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 .
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 § 2146 et seq. 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 filing of a terminal disclaimer by itself is not a complete reply to a nonstatutory double patenting (NSDP) rejection. A complete reply requires that the terminal disclaimer be accompanied by a reply requesting reconsideration of the prior Office action. Even where the NSDP rejection is provisional the reply must be complete. See MPEP § 804, subsection I.B.1. For a reply to a non-final Office action, see 37 CFR 1.111(a). For a reply to final Office action, see 37 CFR 1.113(c). A request for reconsideration while not provided for in 37 CFR 1.113(c) may be filed after final for consideration. See MPEP §§ 706.07(e) and 714.13.
The USPTO Internet website contains terminal disclaimer forms which may be used. Please visit www.uspto.gov/patent/patents-forms. The actual 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/apply/applying-online/eterminal-disclaimer.
Claims 1-20 are provisionally rejected on the ground of nonstatutory double patenting as being unpatentable over claims 2-21 of copending Application No. 19226504 (reference application). Although the claims at issue are not identical, they are not patentably distinct from each other.
This is a provisional nonstatutory double patenting rejection because the patentably indistinct claims have not in fact been patented.
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 13-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (abstract idea) without significantly more.
Under the broadest reasonable interpretation, the following claim terms are presumed to have their plain meaning consistent with the specification as it would be interpreted by one of ordinary skill in the art. MPEP § 2111.
Step 1: Does the Claim Fall within a Statutory Category? (see MPEP 2106.03) Claim 13 recites a process, which is a statutory category of invention (Step 1: YES). Claim 19 recites a system, which is a statutory category of invention (Step 1: YES).
Step 2A, Prong One: Is a Judicial Exception Recited? (see MPEP 2106.04(a)). Yes.
The claims are analyzed to determine whether it is directed to a judicial exception. The following claims identify the limitations that recite additional elements in bold and the abstract idea without bold. Underlined claim limitations denote newly added claim limitations:
Claim 13 recites a method, comprising: obtaining, by a server, identifying information for a deposit being processed for a depositor on a depositing device; determining, by the server, whether the identifying information is linked to a registered issuer of the deposit by searching a data store; sending, by the server, deposit details in an out-of-band message requesting authorization from the registered issuer to continue processing the deposit when the identifying information is linked to the registered issuer; and controlling, by the server, processing of the deposit based on a response received from the registered issuer. These limitations, as drafted, under its broadest reasonable interpretation, covers performance via certain methods of organizing human activity, but for the recitation of generic computer components. Under human activity, the limitations are fundamental economic practice. More specifically, under fundamental economic practice, the claims recite check authorization. The claims are also a commercial interactions, including legal obligations, and business relations. Lastly, the claims recite a mental process, as they are capable of being performed in the human mind or by pen and paper. Accordingly, the claim recites an abstract idea. The mere recitation of generic computer components in the claims do not necessarily preclude that claim from reciting an abstract idea. (Step 2A-Prong 1: Yes. The claims recite an abstract idea).
Step 2A, Prong Two: Is the Abstract Idea Integrated into a Practical Application? (see MPEP 2106.04(d)). No.
The above judicial exception is not integrated into a practical application. In particular, the claim recites the additional elements of a server, depositing device, and data store. The additional elements of a server, depositing device, and data store, are just applying generic computer components to the recited abstract limitations (MPEP 2106.05(f)). The additional elements of first and second graphical user interfaces are generally linking the use of the judicial exception to a particular technological environment or field of use, for the particular technology of Graphical User Interfaces (MPEP 2106.05(h)). The computer components are recited at such a high-level of generality (i.e. as a generic computer components) such that it amounts to no more than mere instructions to apply the exception using generic computer components. 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 and are at a high level of generality. (Step 2A-Prong 2: NO. The judicial exception is not integrated into a practical application).
Step 2B: Does the Claim Provide an Inventive Concept? (see MPEP 2106.05). No.
The claims are next analyzed to determine if there are additional claim limitations that individually, or as an ordered combination, ensure that the claim amounts to significantly more than the abstract ideas (whether claim provides inventive concept). As discussed with respect to Step 2A2 above, the additional elements of (server, depositing device, and data store) in the claims amount to no more than mere instructions to apply the exception using a generic computer component. The same analysis applies here in Step 2B, i.e., mere instructions to apply an exception using a generic computer component cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. Viewing the limitations as an ordered combination does not add anything further than looking at the 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 itself. Therefore, the claims do not amount to significantly more than the recited abstract idea (Step 2B: NO; The claims do not provide significantly more, and are not patent eligible).
Claim 14 recites wherein obtaining further includes receiving the identifying information as decoded Magnetic Ink Character Recognition (MICR) data read from a check being deposited during the deposit. These limitations are also part of the abstract idea identified in claim 13, and is similarly rejected under the same rationale as claim 13, supra.
Claim 15 recites wherein determining further includes performing a hash on MICR data to obtain a hash value and searching the data store with the hash value to match the hash value to an electronic contact address for the registered issuer. These limitations are also part of the abstract idea identified in claim 13, and the additional elements of hash and data store are addressed in the Steps 2A2 and B as just applying generic computer components to the recited abstract limitations (MPEP 2106.05(f)) as in the claim 13 analysis above. Therefore, this claim is similarly rejected under the same rationale as claim 13, supra.
Claim 16 recites wherein sending further includes sending the deposit details as: an entity name associated with the depositing device, a geographical location of the depositing device, a depositor name, an amount of the deposit, and a time-of-day that the deposit was received. These limitations are also part of the abstract idea identified in claim 13, and the additional elements of depositing device are addressed in the Steps 2A2 and B as just applying generic computer components to the recited abstract limitations (MPEP 2106.05(f)) as in the claim 13 analysis above. Therefore, this claim is similarly rejected under the same rationale as claim 13, supra.
Claim 17 recites wherein sending further includes receiving the authorization as an approval from the registered issuer to process a post-dated deposit. These limitations are also part of the abstract idea identified in claim 13, and is similarly rejected under the same rationale as claim 13, supra.
Claim 18 recites wherein controlling further includes recording the response in an audit trail associated with the deposit, the depositing device, the registered issuer, and the depositor. These limitations are also part of the abstract idea identified in claim 13, and the additional elements of depositing device are addressed in the Steps 2A2 and B as just applying generic computer components to the recited abstract limitations (MPEP 2106.05(f)) as in the claim 13 analysis above. Therefore, this claim is similarly rejected under the same rationale as claim 13, supra.
Claim 19 recites a system, comprising: a validation server comprising a processor and a non-transitory computer-readable storage medium; the non-transitory computer-readable storage medium comprising executable instructions; the executable instructions when executed by the processor from the non-transitory computer-readable storage medium cause the processor to operations comprising: receiving decoded Magnetic Ink Character Recognition (MICR) data from a deposit transaction device processing a check deposit; searching a data store with a hash value generated from the MICR data to identify an electronic contact address for an issuer of a check associated with the check deposit; sending deposit transaction details in an out-of-band message to the electronic contact address requesting authorization to process the check deposit; and providing a response to the deposit transaction device indicating whether to continue processing or terminate processing of the check deposit based on a reply received from the issuer. These limitations, as drafted, under its broadest reasonable interpretation, covers performance via certain methods of organizing human activity, but for the recitation of generic computer components. Under human activity, the limitations are fundamental economic practice. More specifically, under fundamental economic practice, the claims recite check authorization. The claims are also a commercial interactions, including legal obligations, and business relations. Lastly, the claims recite a mental process, as they are capable of being performed in the human mind or by pen and paper. Accordingly, the claim recites an abstract idea. The mere recitation of generic computer components in the claims do not necessarily preclude that claim from reciting an abstract idea. (Step 2A-Prong 1: Yes. The claims recite an abstract idea).
Step 2A, Prong Two: Is the Abstract Idea Integrated into a Practical Application? (see MPEP 2106.04(d)). No.
The above judicial exception is not integrated into a practical application. In particular, the claim recites the additional elements of validation server, processor, non-transitory computer-readable storage medium, executable instructions, processor, and data store. The additional elements of a validation server, processor, non-transitory computer-readable storage medium, executable instructions, processor, and data store, are just applying generic computer components to the recited abstract limitations (MPEP 2106.05(f)). The computer components are recited at such a high-level of generality (i.e. as a generic computer components) such that it amounts to no more than mere instructions to apply the exception using generic computer components. 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 and are at a high level of generality. (Step 2A-Prong 2: NO. The judicial exception is not integrated into a practical application).
Step 2B: Does the Claim Provide an Inventive Concept? (see MPEP 2106.05). No.
The claims are next analyzed to determine if there are additional claim limitations that individually, or as an ordered combination, ensure that the claim amounts to significantly more than the abstract ideas (whether claim provides inventive concept). As discussed with respect to Step 2A2 above, the additional elements of (validation server, processor, non-transitory computer-readable storage medium, executable instructions, processor, and data store) in the claims amount to no more than mere instructions to apply the exception using a generic computer component. The same analysis applies here in Step 2B, i.e., mere instructions to apply an exception using a generic computer component cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. Viewing the limitations as an ordered combination does not add anything further than looking at the 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 itself. Therefore, the claims do not amount to significantly more than the recited abstract idea (Step 2B: NO; The claims do not provide significantly more, and are not patent eligible).
Claim 20 recites wherein the executable instructions are further configured to cause the processor to perform additional operations comprising appending an image of the check captured by the deposit transaction device to the out-of-band message sent to the electronic contact address. These limitations are also part of the abstract idea identified in claim 19, and the additional elements of executable instructions and processor are addressed in the Steps 2A2 and B as just applying generic computer components to the recited abstract limitations (MPEP 2106.05(f)) as in the claim 19 analysis above. Therefore, this claim is similarly rejected under the same rationale as claim 19, supra.
Claim Rejections - 35 USC § 102
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
A person shall be entitled to a patent unless –
(a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention.
Claim(s) 13 is rejected under 35 U.S.C. 102(a)(1) as being anticipated by Knebel US 20150127533.
Regarding claim 13, Knebel discloses method, comprising:
obtaining, by a server, identifying information for a deposit being processed for a depositor on a depositing device (Fig. 1, Check acceptance; Para. 15, “It is therefore possible to use a mobile device such as an iPhone or PDA (android) etc. to take a photograph of the check in order to then securely upload this photograph to the transaction server in a substantially automatic manner.”; The digital image recognition unit produces an image that is evaluated in order to record digital check data which describes the issuer, the recipient and the sum of the check);
determining, by the server, whether the identifying information is linked to a registered issuer of the deposit by searching a data store (Knebel teaches loading digital communication addresses of the issuer from a database protected from external access; The database is created and operated for each user/check issuer and accepts entries only from people holding access credentials; Thus, the issuer is a “registered issuer”; The backend transaction system has access to the database which stores the personal communication addresses of the issuer; Para. 19, “the processing unit checks, in a database protected from external access, whether the issuer of the check has cleared the recipient by comparing the digital check data with data from the database… the processing unit loads digital communication addresses of the issuer from a database protected from external access, the digital check data are transmitted to the communication address with the request to digitally clear the check, and digital clearance of the check is received from the issuer);
sending, by the server, deposit details in an out-of-band message requesting authorization from the registered issuer to continue processing the deposit when the identifying information is linked to the registered issuer (Knebel teaches transmitting the digital check to a “digital communication address” with the request to digitally clear the check; Claims 2 and 8, Messege is sent by a separate channel from the deposit terminal: messages such as SMS, MMS, emails or short messages are sent to the issuer who can then clear the check by responding to the message; Fig. 2, issuer of check is informed by recipient when depositing the check that a check which debits his account has been debited);
and controlling, by the server, processing of the deposit based on a response received from the registered issuer (Knebel, Issuer now clears the check by answering “yes” or must reject the check by answering no; After the check has been cleared, the amount is paid to the recipient; Fig. 2).
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 (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
The following is a quotation of 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 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 nonobviousness.
Claim(s) 14 is rejected under 35 U.S.C. 103 as being unpatentable over Knebel US 20150127533, in view of Dutta US 20090276358, Blonder US 5708422 and Maloney US 7028886.
Regarding claim 14, Knebel fails to disclose wherein obtaining further includes receiving the identifying information as decoded Magnetic Ink Character Recognition (MICR) data read from a check being deposited during the deposit. However, Dutta discloses
It would have been considered obvious to one of ordinary skill in the art, before the effective date of filing, to have modified Knebel with the identifying information as decoded from MICR. Doing so adds standardization for a drawer’s routing and account number, as well as swapping OCR for MICR is a simple substitution of one known element for another with predictable results.
Claim(s) 15 is rejected under 35 U.S.C. 103 as being unpatentable over Knebel US 20150127533, in view of Blonder US 5708422 and Maloney US 7028886.
Regarding claim 15, modified Knebel fails to disclose where determining further includes performing a hash on MICR data to obtain a hash value and searching the data store with the hash value. However, Maloney discloses the system 100 that captures check identification data 140 (such as MICR code) from each transaction, generating a hash value from at least a portion of check identification data 140 and each record is associated with a MICR line, with the determined hash value comprising the primary key (Primary key allows for quick access and location; Fig. 3, all items file 130, record 131; Fig. 4, Step 406).
It would have been considered obvious to one of ordinary skill in the art, before the effective date of filing, to have modified Knebel with the hashing and searching with hash values of Maloney. Doing so adds greater security to the system, helping to overcome fraudulent check deposits.
Modified Knebel also fails to disclose to match the hash value to an electronic contact address for the registered issuer. However, Blonder discloses using an identifier of a proxy for it as a lookup key (Card number, or a proxy thereof, is used as a search key to retrieve parent or guardians profile that identifies a communications address).
It would have been considered obvious to one of ordinary skill in the art, before the effective date of filing, to have modified Knebel with the identifier of a proxy for a lookup key. Doing so helps adds in matching efforts of records for efficiency, and leads to greater security for the check depositing system.
Claim(s) 16 is rejected under 35 U.S.C. 103 as being unpatentable over Knebel US 20150127533, in view of Dutta US 20090276358, and Medina US 10210522.
Regarding claim 16, Modified Knebel discloses wherein sending further includes sending the deposit details as:, a depositor name (Knebel, Check data describes the issuer, the recipient and the sum of the check. For a deposit, the recipient if the depositor), an amount of the deposit (Knebel, “the sum”);
Modified Knebel fails to disclose an entity name associated with the depositing device, and a time-of-day that the deposit was received. However, Dutta discloses a name of owning bank (Fig. 19, Line 1908, Provides a transaction number, Line 1910 provides an ATM number, and line 1912 identifies a bank owning the ATM; Line 1904 date deposited is “time”).
It would have been considered obvious to one of ordinary skill in the art, before the effective date of filing, to have modified Knebel with the entity name as it provides greater clarity of the parties involved in the transaction, as well as the occurrence, and adds greater security in the check deposit process.
Modified Knebel fails to disclose a geographical location of the depositing device. However, Medina disclose sensor data that may be used for determining a material of a check, a location of the depositor, etc. (Fig. 5, step 504).
It would have been considered obvious to one of ordinary skill in the art, before the effective date of filing, to have modified Knebel with the location of the deposistor. Doing so adds greater security helping parties where the location of the check deposit occurs.
Claim(s) 17 is rejected under 35 U.S.C. 103 as being unpatentable over Knebel US 20150127533, in view of Singfield US 10521781.
Regarding claim 17, The method of claim 13, wherein sending further includes receiving the authorization as an approval from the registered issuer to process a post-dated deposit. However, Singfield discloses an issuer that grants approval to process a post-dated check (“The request for online check deposit cannot begin (nor can the image be viewed), until the user/depositor has logged onto the online account management system, and has initiated commands (i.e. for deposit, and/or delay of deposit—for post dated checks, notifications and alters, change of password, change of user/depositor banking information, setting user preferences, etc.; …. According to the invention, the option for adjustable clam connectivity feature, where the check image can be copied onto mobile device and/or pda device while working offline, and/or for future deposits (due to the Check 21 Act, banking consumers are less likely to be able to post date a check due to electronic processing, but the OMS allows user receipt of check images using WEDS for post dated check cashing and deposit options, so checks can be written for a future date, pre-stored on user's OMS account, and set by user to command OMS to process request for deposit on user specified date”; According to the invention, newness of the invention consisting of check images ability to be stored for future deposits (ie. in the case of post dated checks), where the system can be set to deposit a check (or an unlimited number of checks) on a specific date for processing—in addition to reminder cue feature option, which reminds user/depositor of checks stored in the system that are waiting to be deposited, reminding user/depositor of time frame before check is no longer valid (ie. 15 days left, 20 days, 30 days, 60 days left, etc.).”)
It would have been considered obvious to one of ordinary skill in the art, before the effective date of filing, to have modified Knebel with the ability to cash a post-dated check as in Singfield. Doing so helps customers correct issues dealing with check cashing and depositing, and makes for a more efficient check depositing system.
Claim(s) 18 is rejected under 35 U.S.C. 103 as being unpatentable over Knebel US 20150127533, in view of Maloney US 7890426 and Randle US 20060106717.
Regarding claim 18, modified Knebel fails to disclose wherein controlling further includes recording the response in an audit trail associated with the deposit, the registered issuer, and the depositor. However, Maloney discloses an audit log (Memory 120 may include audit log) with check processing engine 120a storing a local copy of an audit log, which include an image of the check that has been processed, with the check including an issuer (Fig. 2a, “John Smith”), a depositor (“Pay to the order of: ABC Corp.”) and the deposit itself of $100 on Jan 1, 2000.
It would have been considered obvious to one of ordinary skill in the art, before the effective date of filing, to have modified Knebel with the audit trail of the image of the check to include the depositor, issuer and deposit information. Doing so enhances security and helps prevent future fraud.
Modified Knebel fails to disclose the audit trail including the depositing device. However, Oakes disclose a log file being created for auditing that includes the identification of the image capture device that produced the check image, scanner or digital camera make and model, and device GUID (“Referring now to FIG. 5, an exemplary log file 500 is illustrated and examples of data that may be placed in the log file 500 are listed. In general, a log file can advantageously comprise an identification of an image capture device used to generate an image of a check, for example a scanner make and model, digital camera make and model, or other identification information such as an image capture device Global Unique Identifier (GUID). This identification information may also include an identification of software associated with the device, for example the familiar TWAIN drivers that can be used with scanners, digital cameras, and other image capture devices”)
It would have been considered obvious to one of ordinary skill in the art, before the effective date of filing, to have modified Knebel with the audit trail of the information of the depositing device. Doing so enhances security and helps prevent future fraud.
Claim(s) 19-20 are rejected under 35 U.S.C. 103 as being unpatentable over Knebel US 20150127533, in view of Dutta US 20090276358, Blonder US 5708422 and Maloney US 7028886.
Regarding claim 19, Knebel discloses a system, comprising:
a validation server comprising a processor and a non-transitory computer-readable storage medium (Knebel, authorization unit has network interfaces and a digitial processing unit implemented as software controlled server systems; Claim 7);
Knebel fails to disclose the non-transitory computer-readable storage medium comprising executable instructions; and the executable instructions when executed by the processor from the non-transitory computer-readable storage medium. However, Dutta discloses computer instructions (Abstract) with a storage medium (Para. 51; Claim 46).
It would have been considered obvious to one of ordinary skill in the art, before the effective date of filing, to have modified Knebel with the storage medium and instructions. Doing so allows the system to run check clearing functions (Dutta, Para. 51).
Modified Knebel fails to disclose receiving decoded Magnetic Ink Character Recognition (MICR) data from a deposit transaction device processing a check deposit. However, Dutta discloses a magnetic ink reader (Para. 33) used by an ATM (Fig. 14, Steps 1404-1412) while sending to a server (Para. 73, “Additionally, this scanning step also may include reading magnetic ink data on the check, which may contain a bank identification number and a checking account number. Optical character recognition (OCR) is performed on the digital image of the check to generate data for use in creating an electronic check (step 1406)”; Fig. 14-15, showing processing of check).
It would have been considered obvious to one of ordinary skill in the art, before the effective date of filing, to have modified Knebel with the magnetic ink reader used by a processing system. Doing so adds a greater level of security to the check process.
Knebel discloses searching a data store to identify an electronic contact for the issuer of a deposited check (“loading digital communication addresses of the issuer from a database protected from external access”, where the “database which stores the personal communication addresses of the issuer”), but fails to disclose searching a data store with a hash value generated from the MICR data. However, Maloney discloses a system for duplicate commercial paper detection with a hash generated from MICR data (Fig. 1, system 100/check identification data 140; System captures check data 140 (MICR line) from each transaction, and generates a hash value from at least a portion of the ID Data 140; “check processing engine 135 may determine the hash value using any appropriate technique or via implementing any suitable algorithm, such as MD-5, a proprietary technique, and others. Check processing engine 135 then communicates the determined hash value to repository 106 for authentication at step 406”) with a repository with searching capabilities (data store; Fig. 1, “repository 106 may be a central database communicably coupled with points-of-sale 102 and financial institutions 104”; Fig. 3, all items file 130/record 131, where each record is associated with particular MICR code or line, with the determined hash value comprises the primary key; Fig. 1, repository 106; Fig. 4, Step 406, determined hash is communicated to repository 106 to look up)
It would have been considered obvious to one of ordinary skill in the art, before the effective date of filing, to have modified Knebel with the duplicate commercial paper detection with a hash generated from MICR data with a repository with searching capabilities. Doing so increases fraud prevention and increase security of the check processing system (“For example, system 100 may capture check identification data 140 (such as a Magnetic Ink Character Recognition (MICR) code or a MICR line) from each transaction, generate a hash value from at least a portion of check identification data 140, and compare the hash value to each of a plurality of hash values associated with check identification data 140 for previously processed transactions. Therefore, system 100 may avoid or quickly rectify fraudulent or erroneous transactions.”).
Modified Knebel fails to disclose to identify an electronic contact address for an issuer of a check associated with the check deposit (which is hash key to contract-address lookup). However, Blonder discloses that a stored profile containing a party’s electronic communication address is retrieved by a search key that may be the account identifier “or proxy” (“In that case, the card number, or a proxy thereof, may be used as a search key to retrieve the parent or guardian's profile that identifies a communications address for the parent or guardian”; The profile table includes communication address field 308, which may hold “the communications address field 308 may be used to identify a telephone number or an electronic mail address”; the account identifier is used as a search key to retrieve the profile before the owner is contacted for approval (Fig. 7, steps 701-702))
It would have been considered obvious to one of ordinary skill in the art, before the effective date of filing, to have modified Knebel’s issuer-contact database with Maloney’s hash of the MICR routing fields as a proxy search from Blonder. Doing so allows a retrieving party a party’s contact-address profile with a proxy account of the account identifier rather than the identifier itself.
Modified Knebel discloses sending deposit transaction details (Knebel, “digital check data which describe the issuer, the recipient and the cum of the check”; Claim 1(b); Fig. 2, issuer is “informed by the recipient when depositing the check that a check which debits his account has been deposited”) in an out-of-band message (According to BRI, “out-of-band message” is a message sent to the issuer over a communication channel separate from the one carrying the deposit transaction between the depositing device and the server; See also Blonder, sends its approval request over paging system network 111, separate from the card readers link to validation database 106 over network 102) to the electronic contact address (Knebel, Transmits the check data “to the communication address” loaded from the issuer database (Claim 1(b); Claim 8, “he system of claim 7 set up to transmit the digital check data by SMS, MMS, email or to transmit a request to visit a web portal and to receive a confirmation message for authorizing the check by SMS, MMS, email or a message via the web portal”) requesting authorization to process the check deposit (Knebel, Sends the check data “with the request to digitally clear the check,” and the issuer returns “digital clearance of the check,” Claim 1(b); Clearance is authorization to process the deposit. Knebel says “the check can be processed only if” the authorization step succeeds, and Claim 7, “authorization unit for clearing the further processing of the check”)
Modified Knebel also discloses providing a response to the deposit transaction device indicating whether to continue processing or terminate processing of the check deposit based on a reply received from the issuer (Knebel, self-service machine waits for the issuer’s clearance and then pays out, Fig. 1-2; Blonder, Returns an “unauthorized transaction” message to card reader 101 on disapproval (Fig. 7)).
Regarding claim 20 modified Knebel discloses wherein the executable instructions are further configured to cause the processor to perform additional operations comprising appending an image of the check captured by the deposit transaction device to the out-of-band message sent to the electronic contact address (Dutta, Fig. 16, Step 1608: Check-use alert is sent to all associated account users, and the alert may, include the check image as well as any debit and credit information. Image is captured by ATM scanner (Fig. 8, scanner 802; Fig. 14, Step 1404).
Conclusion
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/BRANDON M DUCK/Examiner, Art Unit 3693
