Prosecution Insights
Last updated: July 05, 2026
Application No. 19/192,658

LAUNDERING DETECTION IN SECOND LAYER NETWORKS

Non-Final OA §101
Filed
Apr 29, 2025
Priority
Dec 27, 2021 — continuation of 12/307,454
Examiner
ZHOU, YINGYING
Art Unit
3697
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
PayPal Inc.
OA Round
1 (Non-Final)
46%
Grant Probability
Moderate
1-2
OA Rounds
2y 8m
Est. Remaining
94%
With Interview

Examiner Intelligence

Grants 46% of resolved cases
46%
Career Allowance Rate
83 granted / 180 resolved
-5.9% vs TC avg
Strong +48% interview lift
Without
With
+48.4%
Interview Lift
resolved cases with interview
Typical timeline
3y 10m
Avg Prosecution
20 currently pending
Career history
209
Total Applications
across all art units

Statute-Specific Performance

§101
8.5%
-31.5% vs TC avg
§103
80.3%
+40.3% vs TC avg
§102
3.4%
-36.6% vs TC avg
§112
6.2%
-33.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 180 resolved cases

Office Action

§101
DETAILED ACTION Acknowledgements The amendment filed on 8/06/2025 is acknowledged. Claims 2-21 are pending. Claims 2-21 have been examined. 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 . Double Patenting The nonstatutory double patenting rejection is based on a judicially created doctrine grounded in public policy (a policy reflected in the statute) so as to prevent the unjustified or improper timewise extension of the “right to exclude” granted by a patent and to prevent possible harassment by multiple assignees. A nonstatutory double patenting rejection is appropriate where the conflicting claims are not identical, but at least one examined application claim is not patentably distinct from the reference claim(s) because the examined application claim is either anticipated by, or would have been obvious over, the reference claim(s). See, e.g., In re Berg, 140 F.3d 1428, 46 USPQ2d 1226 (Fed. Cir. 1998); In re Goodman, 11 F.3d 1046, 29 USPQ2d 2010 (Fed. Cir. 1993); In re Longi, 759 F.2d 887, 225 USPQ 645 (Fed. Cir. 1985); In re Van Ornum, 686 F.2d 937, 214 USPQ 761 (CCPA 1982); In re Vogel, 422 F.2d 438, 164 USPQ 619 (CCPA 1970); In re Thorington, 418 F.2d 528, 163 USPQ 644 (CCPA 1969). A timely filed terminal disclaimer in compliance with 37 CFR 1.321(c) or 1.321(d) may be used to overcome an actual or provisional rejection based on nonstatutory double patenting provided the reference application or patent either is shown to be commonly owned with the examined application, or claims an invention made as a result of activities undertaken within the scope of a joint research agreement. See MPEP § 717.02 for applications subject to examination under the first inventor to file provisions of the AIA as explained in MPEP § 2159. See MPEP §§ 706.02(l)(1) - 706.02(l)(3) for applications not subject to examination under the first inventor to file provisions of the AIA . A terminal disclaimer must be signed in compliance with 37 CFR 1.321(b). The USPTO Internet website contains terminal disclaimer forms which may be used. Please visit www.uspto.gov/patent/patents-forms. The filing date of the application in which the form is filed determines what form (e.g., PTO/SB/25, PTO/SB/26, PTO/AIA /25, or PTO/AIA /26) should be used. A web-based eTerminal Disclaimer may be filled out completely online using web-screens. An eTerminal Disclaimer that meets all requirements is auto-processed and approved immediately upon submission. For more information about eTerminal Disclaimers, refer to www.uspto.gov/patents/process/file/efs/guidance/eTD-info-I.jsp. Claims 2, 14 and 19 are rejected on the ground of nonstatutory double patenting as being unpatentable over claims 1, 9 and 16 of U.S. Patent No. 12,307,454 in view of Hijacking Routes in Payment Channel Networks: A Predictability Tradeoff (“Tochner et al.”). Although the claims at issue are not identical, they are not patentably distinct from each other. 19/192,658 U.S. Patent No. 12,307,454 2. (New) A method, comprising: accessing a plurality of electronic communication channels between an entity and a plurality of nodes in a second layer network, wherein the second layer network is layered on a first layer blockchain network; adjusting an incentive for using the entity as an intermediate node in the second layer network; accessing a request to transfer a digital asset from a sender node of the second layer network; identifying a recipient node of the second layer network; determining a first public address of the sender node and a second public address of the recipient node on the first layer blockchain network; and detecting an occurrence of specified type of event at least in part based on network activity associated with at least one of the first public address or the second public address on the first layer blockchain network. 9. A method, comprising: receiving, through a first channel in a second layer network layered on top of a first layer blockchain network, a request to transfer cryptocurrency from a first node in the second layer network, wherein the request to transfer the cryptocurrency is locked under a specified condition, and wherein the resolution of the specified condition involves a value of a variable that is unknown to an entity that receives the request; receiving, from a second node in the second layer network, the value of the variable; identifying, based on the receiving of the value of the variable, the second node in the second layer network as a recipient to which to transfer the cryptocurrency; determining a first public address for the first node based on information associated with an establishment of the first channel; determining a second public address for the second node based on information associated with an establishment of a second channel between a computer system and the second node, wherein the first public address and the second public address are usable for the first layer blockchain network; monitoring network activity of the first public address or the second public address, wherein the monitoring comprises: accessing a plurality of nodes of the second layer network based on a probed topology of the second layer network; and determining whether the first node or the second node opens an additional channel with a node of the plurality of nodes of the second layer network; and detecting, based on the monitoring of the network activity, a potential money laundering attempt associated with a first user corresponding to the first public address or with a second user corresponding to the second public address. 14. (New) A system, comprising: a non-transitory memory storing instructions; and one or more processors configured to execute the instructions to cause the system to perform operations comprising: accessing a second layer network that is layered on a first layer blockchain network, wherein the second layer network comprises a plurality of nodes that is each one hop away from a first node representing the system; determining a cost associated with using the first node to process a cryptographic transaction in the second layer network, wherein the cost is determined to be lower than other costs associated with using other nodes to process the cryptographic transaction; accessing a request from a sender node of the second layer network to conduct the cryptographic transaction; identifying a recipient node of the second layer network as a counterparty of the cryptographic transaction; determining a first public address of the sender node by hashing a first public key of the sender node according to a hashing protocol; determining a second public address of the recipient node by hashing a second public key of the recipient node according to the hashing protocol; monitoring a network activity associated with the first public address or the second public address; and determining whether a money laundering event has occurred at least in part based on the monitored network activity. 1. A computer system comprising: a non-transitory memory storing instructions; and one or more hardware processors configured to execute the instructions and cause the computer system to perform operations comprising: receiving, through a first channel in a second layer network layered on top of a first layer blockchain network, a request to transfer cryptocurrency from a first node in the second layer network, wherein the request to transfer the cryptocurrency is locked under a specified condition, wherein the request to transfer the cryptocurrency is unlocked when the specified condition is resolved, and wherein the resolution of the specified condition involves a value of a variable that is unknown to the computer system; receiving, from a second node in the second layer network, the value of the variable; identifying, based on the receiving of the value of the variable, the second node in the second layer network as a recipient to which to transfer the cryptocurrency; determining a first public address for the first node based on information associated with an establishment of the first channel; determining a second public address for the second node based on information associated with an establishment of a second channel between the computer system and the second node, wherein the first public address and the second public address are used for the first layer blockchain network; monitoring network activity of the first public address or the second public address, wherein the monitoring comprises: probing a topology of the second layer network; discovering one or more new nodes in the second layer network based on the probing; and determining whether the first node or the second node opens an additional channel with at least one of the one or more new nodes in the second layer network; and detecting, based on the monitoring of the network activity, a potential money laundering attempt associated with a first user corresponding to the first public address or with a second user corresponding to the second public address. 19. (New) A non-transitory machine-readable medium having instructions stored thereon, the instructions executable to cause a machine to perform operations comprising: accessing a plurality of channels between an entity and a plurality of nodes in a second layer network that is layered on a first layer blockchain network; setting an incentive for using the entity as an intermediate node in the second layer network to transfer a cryptocurrency such that the incentive is lower than using any other node as the intermediate node in the second layer network to transfer the cryptocurrency; receiving a request from a sender node to transfer the cryptocurrency via the second layer network, wherein the request is locked until a function is solved, wherein a solving of the function requires a value of a variable; identifying a recipient node of the second layer network based on the value of the variable supplied by the recipient node; determining a first public address of the sender node and a second public address of the recipient node on the first layer blockchain network; monitoring a network activity associated with at least one of the first public address or the second public address on the first layer blockchain network; and determining whether a money laundering event has occurred based at least in part on the monitored network activity. 16. A non-transitory machine-readable medium having instructions stored thereon, wherein the instructions are executable to cause a machine of a system to perform operations comprising: receiving, through a first channel in a second layer network layered on top of a first layer blockchain network, a request to transfer cryptocurrency from a first node in the second layer network, wherein the request to transfer the cryptocurrency is locked under a specified condition, and wherein the resolution of the specified condition involves a value of a variable that is unknown to an entity that receives the request; receiving, from a second node in the second layer network, the value of the variable; identifying, based on the receiving of the value of the variable, the second node in the second layer network as a recipient to which to transfer the cryptocurrency; determining a first public address for the first node based on information associated with an establishment of the first channel; determining a second public address for the second node based on information associated with an establishment of a second channel between a computer system and the second node, wherein the first public address and the second public address are used for the first layer blockchain network; monitoring network activity of the first public address or the second public address at least in part by: accessing a topology of the second layer network, the topology associated with a plurality of nodes; and determining that the first node or the second node has opened a payment channel with one or more nodes of the plurality of nodes; and detecting, based on the monitoring of the network activity, a potential money laundering attempt associated with a first user corresponding to the first public address or with a second user corresponding to the second public address. Regarding claim 2, 14 and 19, the claims of U.S. Patent No. 12,307,454 does not disclose: adjusting an incentive for using the entity as an intermediate node in the second layer network; determining a cost associated with using the first node to process a cryptographic transaction in the second layer network, wherein the cost is determined to be lower than other costs associated with using other nodes to process the cryptographic transaction; setting an incentive for using the entity as an intermediate node in the second layer network to transfer a cryptocurrency such that the incentive is lower than using any other node as the intermediate node in the second layer network to transfer the cryptocurrency; However, Tochner et al. discloses: adjusting an incentive for using the entity as an intermediate node in the second layer network; (abs 2nd para, left column, page 1) determining a cost associated with using the first node to process a cryptographic transaction in the second layer network, wherein the cost is determined to be lower than other costs associated with using other nodes to process the cryptographic transaction; (abs 2nd para, left column, page 1) setting an incentive for using the entity as an intermediate node in the second layer network to transfer a cryptocurrency such that the incentive is lower than using any other node as the intermediate node in the second layer network to transfer the cryptocurrency; (abs 2nd para, left column, page 1) Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to include adjusting fees for the intermediate nodes in accordance with the teaching of Tochner et al.. This modification enables the system to better control the traffic of intermediate nodes by adjusting fees. 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 2-21 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. Analysis In the instant case, claims 2-13 are directed to a method, claims 14-18 are directed to a system, and 19-21 are directed to a CRM. Therefore, these claims fall within the four statutory categories of invention. The claim(s) recite(s) processing financial transaction and detecting fraudulent. Specifically, the claim 2 recites “accessing a plurality of [electronic communication channels] between an entity and a [plurality of nodes] in a [second layer network], wherein the [second layer network] is layered on a [first layer blockchain network]; adjusting an incentive for using the entity as an [intermediate node] in the [second layer network]; accessing a request to transfer a digital asset from a [sender node] of the [second layer network]; identifying a [recipient node] of the [second layer network]; determining a first public address of the [sender node] and a second public address of the [recipient node] on the [first layer blockchain network]; and detecting an occurrence of specified type of event at least in part based on network activity associated with at least one of the first public address or the second public address on the [first layer blockchain network].”, claim 14 recites “accessing a [second layer network] that is layered on a [first layer blockchain network], wherein the [second layer network] comprises a [plurality of nodes] that is each one hop away from a [first node] representing the [system]; determining a cost associated with using the [first node] to process a [cryptographic transaction] in the [second layer network], wherein the cost is determined to be lower than other costs associated with using [other nodes] to process the [cryptographic transaction]; accessing a request from a [sender node] of the [second layer network] to conduct the [cryptographic transaction]; identifying a [recipient node] of the [second layer network] as a counterparty of the [cryptographic transaction]; determining a first public address of the [sender node] by [hashing a first public key] of the [sender node] according to a [hashing protocol]; determining a second public address of the [recipient node] by [hashing a second public key] of the [recipient node] according to the [hashing protocol]; monitoring a network activity associated with the first public address or the second public address; and determining whether a money laundering event has occurred at least in part based on the monitored network activity.”, and claim 19 recites “accessing a [plurality of channels] between an entity and a [plurality of nodes] in a [second layer network] that is layered on a [first layer blockchain network]; setting an incentive for using the entity as an [intermediate node] in the [second layer network] to transfer a cryptocurrency such that the incentive is lower than using any [other node] as the [intermediate node] in the [second layer network] to transfer the cryptocurrency; receiving a request from a [sender node] to transfer the cryptocurrency via the [second layer network], wherein the request is locked until a function is solved, wherein a solving of the function requires a value of a variable; identifying a [recipient node] of the [second layer network] based on the value of the variable supplied by the [recipient node[; determining a first public address of the [sender node] and a second public address of the [recipient node] on the [first layer blockchain network]; monitoring a network activity associated with at least one of the first public address or the second public address on the [first layer blockchain network]; and determining whether a money laundering event has occurred based at least in part on the monitored network activity.” which is “fundamental economic principles or practices” and “commercial or legal interactions” within the “certain methods of organizing human activity” grouping of abstract ideas in prong one of step 2A of the Alice/Mayo test (See MPEP 2106) because the claims involve a series of steps for processing financial transaction and detecting fraudulent. Accordingly, the claims recite an abstract idea. Additionally, the claims recite cryptographic transaction, hashing protocol, hashing a first public key, hashing a second public key which is the abstract idea of a mathematical concept. See MPEP 2106. Therefore, the claims recite an abstract idea, as it has been held that a combination of abstract ideas, in this case organizing human activity and a mathematical concept, is still an abstract idea. See FairWarning IP, LLC v. Iatric Sys., Inc., 839 F.3d 1089, 1093-94 (Fed. Cir. 2016). This judicial exception is not integrated into a practical application because, when analyzed under prong two of step 2A of the Alice/Mayo test (See MPEP 2106), the additional element(s) of the claim(s) such as the use of electronic communication channels, plurality of channels, second layer network, first layer blockchain network, nodes, intermediate node, sender node, recipient node, a plurality of nodes, first node, other nodes, system, memory, processor, non-transitory machine-readable medium, and machine merely use(s) a computer as a tool to perform an abstract idea. The processors and memories are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function of processing financial transaction and detecting fraudulent) such that it amounts no more than mere instructions to apply the exception using a generic computer components. Accordingly, the additional elements do not impose any meaningful limits on practicing the abstract idea, and the claims are directed to an abstract idea. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional element of using electronic communication channels, plurality of channels, second layer network, first layer blockchain network, nodes, intermediate node, sender node, recipient node, a plurality of nodes, first node, other nodes, system, memory, processor, non-transitory machine-readable medium, and machine steps amounts to no more than mere instructions to apply the exception using a generic computer components. Mere instructions to apply an exception using a generic computer components cannot provide an inventive concept. The claim is not patent eligible. Dependent claim 3 describes electronic communication channels and digital asset. Dependent claim 4 describes electronic communication channels. Dependent claim 5 describes the first and second public addresses. Dependent claims 6-7 and 17 describe incentive. Dependent claims 8 and 15 describe the request. Dependent claim 9 describes the recipient node. Dependent claim 10 describes determining a transferring status. Dependent claims 11 and 13 describe event. Dependent claims 12 and 18 describe identifying new nodes of the second layer network. Dependent claims 16 and 21 describe determining a money laundering event. Dependent claim 20 describes probing the second layer network to identify new nodes of the second layer network. These claims further recite the abstract idea of certain methods of organizing human activity. This judicial exception is not integrated into a practical application because the additional element(s) of the claim(s) such as the use of electronic communication channels, plurality of channels, second layer network, first layer blockchain network, nodes, intermediate node, sender node, recipient node, a plurality of nodes, first node, other nodes, system, memory, processor, non-transitory machine-readable medium, and machine merely use(s) a computer as a tool to perform an abstract idea. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. The claims are not patent eligible. Viewed as a whole, the combination of elements recited in the claims simply recite the concept of processing financial transaction and detecting fraudulent. The claims do not, for example, purport to improve the functioning of the computer itself. Nor do they effect an improvement in any other technology or technical field. The use of electronic communication channels, plurality of channels, second layer network, first layer blockchain network, nodes, intermediate node, sender node, recipient node, a plurality of nodes, first node, other nodes, system, memory, processor, non-transitory machine-readable medium, and machine as tools to implement the abstract idea does not render the claim patent eligible because it does not provide meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment and requires no more than a computer performing functions that correspond to acts required to carry out the abstract idea. Allowable Subject Matter Claims 2-21 would be allowable if rewritten or amended to overcome the double patent rejection and rejection(s) under 35 U.S.C. 101 set forth in this Office action. The closest prior art of record is 2018 IEEE “Routing payments on the Lightning Network” (“Stasi et al.”). Stasi et al. teaches accessing a plurality of electronic communication channels between an entity and a plurality of nodes in a second layer network, wherein the second layer network is layered on a first layer blockchain network; (page 1163, section “III. Lighting Network”), adjusting an incentive for using the entity as an intermediate node in the second layer network; (page 1161, abs); accessing a request to transfer a digital asset from a sender node of the second layer network; (page 1164, right column, section “A. A network of payment channels”) identifying a recipient node of the second layer network; (page 1164, right column, section “A. A network of payment channels”). However, the prior art does not teach, determining a first public address of the sender node and a second public address of the recipient node on the first layer blockchain network; and detecting an occurrence of specified type of event at least in part based on network activity associated with at least one of the first public address or the second public address on the first layer blockchain network. Conclusion The following prior art made of record and not relied upon is considered pertinent to applicant's disclosure. The Bitcoin Lighting Network: Scalable Off-Chain Instant Payments (“Poon et al.”) discloses A decentralized system is proposed whereby transactions are sent over a network of micropayment channels (a.k.a. payment channels or transaction channels) whose transfer of value occurs off-blockchain. If Bitcoin transactions can be signed with a new sighash type that addresses malleability, these transfers may occur between untrusted parties along the transfer route by contracts which, in the event of uncooperative or hostile participants, are enforceable via broadcast over the bitcoin blockchain in the event of uncooperative or hostile participants, through a series of decrementing timelocks.. Layer-Two Blockchain Protocols (“Gudgeon et al.”) provides a systematization of the associated synchronization and routing protocols along with their privacy and security aspects. This Systematization of Knowledge (SoK) clears the layer-two fog, highlights the potential of layer-two solutions and identifies their unsolved challenges, indicating propitious avenues of future work. Any inquiry concerning this communication or earlier communications from the examiner should be directed to YINGYING ZHOU whose telephone number is (571)272-5308. The examiner can normally be reached Mon - Fri 9:00am - 5:00pm ET. 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, John W Hayes can be reached on 571-272-6708. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /YINGYING ZHOU/Examiner, Art Unit 3697
Read full office action

Prosecution Timeline

Apr 29, 2025
Application Filed
Mar 27, 2026
Non-Final Rejection mailed — §101
Jun 15, 2026
Examiner Interview Summary
Jun 15, 2026
Applicant Interview (Telephonic)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12597038
REAL TIME INTERACTION PROCESSING SYSTEM AND METHOD
5y 3m to grant Granted Apr 07, 2026
Patent 12596999
SYSTEM AND METHOD FOR CONVERTING CRYPTOCURRENCY TO VIRTUAL ASSETS WHOSE VALUE IS SUBSTANTIATED BY A RESERVE OF ASSETS
4y 5m to grant Granted Apr 07, 2026
Patent 12597033
MACHINE LEARNING FOR FRAUD PREVENTATION ACROSS PAYMENT TYPES
3y 8m to grant Granted Apr 07, 2026
Patent 12596995
MYRIAD OF PAYMENT METHODS WITH ALTERNATE PAYMENT CONTROLS
3y 8m to grant Granted Apr 07, 2026
Patent 12597025
BLOCKCHAIN TRANSACTION EXECUTION METHOD AND APPARATUS, PROGRAM PRODUCT, DEVICE, AND MEDIUM
2y 5m to grant Granted Apr 07, 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
46%
Grant Probability
94%
With Interview (+48.4%)
3y 10m (~2y 8m remaining)
Median Time to Grant
Low
PTA Risk
Based on 180 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