode a specific data element. Examiner notes, Stanley teaches the input can be any input data, and alphabet or other set of characters of lookup table suggests the input and encoded tweak input may be alphanumeric values. Stanley also suggests the lookup tables may be randomly generated, see e.g. [0015]); (See Hatcher below for teachings of limitations in brackets above) While Stanley teaches the main concept of the claimed invention, but does not specifically teach using table index, in the same field of endeavor Hatcher teaches: a replacement alphanumeric digit; by one or more table indices (Hatcher, discloses method of vaultless tokenization with lookup tables, see [Abstract]. Referring to Fig. 2, and [0037] In step 116a-116d the security provider traverses each character in the input value 97 according to format configurations provided by the customer 32 on the token definition 44. And [0041] In step 116c, one or more replacement tables (i.e., lookup tables) are selected from a pool of tables. In this embodiment, the decision for selecting the one or more replacement tables is based on the input value 97, the index, the value of the single character (i.e., character value) at the index, and the derived key 98); Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have employed the teachings of Hatcher in the vaultless systems and methods of Stanley by using table index to select lookup tables. This would have been obvious because the person having ordinary skill in the art would have been motivated to select replacement tables based on input value to generate vaultless tokens based on the received input value (Hatcher, [Abstract]). The combination of Stanley and Hatcher further teaches: generating, for each character in the third character string, a replacement numeric digit by sequentially shuffling each character through a plurality of randomly generated numeric tables to generate a fourth character string, wherein the plurality of randomly generated numeric tables are identified by the one or more table indices (See above of Stanley and Hatcher, the generating the third character string can be similarly applied to the generating of the fourth character string); Stanley further teaches: encrypting the fourth character string ([Abstract] and a unique encryption key to generate ciphertext output; and generating a token from the ciphertext output. See also [0040]); The combination of Stanley and Hatcher further teaches: and generating an alphanumeric token of the user information by replacing each digit of the encrypted fourth character string by sequentially shuffling each character of the encrypted fourth character string through the plurality of randomly generated alphanumeric tables, wherein the plurality of randomly generated alphanumeric tables are identified by the one or more table indices (Stanley, [Abstract] and a unique encryption key to generate ciphertext output; and generating a token from the ciphertext output. And see above of Stanley and Hatcher, the generating the fourth character string can be similarly applied to the generating of the alphanumeric token). Regarding claim 4, Stanley-Hatcher combination teaches the non-transitory computer-readable medium of claim 1, Stanley further teaches: the operations further comprising: shuffling each of the corresponding characters through a different alphanumeric table of the plurality of alphanumeric tables as identified by a corresponding one of the one or more table indices (e.g. [0028] the table encoding module 108 can shuffle contents of the unique lookup table each time it is used or for each round of transposition used. In some embodiments, the shuffling of the lookup table can include shifting or mixing of transposition characters in the lookup table. For example, if the lookup table included transposition characters [7,8,6,5,4] which correspond to [1,2,3,4,5]. In this example, when a digit or character of cleartext input equals 1, it is replaced with 7. The lookup table can be shuffled [8,6,7,4,5] such that when a digit or character of cleartext input equals 1, it is replaced with 8). Regarding claim 5, Stanley-Hatcher combination teaches the non-transitory computer-readable medium of claim 1, Stanley further teaches: the operations further comprising: shuffling a randomly determined number of rounds ([0015] Some embodiments of the present disclosure enable randomized or dynamically generated look-up tables depending on the required use case. And [0028] it will be understood that any number of rounds of lookup table transformation can be used). Claims 2-3 are rejected under 35 U.S.C. 103 as being unpatentable over Stanley-Hatcher as applied above to claim 1, further in view of Iyer et al (US20190207754A1, hereinafter, “Iyer”). Regarding claim 2, Stanley-Hatcher combination teaches the non-transitory computer-readable medium of claim 1, The combination of Stanley and Hatcher does not specifically teach, in the same field of endeavor Iyer teaches: the operations further comprising: modifying a format of any of the corresponding character strings by sequentially shuffling each of the characters of the corresponding character strings through an additional group of randomly generated tables of a desired output format (Iyer, discloses system and method for securing data using vaultless tokenization and encryption, [Abstract]. And [0058] Tokenization formats may be created through the administration interface 108 by the internal users 4 or may be determined by the third party users through the third party access systems 104. The formats are segmented as per the type and split length, which may be determined by the third party and/or the entity, or sub thereof, which is requesting the tokenization of the data. The segment types can be numeric, alphabetic, or alphanumeric. The split length includes the number of characters for which each segment needs to be parsed and replaced by the random tokens). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have employed the teachings of Iyer in the vaultless systems and methods of Stanley-Hatcher by creating tokenization format per type and split length. This would have been obvious because the person having ordinary skill in the art would have been motivated to tokenize sensitive data for secure transfer and storage (Iyer, [Abstract]). Regarding claim 3, Stanley-Hatcher-Iyer combination teaches the non-transitory computer-readable medium of claim 2, Iyer further teaches: wherein the desired output format comprises any of: numeric, alphanumeric, alphabetic, or non-ASCII characters ([0058] The formats are segmented as per the type and split length, which may be determined by the third party and/or the entity, or sub thereof, which is requesting the tokenization of the data. The segment types can be numeric, alphabetic, or alphanumeric). Claim 6 is rejected under 35 U.S.C. 103 as being unpatentable over Stanley-Hatcher as applied above to claim 5, further in view of Golan et al (US20230214511A1, hereinafter, “Golan”). Regarding claim 6, Stanley-Hatcher combination teaches the non-transitory computer-readable medium of claim 5, the operations further comprising: modifying the one or more table indices after each of the rounds (Golan, discloses methods for database management, [Abstract]. And [0072] As another example, the indices of a table of the database may have been modified, such that other tables relying on the unmodified, original indices are unable to be used, such that the database is rendered unusable). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have employed the teachings of Golan in the vaultless systems and methods of Stanley-Hatcher by modifying indices of table of database. This would have been obvious because the person having ordinary skill in the art would have been motivated to providing a privacy compliance notification in database management (Golan, [Abstract]). Allowable Subject Matter Claims 7-10 are objected to as being dependent upon a rejected base claim(s), but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims as well as resolving of any outstanding informalities and concerns under 35 USC 112(b) presented in this office action. The following is a statement of reasons for the indication of allowable subject matter: Claim 7 depends on claim 1, further recites, “identifying, by the one or more table indices, an initial table of the plurality of alphanumeric tables for initiating shuffling of each character in the second character string through the plurality of randomly generated alphanumeric tables; and generating an increment value to determine a next table of the plurality of alphanumeric tables different from the initial alphanumeric table for shuffling a next character in the second character string through the next alphanumeric table”. Claim 8 depends on claim 7 which depends on claim 1, further recites, “generating the increment values from one or more pre-configured secrets”. Claim 9 depends on claim 1, further recites, “identifying, by the one or more table indices, an initial table, of the plurality of numeric tables, for initiating shuffling of each character in the third character string through the plurality of randomly generated numeric tables; and generating an increment value to determine a next table of the plurality of numeric tables different from the initial numeric table for shuffling a next character in the third character string through the next numeric table”. Claim 10 depends on claim 1, further recites, “identifying, by the one or more table indices, an initial table, of the plurality of alphanumeric tables, for initiating shuffling of each character in the encrypted fourth character string through the plurality of randomly generated alphanumeric tables; and generating an increment value to determine a next table of the plurality of alphanumeric tables different from the initial alphanumeric table for shuffling a next character in the second character string through the next alphanumeric table”. The prior arts identified, either singularly or in combination fails to anticipate or render obvious the claimed limitations of claims shown above. Citation of References The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. The following references are cited but not been replied upon for this office action: Barnett (US20200366656A1) discloses system and method for vaultless tokenization and encryption. Bush et al (US20210390884A1) discloses methods for shifting substitution cipher based efficient vaultless data tokenization. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to MICHAEL M LEE whose telephone number is (571)272-1975. The examiner can normally be reached on M-F: 8:30AM - 5:30PM. 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, Shewaye Gelagay can be reached on (571) 272-4219. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /MICHAEL M LEE/Primary Examiner, Art Unit 2436
Read full office action

Prosecution Timeline

Apr 01, 2025
Application Filed
Sep 29, 2026
Non-Final Rejection mailed — §103, §112 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12750399
METHOD AND SYSTEM FOR DETECTION OF ENCRYPTED DISTRIBUTED DENIAL OF SERVICE (DDoS) ATTACKS
2y 9m to grant Granted Sep 29, 2026
Patent 12750342
Conditional Filtering For Time-Deterministic Firewall
2y 2m to grant Granted Sep 29, 2026
Patent 12744762
PROTOCOL OBFUSCATION IN MOVING TARGET DEFENSE
2y 9m to grant Granted Sep 22, 2026
Patent 12744793
CYBERSECURITY COMPONENTS COMMUNICATING AND COOPERATING WITH ONE OR MORE LARGE LANGUAGE MODELS
2y 3m to grant Granted Sep 22, 2026
Patent 12744808
SECURITY ASSESSMENT METHOD AND APPARATUS, ELECTRONIC DEVICE, AND READABLE STORAGE MEDIUM
2y 0m to grant Granted Sep 22, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

Strategy Recommendation AI-generated — please review before filing

Get a prosecution strategy drawn from examiner precedents, rejection analysis, and claim mapping.
Typically takes 5-10 seconds — AI-generated, attorney review required before filing

Prosecution Projections

1-2
Expected OA Rounds
84%
Grant Probability
99%
With Interview (+37.5%)
2y 8m (~1y 1m remaining)
Median Time to Grant
Low
PTA Risk
Based on 280 resolved cases by this examiner. Grant probability derived from career allowance rate.

Sign in with your work email

Enter your email to receive a magic link. No password needed.

Personal email addresses (Gmail, Yahoo, etc.) are not accepted.

Free tier: 3 strategy analyses per month