DETAILED ACTION
This is a Non-final office action on the merits. The U.S. Patent and Trademark Office (the Office) has received claims 21-40 in application number 19/125,197. Claims 21-40 are pending and have been examined on the merits.
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.
Examiner is using the “step” annotation from the flowchart of MPEP 2106 (III), and MPEP 2106.04 and MPEP 2106.05 for clarity.
Claims 21-40 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Step 1:
Independent Claim 21 and dependent Claims 22-30 recite a method (process) and Independent Claim 31 and dependent Claims 31-40 recite a system including circuitry (machine), thereby falling into one of the four statutory categories of invention.
Step 2A, prong 1:
Applicant recites the following elements in Claim 31: (Claim 31 is used as exemplary but Claim 21 is similar).
A computer system configured for updating accounts in an account database, the computer system having access to the account database and comprising: interface circuitry; and processing circuitry configured to: receive, via the interface circuitry, electronic signaling identifying an account in the account database and indicating a transaction for recordation against the account; and determine whether to record the transaction against the account using a delta logging procedure that does not lock the account against concurrent transactions or a balance updating procedure that locks the account against concurrent transactions, based on at least one of: determining whether the transaction is a candidate for use of the delta logging procedure, based on evaluating one or more attributes of the transaction; or determining whether the account satisfies one or more conditions for use of the delta logging procedure; and responsive to determining to record the transaction using the delta logging procedure, perform the delta logging procedure, which comprises recording a change value against the account in the account database without updating an account balance of the account, for later reconciliation of the account balance.
Examiner has bolded the elements that are part of the abstract idea.
These elements recite an accounting process of obtaining data and recording data into an accounting database or delaying the recording of data into an accounting database based on various rule-based constraints. These elements represent an abstract idea in the category of Certain Methods of Organizing Human Activity in the subcategory of Commercial or Legal interactions because it is a common commercial practice to record data into an accounting database based on various rule-based constraints.
Claim 31 (and similarly Claim 21) thus recite an abstract idea. Dependent Claims 22-30 and 32-40 contain the same abstract idea by virtue of their dependency on Claim 21 or 31, respectively. Accordingly Claims 21-40 recite an abstract idea.
Step 2A, prong 2:
In addition to the abstract idea discussed above, Claim 1 also recites the following additional elements:
Computer system – Applicant describes “computer system” on page 4, lines 10-17, as a general purpose computer with no detailed technical disclosure of any special features or technologies.
Interface circuitry – Applicant describes “interface circuitry” on page 5, lines 3-15, as one of many possible types, technologies and physical forms and does not identify any detailed technical disclosure of any special features or technologies.
Processing circuitry - Applicant describes “processing circuitry” on page 5, lines 16-23 and lines 30-34, as one of many possible types, technologies and physical forms and does not identify any detailed technical disclosure of any special features or technologies.
MPEP 2106.05(f)(2) states “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”.
As discussed, the additional elements Computer system, Interface circuitry and Processing circuitry are broadly claimed and used in their ordinary capacity with no detailed technical disclosure of any special features or technologies and, thus, they do not integrate the abstract idea into a practical application. The claims as a whole do not integrate the abstract idea into a practical application because they do not impose any meaningful limitations on practicing the abstract idea. Claims 21- 40 are therefore directed to an abstract idea.
Step 2B: As discussed above, Applicant claims the abstract idea of an accounting process of obtaining data and recording data into an accounting database or delaying the recording of data into an accounting database based on various rule-based constraints. As discussed above, Applicant also recites the additional elements of: Computer system, Interface circuitry and Processing circuitry.
As discussed above with respect to Step 2A, the claimed Computer system, Interface circuitry and Processing circuitry are hardware recited at a high level of generality and amount to no more than instructions to apply the exception using general purpose computer systems. MPEP 2106.05(f) states that merely adding a general purpose computer or computer components to an abstract idea does not amount to significantly more, thus Computer system, Interface circuitry and Processing circuitry are not significantly more.
The additional elements alone or in combination do not improve the functioning of a computer or any other technology or technological field. The additional elements alone or in combination do not apply the judicial exception to a particular (non-general purpose) machine. The additional elements alone or in combination do not effect a transformation or reduction of a particular article to a different state or thing. Applicant does not claim or teach in their specification any special purpose hardware or improvements thereof. Therefore, the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. Applicant may be “improving” data but Examiner holds that this “improvement” is part of the abstract idea. MPEP 2106.05(II) (citing Trading Technologies) recites: “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”.
Dependent Claims 22-30 and 32-40 contain the same abstract idea by virtue of their dependency on Claim 1 and further limit the abstract idea by further limiting the data and data rules.
Claims 21-40 are not patent eligible.
Claim Rejections - 35 USC § 102
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 (i.e., changing from AIA to pre-AIA ) 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 the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
A person shall be entitled to a patent unless –
(a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention.
Claims 21-40 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by U.S. Patent 8,706,619 (Yu).
Regarding Claims 21 and 31:
Yu teaches a system of updating financial accounts by crediting or debiting an account for a transaction and further teaches using rules to either immediately record a credit or debit against an account to update the account for a certain transaction, or to temporarily hold and not record a credit or debit for a transaction until the account is locked against other credits or debits to the same account. When the account is subsequently locked, the held credits or debits can be recorded against the account to update it. Yu teaches: (New) A method of updating accounts in an account database, the method performed by a computer system having access to the account database and comprising: receiving electronic signaling identifying an account in the account database and indicating a transaction for recordation against the account; ([Column 2, line 33] “computing device 103” and [Column 7, lines 50-52) “data store interface application…receives a transaction to update a value associated with the account, such as an account balance”).
and determining whether to record the transaction against the account using a delta logging procedure that does not lock the account against concurrent transactions or a balance updating procedure that locks the account against concurrent transactions, based on at least one of: determining whether the transaction is a candidate for use of the delta logging procedure, based on evaluating one or more attributes of the transaction; or determining whether the account satisfies one or more conditions for use of the delta logging procedure; ([Column 3, line 30-35] “An account constraint associated with an account is an account rule that the account must follow with regard to a data field associated with the account. Accordingly, transactions posted to the account cannot violate such a constraint or they can be refused”).
and responsive to determining to record the transaction using the delta logging procedure, performing the delta logging procedure, which comprises recording a change value against the account in the account database without updating an account balance of the account, for later reconciliation of the account balance. ([Column 4, lines 57-60] “If the data store 131 in the data store system 105 does not grant access to the data store interface application 125 so that the data field update can be performed, the data store interface application 125 can write the update to the spillover table 135”). Examiner is interpreting Applicant’s “delta logging procedure” as equivalent to Yu’s rules relating to writing to the spillover table or not.
Regarding Claims 22 and 32:
Yu teaches all the elements of Claims 21 and 31. Yu also teaches: (New) The method according to claim 21, further comprising periodically reconciling account balances by, for individual accounts in the account database that have recorded change values, updating each such account by adjusting the account balance to incorporate the recorded change values and correspondingly clearing the recorded change values. ([Column 7, lines 28-29] “attempt an update of the accounts table 133 on a periodic basis”).
Regarding Claims 23, 24, 33 and 34:
Yu teaches all the elements of Claims 21 and 31. Yu also teaches: (New) The method according to claim 21, wherein determining whether the account satisfies the one or more conditions for use of the delta logging procedure comprises determining whether there is at least a threshold distance between the account balance of the account and a defined account limit. (New) The method according to claim 21, wherein determining whether the account satisfies the one or more conditions for use of the delta logging procedure comprises determining whether the credit or debit value of the transaction is less than a defined percentage of the account balance. ([Column 7, lines 47-49] “the account shown in the accounts table 133 includes a constraint that the account balance must be greater than or equal to zero” and [Column 3, lines 42] “transactions larger than a threshold amount” and also see ([Column 4, line4] “concurrency control”). Examiner notes that calculating a difference between a number and an account cap number or calculating a percentage of balance are simple arithmetic and are obvious variants of Yu’s greater than zero or larger than a threshold teachings. Yu teaches limiting the use of a locking requirement or not (i.e. whether a new number is immediately used to update the account balance or is it held and used later to update the account balance) based on calculations that approximate the risk of a particular transaction negatively affecting the balance by delaying processing by processing it in a batch update. Examiner holds that simple arithmetic calculations using attributes of the transaction or the account, such as those claimed by Applicant, would be obvious from Yu’s teachings.
Regarding Claims 25 and 35:
Yu teaches all the elements of Claims 21 and 31. Yu also teaches: (New) The method according to claim 21, wherein determining whether the account satisfies the one or more conditions for use of the delta logging procedure comprises determining whether a current number of recorded change values for the account is below a defined number. ([Column 7, lines 29-32] “The spillover task 143 can also be configured to process a certain number of entries from the spillover table 135 and then release a lock on the accounts table 133 so that the data store 131 can process other transactions”).
Regarding Claims 26 and 36:
Yu teaches all the elements of Claims 21 and 31. Yu also teaches: (New) The method according to claim 21, wherein responsive to determining that the transaction is a candidate for use of the delta logging procedure in conjunction with determining that the account does not satisfy the one or more conditions for use of the delta logging procedure, computing an updated account balance to reflect any recorded change values in the account, along with the change value of the transaction, and updating the account balance to the updated account balance. ([Column 6, lines 47-52] “For these ineligible transactions, the data store interface application 125 can wait until an exclusive lock can be obtained on a data table or data field that a transaction is updating and process the transaction when a lock can be obtained or when a concurrency control mechanism can be complied with”).
Regarding Claims 27 and 37:
Yu teaches all the elements of Claims 21, 26, 31 and 36. Yu also teaches: (New) The method according to claim 26, wherein updating the account balance comprises updating the account balance conditioned on not detecting a concurrent transaction involving the account, and, in response to detecting a concurrent transaction, aborting updating of the account balance and restarting recordation of the transaction against the account. ([Column 4, line4] “concurrency control”)
Regarding Claims 28 and 38:
Yu teaches all the elements of Claims 21 and 31. Yu also teaches: (New) The method according to claim 21, wherein, responsive to determining to record the transaction using the balance updating procedure, the method comprises locking the account against concurrent transactions, performing the balance updating procedure, in which the account balance of the account is updated to reflect the change value of the transaction, and then unlocking the account. ([Column 4, lines 3-7] “Certain data fields or tables within a data store 131 may employ an exclusive lock or other concurrency control mechanism, such as an optimistic lock, etc., in order for updates to a particular piece of data in the data store 131 to be applied” and [Column 7, lines 31-32] “release a lock on the accounts table 133 so that the data store 131 can process other transactions”).
Regarding Claims 29, 30, 39 and 40:
Yu teaches all the elements of Claims 21 and 31. Yu also teaches: (New) The method according to claim 21, wherein determining whether the transaction is a candidate for use of the delta logging procedure comprises determining whether a type of the transaction matches one or more transaction types for which use of the delta logging procedure is disallowed. (New) The method according to claim 21, wherein determining whether the transaction is a candidate for use of the delta logging procedure comprises determining whether the change value of the transaction exceeds a defined amount. ([Column 3, lines 39-41] “an account constraint can provide that for an account balance field, transactions larger than a threshold amount are not allowed, and refuse or roll back such a transaction if attempted”).
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to KIMBERLY S BURSUM whose telephone number is (571)272-8213. The examiner can normally be reached M-F 9:30 AM - 6:30 PM.
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/KIMBERLY S. BURSUM/Examiner, Art Unit 3627
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