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 communication is a First Office Action Non-Final on Merits.
Claims 1-20 have been cancelled in preliminary amendment filed on 9/22/2025.
Therefore, Claims 21-40 are currently pending and have been considered below.
Information Disclosure Statement
The information disclosure statements (IDS) submitted on 09/22/2025 and 05/21/2026 are in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statements are being considered by the examiner.
Priority
The present application, filed on 09/22/2025, claims priority to PCT/SE2023/050264, filed on 03/23/2023.
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 21-40 are rejected under 35 U.S.C. § 101 because the claimed invention is directed to a judicial exception without a practical application and significantly more.
Step 1: Identifying Statutory Categories
When considering subject matter eligibility under 35 U.S.C. § 101, it must be determined whether the claims are directed to one of the four statutory categories of invention, i.e., process, machine, manufacture, or composition of matter (i.e., Step 1). In the instant case, claims 21-29 are directed to a method (i.e. a process). Claims 30-38 are directed to a computing device (i.e. a machine). Claim 39 is directed to a billing dispute resolution system. Claim 40 is directed to a non-transitory computer-readable medium (i.e. an article of manufacture). Thus, each of these claims fall within one of the four statutory categories. Nevertheless, the claims fall within the judicial exception of an abstract idea.
Step 2A: Prong One: Abstract Ideas
Claims 21-40 are rejected under 35 U.S.C. 101 because the claimed invention recites an abstract idea. Independent claim 21, analogous to independent claims 30, 39 and 40 recite: A method for dispute resolution in billing information generated for communication services, the method comprising: receiving a request message for a credit amount to be refunded to a customer account, said request message comprising the billing information related to a customer; determining whether or not to refund the credit amount to the customer account based on an evaluation of the billing information; and in response to the determination, selectively initiating credit refund to the customer account, altering the billing information, or denying the request message. The limitations as drafted, is a process that, under its broadest reasonable interpretation, falls under the abstract groupings of: Certain methods of organizing human activity (commercial or legal interactions (including advertising, marketing or sales activities or behaviors; business relations; (managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions). As the claims discuss dispute resolution in billing information, including billing information related to a customer; determining whether or not to refund the credit amount to the customer account based on an evaluation of the billing information; and in response to the determination, selectively initiating credit refund to the customer account, altering the billing information, or denying the request message, which is a clear business relations, and one of certain methods of organizing human activity. Mental Processes (concepts performed in the human mind (including an observation, evaluation, judgement, opinion (independent claim 21 recites for example, “receiving a request message for a credit amount to be refunded to a customer account, said request message comprising the billing information related to a customer”; “determining whether or not to refund the credit amount to the customer account based on an evaluation of the billing information”; “in response to the determination, selectively initiating credit refund to the customer account, altering the billing information, or denying the request message.”) Concepts performed in the human mind as mental processes because the steps of receiving, determining, responding and analyzing data, mimic human thought processes of observation, evaluation, judgement and opinion, perhaps with paper and pencil, where data interpretation is perceptible in the human mind. See In re TLI Commc’ns LLCPatentLitig., 823 F.3d 607, 611 (Fed. Cir. 2016); FairWarning IP, LLC v. Iatric Sys., Inc., 839 F.3d 1089, 1093-94 (Fed. Cir. 2016)).
Further, dependent claims add additional limitations, for example: (claims 22 and 31) determining whether or not to refund the credit amount to the customer account based on the evaluation of the billing information comprises obtaining the billing information; obtaining historical data of the customer comprising billing information of the customer for a pre-determined time interval; comparing the billing information with the historical data of the customer to detect whether there exists any anomaly in the billing information; responsive to the anomaly being detected in the billing information, calculating a credit range of the billing information based on one or more statistical parameters derived from the historical data; identifying whether the requested credit amount is within the credit range when the anomaly is detected; and responsive to identifying that the requested credit amount is within the credit range, determining to refund the credit amount to the customer account; (claims 23 and 32) responsive to identifying that the anomaly is not detected in the billing information or the requested credit amount is not within the credit range of the billing information, determining to alter the billing information or to deny the request message; (claims 24 and 33) wherein the step of evaluating the billing information by comparing with the historical data of the customer to detect whether there exists any anomaly in the billing information comprises: obtaining the billing information; obtaining the historical data of the customer for a pre-determined time interval; determining one or more statistical parameters from the historical data; and comparing the billing information with the one or more statistical parameters to detect whether there exists any anomaly in the billing information; (claims 25 and 34) wherein the step of evaluating the billing information by comparing with the historical data of the customer to detect whether there exists any anomaly in the billing information comprises: obtaining billing information details and identifying a billing cycle corresponding to the request; obtaining historical billing information corresponding to one or more billing cycles preceding the identified billing cycle of the customer account; and comparing the billing information corresponding to the identified billing cycle with the historical billing information to detect whether there exists any anomaly in the billing information; (claims 26 and 35) wherein the step of calculating the credit range based on analysis of the one or more statistical parameters derived from the historical data comprises: obtaining a pre-defined tolerance for the billing information; extracting one or more credit range rules pre-defined for determining the credit range; evaluating a credit amount in the billing information, the one or more statistical parameters derived for the historical billing information, and the pre-defined tolerance credit in accordance with the one or more credit range rules; and determining the credit range based on the evaluation; (claims 27 and 36) wherein the step of initiating the credit refund to the customer account comprises: refunding the requested credit amount to the customer account, responsive to determining to refund the credit amount to the customer account; (claims 28 and 37) wherein the step of initiating to alter the billing information or to deny the request message comprises: performing one or more of: communicating the calculated credit range of the billing information to the customer, altering the billing information and redirecting the request message for manual resolution, responsive to determining that the requested credit amount is not within the credit range and the anomaly is detected in the billing information; (claims 29 and 38) denying the request message and redirecting the request message for manual resolution, responsive to determining that the anomaly is not detected in the billing information, but these only serve to further limit the abstract idea. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation of certain methods of organizing human activity and mental processes, but for the recitation of generic computing components, the claims recite an abstract idea.
Step 2A: Prong Two
This judicial exception is not integrated into a practical application because the claims merely describe how to generally “apply” the abstract idea. In particular, the claims only recite the additional elements – (claim 21) computing device (claim 30) processing circuitry; memory; (claim 40) non-transitory computer-readable medium. These additional elements are recited at a high-level of generality such that it amounts to no more than mere instructions to apply the exception using generic computer components. Simply implementing the abstract idea on generic computer components is not a practical application of the abstract idea, as it adds the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea, as discussed in MPEP 2106.05(f). The limitations generally link the abstract idea to a particular technological environment or field of use (such as computing, see MPEP 2106.05(h)). Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. Their collective functions merely provide generic computer implementation and do not impose a meaningful limit to integrate the abstract idea into a practical application.
Step 2B:
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 discussion of integration of the abstract idea into a practical application, the additional elements amount to no more than mere instructions to apply an exception and generally link the abstract idea to a particular technological environment or field of use. Furthermore, claims 21-40 have been fully analyzed to determine whether there are additional elements recited that amount to significantly more than the abstract idea. The limitations fail to include an improvement to another technology or technical field, an improvement to the functioning of the computer itself, or meaningful limitations beyond generally linking the use of the abstract idea to a particular technological environment. Thus, nothing in the claim adds significantly more to the abstract idea. Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. Their collective functions merely provide conventional computer implementation. The claims are ineligible. Therefore, since there are no limitations in the claim that transform the exception into a patent eligible application such that the claim amounts to significantly more than the exception itself, the claims are rejected under 35 USC 101 as being directed to non-statutory subject matter.
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 non-obviousness.
Claims 21-40 are rejected under 35 U.S.C. 103 as being unpatentable over KATZ (WO 2014/047585 A2), hereinafter “Katz”, over MENEZES et al. (US 2013/0268419 A1), hereinafter “Menezes”.
Regarding Claim 21, Katz teaches A method for dispute resolution in ... generated for communication services, the method being performed by a computing device, the method comprising: (See at least Katz, Abstract, teaches dispute resolution);
receiving a request message for a credit amount to be refunded to a customer account, said request message comprising the ... related to a customer; (Katz, para 0002, the invention provides a method and system for allowing card issuers or other electronic payment providers to issue credits to cardholders for disputed credit card transactions);
determining whether or not to refund the credit amount to the customer account based on an evaluation of the ...; and (Katz, para 0083, determining whether to refund the transaction);
in response to the determination, selectively initiating credit refund to the customer account, altering the ..., or denying the request message (See at least Katz, para 0044, a refund may be issued to the cardholder.) While Katz teaches billing descriptors, Katz does not appear to explicitly teach and in the same field of endeavor Menezes teaches billing information (Menezes teaches billing information throughout, see at least Menezes, Abstract, teaches billing information associated with an account of a customer). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine Katz with billing information as taught by Menezes with the motivation to create a final bill for the account based on the current billing information and the corrected one or more inaccuracies (Menezes, Abstract). The Katz invention now incorporating the Menezes invention, has all the limitations of claim 21.
Regarding Claim 22, Katz, now incorporating Menezes, teaches The method of claim 21, wherein the step of determining whether or not to refund the credit amount to the customer account based on the evaluation of the billing information comprises obtaining the billing information; (See at least Katz, Abstract; Further, Menezes teaches billing information throughout, see at least Menezes, Abstract, teaches billing information associated with an account of a customer);
obtaining historical data of the customer comprising billing information of the customer for a pre-determined time interval; (Katz, para 0037, screens disputes for ineligible transactions based on the predetermined transaction-level eligibility requirements such as whether the transaction was previously refunded or refunded by the merchant and/or the dispute resolution system (Examiner notes historical data), whether the transaction has a Central Processing Date (CPO) greater than a predetermined interval, such as 120 days).
comparing the billing information with the historical data of the customer to detect whether there exists any anomaly in the billing information; (Katz, para 0036, comparing the disputed transaction details extracted by the Issuer from interchange data against a table of identifiers for participating merchants provided by the Dispute Resolution System);
responsive to the anomaly being detected in the billing information, calculating a credit range of the billing information based on one or more statistical parameters derived from the historical data; (Katz, para 0059, compare the transaction data to predetermined eligibility criteria for transaction credit, and if the credit criteria is met, transmitting a credit instruction for the transaction; Katz, para 0045, teaches the 120 day maximum interval (Examiner notes range) from the transaction to the date of the dispute resolution system is offered as an example, and this interval may be adjusted);
identifying whether the requested credit amount is within the credit range when the anomaly is detected; and (Katz, para 0060, comparing the transaction data to predetermined eligibility criteria for transaction credit, and if the credit criteria is met);
responsive to identifying that the requested credit amount is within the credit range, determining to refund the credit amount to the customer account (Katz, para 0059, compare the transaction data to predetermined eligibility criteria for transaction credit, and if the credit criteria is met, transmitting a credit instruction for the transaction).
Regarding Claim 23, Katz, now incorporating Menezes, teaches The method of claim 22, further comprising: responsive to identifying that the anomaly is not detected in the billing information or the requested credit amount is not within the credit range of the billing information, determining to alter the billing information or to deny the request message (See at least Katz, para 0002, decline such credit requests when the transaction parameters are not satisfied.)
Regarding Claim 24, Katz, now incorporating Menezes, teaches The method of claim 22, wherein the step of evaluating the billing information by comparing with the historical data of the customer to detect whether there exists any anomaly in the billing information comprises: (Katz, para 0059, compare the transaction data to predetermined eligibility criteria for transaction credit, and if the credit criteria is met, transmitting a credit instruction for the transaction);
obtaining the billing information; (Katz teaches billing descriptors; Further, Menezes teaches billing information throughout, see at least Menezes, Abstract, teaches billing information);
obtaining the historical data of the customer for a pre-determined time interval; (Katz, para 0037, screens disputes for ineligible transactions based on the predetermined transaction-level eligibility requirements such as whether the transaction was previously refunded or refunded by the merchant and/or the dispute resolution system (Examiner notes historical data), whether the transaction has a Central Processing Date (CPO) greater than a predetermined interval, such as 120 days);
determining one or more statistical parameters from the historical data; and (Katz, para 0036, comparing the disputed transaction details extracted by the Issuer from interchange data against a table of identifiers for participating merchants provided by the Dispute Resolution System);
comparing the billing information with the one or more statistical parameters to detect whether there exists any anomaly in the billing information (Katz, para 0059, compare the transaction data to predetermined eligibility criteria for transaction credit, and if the credit criteria is met, transmitting a credit instruction for the transaction).
Regarding Claim 25, Katz, now incorporating Menezes, teaches The method of claim 22, wherein the step of evaluating the billing information by comparing with the historical data of the customer to detect whether there exists any anomaly in the billing information comprises: (Katz, para 0059, compare the transaction data to predetermined eligibility criteria for transaction credit, and if the credit criteria is met, transmitting a credit instruction for the transaction); obtaining billing information details and identifying a billing cycle corresponding to the request; (See at least Katz, para 0037, teaches a predetermined maximum interval, such as 120 days from the date of the dispute resolution system dispute request, may also be used to determine eligibility. As may be understood by persons of ordinary skill in the art, the 120 day maximum interval from the date of the transaction to the date of the dispute resolution system dispute request is offered only as an example, and this interval may be adjusted);
obtaining historical billing information corresponding to one or more billing cycles preceding the identified billing cycle of the customer account; and (Katz, para 0037, screens disputes for ineligible transactions based on the predetermined transaction-level eligibility requirements such as whether the transaction was previously refunded or refunded by the merchant and/or the dispute resolution system (Examiner notes historical data), whether the transaction has a Central Processing Date (CPO) greater than a predetermined interval, such as 120 days);
comparing the billing information corresponding to the identified billing cycle with the historical billing information to detect whether there exists any anomaly in the billing information (Katz, para 0059, compare the transaction data to predetermined eligibility criteria for transaction credit, and if the credit criteria is met, transmitting a credit instruction for the transaction).
Regarding Claim 26, Katz, now incorporating Menezes, teaches The method of claim 22, wherein the step of calculating the credit range based on analysis of the one or more statistical parameters derived from the historical data comprises: (See at least Katz, para 0045, teaches the 120 day maximum interval (Examiner notes range) from the transaction to the date of the dispute resolution system, this interval may be adjusted);
obtaining a pre-defined tolerance for the billing information; (See at least Katz, para 0002, teaches transaction parameters (Examiner notes parameters are tolerance));
extracting one or more credit range rules pre-defined for determining the credit range; (See at least Katz, para 0002, if appropriate transaction parameters are satisfied, and to decline such credit requests when the transaction parameters are not satisfied; Further, see para 0081-0082 teaches parameters; Further, Menezes teaches rules throughout, see at least Menezes, Abstract, billing information due to an improperly applied set of rules);
evaluating a credit amount in the billing information, the one or more statistical parameters derived for the historical billing information, and the pre-defined tolerance credit in accordance with the one or more credit range rules; and determining the credit range based on the evaluation (See at least Katz, claim 16, teaches determine whether to refund or cancel the transaction based at least in part on the further information, in response to predetermined eligibility criteria being met.)
Regarding Claim 27, Katz, now incorporating Menezes, teaches The method of claim 22, wherein the step of initiating the credit refund to the customer account comprises: refunding the requested credit amount to the customer account, responsive to determining to refund the credit amount to the customer account (Katz, para 0012, The dispute resolution system determines if the transaction qualifies for resolution under the system and, if so, directs the issuance of the credit to the cardholder for the transaction).
Regarding Claim 28, Katz, now incorporating Menezes, teaches The method of claim 22, wherein the step of initiating to alter the billing information or to deny the request message comprises: performing one or more of: communicating the calculated credit range of the billing information to the customer, altering the billing information and redirecting the request message for manual resolution, responsive to determining that the requested credit amount is not within the credit range and the anomaly is detected in the billing information (See at least Katz, para 0045, teaches the 120 day maximum interval (Examiner notes range) from the transaction to the date of the dispute resolution system, this interval may be adjusted); Katz, para 0031, teaches communicates with the merchant ...provide the network entity with the data/results related to the processing performed to resolve the dispute or inquiry; Katz, para 0046, teaches forwarded for manual review).
Regarding Claim 29, Katz, now incorporating Menezes, teaches The method of claim 28, further comprising: denying the request message and redirecting the request message for manual resolution, responsive to determining that the anomaly is not detected in the billing information (See at least Katz, para 0046, disputes which return "no match" with the qualifying merchant identification descriptors in the table or which were not originally processed through the dispute resolution system are tagged as "unmatched" and at step 66 are forwarded for manual review).
Regarding Claims 30, 39 and 40, the claims are an obvious variant to claim 21 above, and are therefore rejected on the same premise. Claim 30 recites: “A computing device for performing dispute resolution in billing information generated for communication services, the computing device comprising processing circuitry and memory operatively coupled to the processing circuitry, the processing circuitry comprising computer program instructions”. See at least Katz, Abstract and para 0088-0089, discusses the computing environment including processor, memory and instructions for executing functions. Claim 39 recites: “A billing dispute resolution system for dispute resolution in billing information generated for communication services”. See at least Katz, para 0002, teaches the invention generally relates to a method and system for providing dispute resolution. Claim 40 recites: “A non-transitory computer-readable medium, having thereon a computer program comprising program instructions”. See at least Katz, claim 22, teaches A computer program product comprising, comprising: a non-transitory computer readable medium comprising code for causing a computer.
Regarding Claim 31, the claim recites analogous limitations to claim 22 above, and is therefore rejected on the same premise.
Regarding Claim 32, the claim recites analogous limitations to claim 23 above, and is therefore rejected on the same premise.
Regarding Claim 33, the claim recites analogous limitations to claim 24 above, and is therefore rejected on the same premise.
Regarding Claim 34, the claim recites analogous limitations to claim 25 above, and is therefore rejected on the same premise.
Regarding Claim 35, the claim recites analogous limitations to claim 26 above, and is therefore rejected on the same premise.
Regarding Claim 36, the claim recites analogous limitations to claim 27 above, and is therefore rejected on the same premise.
Regarding Claim 37, the claim recites analogous limitations to claim 28 above, and is therefore rejected on the same premise.
Regarding Claim 38, the claim recites analogous limitations to claim 29 above, and is therefore rejected on the same premise.
Additional Prior Art Consulted
The prior art made of record and not relied upon which is considered pertinent to applicant’s disclosure includes the following:
Clark US 2005/0243985 - "Method and system for presenting billing information according to a customer-defined hierarchal structure"; “A computer readable medium storing a computer program that displays billing information to a customer, the computer readable medium comprising”; "processing the billing information in accordance with the customer-defined format stored in a database, sending the processed billing information to an outputting operation where a bill is generated in accordance with the hierarchy".
Rothfarb US 2003/0187788 A1 - "processing an order for said product or service and billing for said order using said partial billing information stored in said one of said plurality of consumer records, and said key"; “a seller engaging the telemarketer to perform telemarketing on its behalf may choose to provide the billing information, with the billing information being inaccessible (e.g., encrypted) absent the provision of the key by the consumer"; “storing a plurality of consumer records, each of which includes consumer identification information and partial billing information”.
Scherer et al. US 2008/0077541 – systems and methods for using billing information to dynamically route vehicles
Smirnoff US 2003/0093373 A1 - "arranging for printed invoice-based billing information to be generated via the customer device"; "arranging for statement-based billing information to be provided via the customer device”; "storing the customer notation information in association with the invoice-based billing information."
NPL – Laurie Butgereit, “An Architecture for a Smart Fourth Party in an Online Dispute Resolution Platform” - Disputes involve two different people or parties. Because of cost or time constraints, the two parties may wish to avoid a lengthy court case and, instead, involve a mediator or arbitrator to help them resolve the dispute. This mediator or arbitrator is often called the third party with the two original participants being called the first and second parties. As this mediation or arbitration process becomes an online process (as in the case of Online Depute Resolution - ODR), the platform used for the ODR has been called the Fourth Party. This paper looks at a technology architecture for creating such a Fourth Party. This paper looks at different types of Alternate Dispute Resolution systems. The paper then progresses to ODR systems. Different facilities of various ODR systems are itemised and a few examples of ODR systems which have already been used or developed are described. A brief discussion of a pilot program is provided including comments about the data which was collected during this pilot. Finally, a proposed IT architecture is provided for an ODR system including a fully fledged Fourth Party as defined by Katsh and Rifkin – including algorithmic support; Published in: 2022 3rd International Conference on Next Generation Computing Applications (NextComp); Date of Conference: 06-08 October 2022, https://ieeexplore.ieee.org/document/9932177
Applicant is advised to review additional references supplied on the PTO-892 as to the state of the art of the invention.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to REBECCA R NOVAK whose telephone number is (571)272-2524. The examiner can normally be reached Monday - Friday 8:30am - 5:00pm EST.
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/R.R.N./Examiner, Art Unit 3629/LYNDA JASMIN/Supervisory Patent Examiner, Art Unit 3629
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