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 office action is in response to Applicant’s response filed July 15, 2026 in which claims 1, 4, 6, 10, 11, 14, 15, 16 and 20 are amended. Thus, claims 1-20 are pending in the application.
Claim Rejections - 35 USC § 101
2. 35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
The Examiner has identified independent system Claim 1 as the claim that represents the claimed invention for analysis and is similar to independent Claim 11.
The claims 1-10 are directed to a system and claims 11-20 are directed to a method which are one of the statutory categories of invention (Step 1: YES).
The claim 1 recites : a first user device associated with a first user; a second user device associated with a second user, at least one blockchain server comprising a distributed blockchain ledger, said distributed blockchain ledger maintained using cryptographic consensus across multiple nodes, wherein the blockchain server is in communication with at least one database, the first user device and the second user device via a network, wherein the blockchain server comprises at least one memory configured to store executable instructions and at least one processor configured to execute the executable instructions to :
receive identification information and ownership information of the vehicle from at least one of the first user device and the second user device, wherein the identification information includes a vehicle make, a vehicle model, a vehicle year information and a vehicle identification number, and wherein the ownership information includes a payment amount for legal title and a legal title term, receive first user information comprising information related to a first digital wallet and second user information comprising information related to a second digital wallet;
generate a smart contract between the first user and the second user, wherein the smart contract comprises terms to manage transaction to transfer ownership of the vehicle, including the payment amount for legal title, the legal title term, and the identification information of the vehicle; generate a machine-readable payment code corresponding to the payment amount and the smart contract; receive, through the machine-readable payment code, authorization to transfer the payment amount from the first digital wallet to the second digital wallet; generate a digital certificate comprising the vehicle identification information on completion of transfer of ownership of the vehicle; create payment data and ownership transfer data comprising the payment amount, the digital certificate, and the smart contract; bundle the payment data and the ownership transfer data into one or more blocks of the distributed blockchain ledger; cause a plurality of computing nodes of a blockchain network to form consensus regarding integration of the one or more blocks into the distributed blockchain ledger; and store identical copies of an updated distributed blockchain ledger at the plurality of computing nodes, thereby creating a tamper-proof and immutable transaction record for the transfer of ownership of the vehicle. These limitations (with the exception of italicized portions), are a process that covers Certain methods of organizing human activity such as a Commercial or legal interaction. Managing a transaction to transfer ownership of vehicles is a commercial or legal interaction. The claim also recites additional elements (as shown above in italics) which do not necessarily restrict the claim from reciting an abstract idea. That is, other than, the recited additional elements (as shown above in italics), nothing in the claim precludes the steps from being performed as a method of organizing human activity. If the claim limitations, under the broadest reasonable interpretation, covers methods of organizing human activity, but for the recitation of generic computer components, then it falls within the “Certain methods of organizing human activity” grouping of abstract ideas. Accordingly, the claim 1 recites an abstract idea (Step 2A: Prong 1: YES).
This judicial exception is not integrated into a practical application. The additional elements of a first user device, a second user device, a first digital wallet and a second digital wallet, blockchain server, a distributed blockchain ledger, a database, a network, a memory configured to store executable instructions, a processor and a smart contract result in no more than simply applying the abstract idea using generic computer elements. The limitations, “cause a plurality of computing nodes of a blockchain network to form consensus regarding integration of the one or more blocks into the distributed blockchain ledger; and store identical copies of an updated distributed blockchain ledger at the plurality of computing nodes” amount to generic computer implementation. The specification describes the additional elements of a first user device, a second user device, a first digital wallet and a second digital wallet, blockchain server, a distributed blockchain ledger, a database, a network, a memory configured to store executable instructions, a processor and a smart contract to be generic computer elements (see [0008], [0010-0014], Fig. 1). Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. The additional elements are recited at a high level of generality and under their broadest reasonable interpretation comprises a generic computer arrangement. The presence of a generic computer arrangement is nothing more than mere instructions to implement the abstract idea on a computer (MPEP 2106.05(f)). Accordingly, these additional elements, when considered separately and as an ordered combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Hence, the claims as a whole are not integrated into a practical application. Therefore, the claim 1 is directed to an abstract idea (Step 2A - Prong 2: NO).
The claim 1 does not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements are recited at a high level of generality in that it results in no more than simply applying the abstract idea using generic computer elements. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements amount to no more than mere instructions to apply the exception using a generic computer component (MPEP 2106.05(f)). The additional elements, when considered separately and as an ordered combination, does not add significantly more (also known as an “inventive concept”) to the exception. The additional elements of the instant underlying process, when taken in combination, together do not amount to significantly more than the sum of the functions of the elements when each is taken alone. Thus, claim 1 is not patent eligible (Step 2B: NO).
Similar arguments can he extended to other independent claim 11 and hence the claim 11 is rejected on similar grounds as claim 1.
The dependent claims have been given the full two-part analysis including analyzing the additional limitations both individually and in combination. Dependent claims 2-10 and 12-20 are held to be patent ineligible under 35 U.S.C. 101 because the additional recited limitations only narrow the abstract idea further and thus correspond to Certain Methods of Organizing Human Activity and hence are abstract for the reasons presented above. Claims 2-10 and 12-20 do not recite any new additional elements that are not present in independent claims 1 and 11.
Viewing the claim limitations as an ordered combination does not add anything further than looking at the claim limitations individually. When viewed either individually, or as a combination, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea. Accordingly, claim(s) 1-20 are ineligible.
No Prior Art Rejections
3. Based on the prior art search results, the prior art of record fails to anticipate or render obvious the claimed subject matter of claims 1-20. While some individual features of claims 1-20 may be shown in the prior art of record, no known reference, alone or in combination, would provide the invention of claims 1-20. The prior art most closely resembling the applicant’s claimed invention are :
1) Ma (US 2022/0335494 A1) – This invention relates generally to managing trustable transaction services based on blockchain technology. The trustable transaction services can include trading services, payment services, financing services, data exchange services, or any other transaction services. These technologies can implement a new trustable transaction (e.g., trading and financing) service system by integrating a number of trustable nodes into a blockchain network to provide trustable transaction services to transaction entities (e.g., trading parties), especially for international order or cross-border transactions. These technologies can create a trustable transaction platform that allow transaction parties, e.g., small and medium-size enterprises (SMEs), which may be unaffiliated and have no or weak trust before, to be able to communicate and conduct business with each other in a reliable and efficient manner. These technologies can bridge the trust gap between the transaction parties and connect them through a transaction platform. The technologies can integrate the transaction platform, financial institutions such as offshore banks and onshore banks, customs offices, logistics providers, and/or any other relevant entities as the network nodes in the blockchain network to create a new ecosystem, for example, for providing trusted digital international or cross-border transactions.
2) Kim (US 2018/0293557 A1) - The present invention relates to a method of charging an electronic currency automatically based on a blockchain and a system thereof, and more particularly, to an automatic charging method devised to solve a problem of low user convenience in providing a service for charging electronic currency automatically based on a blockchain, and a system for performing the same.
3) Love (US 2020/0013048 A1) – The present invention relates to securely conducting a transaction requiring approval via a personal device of a purchaser. In some embodiments, under control of a payment application executing on the personal device of a purchaser, the method establishes secure connection to a payment terminal of a seller. The method receives via the secure connection transaction information generated by a point-of-sale system. The method prompts the purchaser to approve the transaction. Upon approval, the method sends via the secure connection with the payment terminal an indication of the approved transaction to a digital payment guardian system. Under control of the digital payment guardian system, the method adds the approved transaction to a distributed ledger upon receiving the approved transaction. The method settles the approved transaction and provides notification of the settlement to the point-of-sale system so that the point-of-sale system can close the transaction.
Response to Arguments
4. Applicant's arguments filed dated 07/15/2026 have been fully considered but they are not persuasive due to the following reasons:
5. With respect to the rejection of all claims under 35 U.S.C. 101 with regards to Step 2A, Prong 2 (pages 10-12), Applicant argues that, “The amended claims therefore integrate any alleged abstract idea into a practical application”
The Examiner respectfully disagrees. The Examiner would like to point out that according to 2019 Patent Eligibility Guidelines (2019 PEG), limitations that are indicative of integration into a practical application include:
• Improvements to the functioning of a computer, or to any other technology or technical field - see MPEP 2106.05(a)
• Applying or using a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition - see Vanda Memo
• Applying the judicial exception with, or by use of, a particular machine - see MPEP 2106.05(b)
• Effecting a transformation or reduction of a particular article to a different state or thing -see MPEP 2106.05(c)
• Applying or using the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception - see MPEP 2106.05(e) and Vanda Memo
In the instant case, the judicial exception is not integrated into a practical application, because none of the above criteria is met. The amended limitations of the claims do not result in computer functionality improvement or technical/technology improvement when the underlying abstract idea is implemented using technology. The amendments to the claims only further define the data being used however a specific abstract idea is still an abstract idea. All the features in the Applicant’s claims can at best be considered an improvement in the abstract idea. The claim describes what the business/financial transaction does rather than a technical improvement to the functioning of the computer or network itself. Functions like "bundling data into blocks," "forming consensus across nodes," and "storing identical copies to create an immutable record" are the foundational, baseline features inherent to any standard blockchain network.
The advantages over conventional systems are directed towards improving the abstract idea. The specification describes the additional elements of a first user device, a second user device, a first digital wallet and a second digital wallet, blockchain server, a distributed blockchain ledger, a database, a network, a memory configured to store executable instructions, a processor and a smart contract to be generic computer elements (see [0008], [0010-0014], Fig. 1). The limitations, “cause a plurality of computing nodes of a blockchain network to form consensus regarding integration of the one or more blocks into the distributed blockchain ledger; and store identical copies of an updated distributed blockchain ledger at the plurality of computing nodes” amount to generic computer implementation. Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. The additional elements are recited at a high level of generality and under their broadest reasonable interpretation comprises a generic computer arrangement. The presence of a generic computer arrangement is nothing more than mere instructions to implement the abstract idea on a computer (MPEP 2106.05(f)). Accordingly, these additional elements, when considered separately and as an ordered combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Hence, the claims as a whole are not integrated into a practical application.
6. Applicant argues that (page 12), “The amended claims also provide significantly more than the alleged abstract idea”
One of the guidelines issued by the Office to determine if the claims recite additional elements which are not well understood, routine or conventional and hence, amount to significantly more than an abstract idea, is the USPTO guidelines of April 19, 2018 incorporating the Berkheimer memo (Berkheimer memo, hereinafter).
According to the Berkheimer memo,
In a step 2B analysis, an additional element (or combination of elements) is not well understood, routine or conventional unless the examiner finds, and expressly supports a rejection in writing with, one or more of the following:
1. A citation to an express statement in the specification or to a statement made by an applicant during prosecution that demonstrates the well-understood, routine, conventional nature of the additional element(s).
2. A citation to one or more of the court decisions discussed in MPEP § 2106.05(d)(II) as noting the well-understood, routine, conventional nature of the additional element(s).
3. A citation to a publication that demonstrates the well-understood, routine, conventional nature of the additional element(s).
4. A statement that the examiner is taking official notice of the well-understood, routine, conventional nature of the additional elements). This option should
be used only when the examiner is certain, based upon his or her personal knowledge, that the additional elements) represents well-understood, routine, conventional activity engaged in by those in the relevant art, in that the additional elements are widely prevalent or in common use in the relevant field, comparable to the types of activity or elements that are so well-known that they do not need to be described in detail in a patent application to satisfy 35 U.S.C. § 112(a).
The additional elements in the claim are a first user device, a second user device, a first digital wallet and a second digital wallet, blockchain server, a distributed blockchain ledger, a database, a network, a memory configured to store executable instructions, a processor and a smart contract. The limitations, “cause a plurality of computing nodes of a blockchain network to form consensus regarding integration of the one or more blocks into the distributed blockchain ledger; and store identical copies of an updated distributed blockchain ledger at the plurality of computing nodes” amounts to generic computer implementation. As per the rejection above, the specification describes the additional elements to be generic computer elements (see [0008], [0010-0014], Fig. 1). Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. There is no indication in Applicants’ claims that any specialized hardware or other inventive computer components are required. The fact that a general purpose computing system, suitably programmed, may be used to perform the claimed method and the fact that the claims at issue do not require any nonconventional computer, network, or other components, or even a “non-conventional and non-generic arrangement of known, conventional pieces” but merely call for performance of the claimed functions “on a set of generic computer components, satisfies the Berkheimer memo requirement that the additional elements are conventional elements (as outlined in criterion 1 of the Berkheimer memo). The additional elements of the instant underlying process, when taken in combination, together do not amount to substantially more than the sum of the functions of the elements when each is taken alone.
For these reasons and those discussed in the rejection, the rejections under 35 U.S.C. 101 are maintained.
Examiner Request
7. The Applicant is request to indicate where in the specification there is support for amendments to claims should Applicant amend. The purpose of this is to reduce potential 35 U.S.C. §112(a) or §112 1st paragraph issues that can arise when claims are amended without support in the specification. The Examiner thanks the Applicant in advance.
Conclusion
8. Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). 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 extension fee 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 date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to BHAVIN SHAH whose telephone number is (571)272-2981. The examiner can normally be reached on M-F 9AM-6PM.
If attempts to reach the examiner by telephone are unsuccessful, the examiner's supervisor, Bennett Sigmond can be reached on 303-297-4411. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/B.D.S./Examiner, Art Unit 3694
September 14, 2026
/BENNETT M SIGMOND/Supervisory Patent Examiner, Art Unit 3694