DETAILED ACTION
Notice of Pre-AIA or AIA Status
1. 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.
2. Claims 1-10, 12-21 are rejected under 35 U.S.C. 101 because the claimed invention recites an abstract idea without significantly more.
Using the language in claim(s) 1 to illustrate, the limitations of obtain historical financial transaction data indicative of financial transactions made by account holders associated with a financial institution; create, based on the historical financial transaction data, one or more features for use by a money laundering scenario detection model, wherein the one or more features operate as proxies for information that is not directly represented in the historical financial transaction data; provide the one or more features to the money laundering scenario detection model to detect the presence of one or more cash-based money laundering scenarios, including at least one of commingling of funds or conversion of bills from one denomination to a larger denomination; perform, using the money laundering scenario detection model, anomaly detection by defining a distribution of data points in a space in which the one or more features represent dimensions, each data point representing an account holder, determining a statistical distance of each data point from a centroid of the distribution, and ranking the account holders based on the determined statistical distances, wherein a greater statistical distance is indicative of a more anomalous account holder;
and provide, in response to a determination that a cash-based money laundering scenario has been detected, an alert indicative of the detected cash-based money laundering scenario, as drafted, is a process that, under its broadest reasonable interpretation, covers certain methods of organizing human activity, in particular, fundamental economic principles or practices (including mitigating risk), but for the recitation of generic computer components. The claims as a whole recite a method of organizing human activity. The claimed invention allows for detection of a cash-based money laundering scenario which is a fundamental economic practice. The mere nominal recitation of a generic circuitry do not take the claim out of the methods of organizing human activity grouping. Thus, under Eligibility Step 2A, prong one, (MPEP §2106.04(a)), the claims recite an abstract idea.
Under Eligibility Step 2A, prong two, (MPEP §2106.04(d)), this judicial exception is not integrated into a practical application. In particular, the claims only recite the additional elements— circuitry . The circuitry is recited at a high-level of generality (i.e., as a generic circuitry performing a generic computer functions of obtaining historical transaction data, creating features, providing features to a model, performing anomaly detection, determining a statistical distance, ranking the account holders, and providing an alert) such that they amount to no more than mere instructions to apply the exception using generic computer components (see MPEP §2106.05(f)). Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
Similar arguments can be extended to independent claim 15 and hence claim 15 is rejected on similar grounds as claim 1. In addition, claim 15 recites a “compute device” that amount to generic computer implementation.
The claims are directed to an abstract idea.
Under Eligibility Step 2B, (MPEP §2106.05), the claim(s) does/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 elements of using circuitry and a “compute” device, amounts to no more than mere instructions to apply the exception using generic computer components. Mere instructions to apply an exception using generic computer components cannot provide an inventive concept. The claims are not patent eligible.
The dependent claims have been given the full two part analysis including analyzing the additional limitations both individually and in combination. The dependent claim(s) when analyzed both individually and in combination are also held to be patent ineligible under 35 U.S.C. 101 because for the same reasoning as above and the additional recited limitation(s) fail(s) to establish that the claim(s) is/are not directed to an abstract idea. The dependent claims simply help to define the abstract idea. The additional limitations of the dependent claim(s) when considered individually and as an ordered combination do not amount to significantly more than the abstract idea.
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 an ordered combination, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea. Accordingly, claim(s) 1-10, 12-21 is/are ineligible.
Response to Arguments
3. In response to the amendment of the claims, the Examiner withdraws the 35 U.S.C. § 103 rejections.
The remaining arguments filed 8/13/2026 have been fully considered but they are not persuasive.
On page 7 of the Remarks, applicants argue that the claims integrate the judicial exception into a practical application because “the specification identifies a concrete technical problem: cash ‘provides less of a digital trace compared to other forms of money,’ ‘is readily broken down into smaller amounts (e.g., to avoid satisfying certain money laundering detection thresholds”,’ and can be moved quickly, ‘thereby reducing the window of time available for detection.’” Applicants further argue that to “address the problem, by providing a specific computational anomaly-detection technique to surface anomalous account holders and generate targeted alerts with the underlying data for analyst review.”
Applicants argue that the claims recite elements or a combination of elements which “integrate the exception into a practical application of the exception.” The Examiner respectfully disagrees. Under the 2019 PEG, Step 2A, prong two, integration into a practical application requires an additional element(s) or a combination of additional elements in the claim to apply, rely on, or use the judicial exception in a manner that imposes a meaningful limit on the judicial exception, such that the claim is more than a drafting effort designed to monopolize the exception. Limitations that are not indicative of integration into a practical application are those that are mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea.-see MPEP 2106.05(f).
Furthermore, in determining whether a claim integrates a judicial exception into a practical application, a determination is made of whether the claimed invention pertains to an improvement in the functioning of the computer itself or any other technology or technical field (i.e., a technological solution to a technological problem).
Here, the claims recite generic computer components, i.e., a compute device comprising circuitry to perform the claimed method steps and system functions and are recited as performing generic computer functions customarily used in computer applications.
The Examiner fails to see, and the Applicant fails to point out, how the steps are unconventional steps that confine the claims to a particular useful application.
On pages 8-9 of the Remarks, Applicants submit that under step 2B, Even if the claims were found to recite an abstract idea not integrated into a practical application, the specific, ordered combination of proxy-feature generation and statistical-distance-based anomaly detection is not "well-understood, routine, [and] conventional."
The only claim elements beyond the judicial exception are the claimed a compute device comprising circuitry configured to perform the claimed functions, i.e., generic computer components used to perform generic computer functions. Mere instructions to apply an exception using generic computer components cannot provide an inventive concept.
Applicants further argue that the Office Action provides no factual evidence, as required by Berkheimer v. HP Inc., 881 F.3d 1360 (Fed. Cir. 2018), and MPEP § 2106.05(d), that this particular combination is conventional in the field.
The Examiner respectfully disagrees with this argument. The Federal Circuit in Berkheimer made clear that “not every § 101 determination contains genuine disputes over the underlying facts material to the § 101 inquiry.” Berkheimer v. HP Inc., 881 F.3d 1360, 1368 (Fed. Cir. 2018). In fact, the Federal Circuit in Berkheimer did not require evidentiary support for independent claim 1 because “[t]he limitations [of claim 1] amount to no more than performing the abstract idea of parsing and comparing data with conventional computer components.” Id. at 1370.
Here, the claims recite generic computer components, i.e., a “compute device comprising circuity.” The claimed invention does not recite an improvement in technology but rather recites an improvement in a business process, i.e., money laundering scenario detection.
Conclusion
4. THIS ACTION IS MADE FINAL. 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 nonprovisional extension fee (37 CFR 1.17(a)) 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 mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ELDA MILEF whose telephone number is (571)272-8124. The examiner can normally be reached Monday-Thursday 6:30am-3:30pm; Friday 7am-12pm.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Bennett Sigmond can be reached at (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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/ELDA G MILEF/Primary Examiner, Art Unit 3694
