Prosecution Insights
Last updated: April 19, 2026
Application No. 19/224,140

Electronic Payment System Including Merchant Server and Associated Methods

Non-Final OA §101§103§112
Filed
May 30, 2025
Examiner
HUANG, JAY
Art Unit
3619
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Malikie Innovations Limited
OA Round
3 (Non-Final)
52%
Grant Probability
Moderate
3-4
OA Rounds
5y 8m
To Grant
72%
With Interview

Examiner Intelligence

Grants 52% of resolved cases
52%
Career Allow Rate
245 granted / 467 resolved
+0.5% vs TC avg
Strong +20% interview lift
Without
With
+19.9%
Interview Lift
resolved cases with interview
Typical timeline
5y 8m
Avg Prosecution
44 currently pending
Career history
511
Total Applications
across all art units

Statute-Specific Performance

§101
20.5%
-19.5% vs TC avg
§103
39.2%
-0.8% vs TC avg
§102
7.7%
-32.3% vs TC avg
§112
27.4%
-12.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 467 resolved cases

Office Action

§101 §103 §112
DETAILED ACTION Acknowledgements This Office Action is in response to Applicant’s correspondence filed on 12/17/25. The Examiner notes that citations to United States Patent Application Publication paragraphs are formatted as [####], #### representing the paragraph number. In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. Status of Claims Claims 1-3, 9-14, 16-18, 24, 26-27, 29-30 are currently pending. Claims 1-3, 9-14, 16-18, 24, 26-27, 29-30 are rejected as set forth below. Notice of Pre-AIA or AIA Status The present application is being examined under the pre-AIA first to invent provisions. Continued Examination Under 37 CFR 1.114 A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 12/17/25 has been entered. Response to Arguments Claim Rejections - 35 U.S.C. § 101 Applicant’s arguments with respect to claim(s) 1, 16, 26, 27 have been fully considered and are persuasive. The rejection (and corresponding rejections to its dependent claims, if applicable) is withdrawn. Claim Rejections - 35 U.S.C. § 112(a) Applicant’s arguments with respect to claim(s) 5, 20, 25 have been fully considered and are persuasive. The rejection (and corresponding rejections to its dependent claims, if applicable) is withdrawn. Claim Rejections - 35 U.S.C. § 103 Applicant’s arguments with respect to claim(s) 1, 16, 26, 27 have been fully considered but are not persuasive. The rejection (and corresponding rejections to its dependent claims, if applicable) is maintained. Applicant contends the combination of Labrou and Tumminaro is improper because Labrou teaches away from generating the ID on a user device. The Examiner respectfully disagrees. First, the prior art in question must expressly exclude the feature in question or describe a disadvantage for using the feature. See MPEP 2145 D; In re Fulton, 391 F.3d 1195, 1201, 73 USPQ2d 1141, 1146 (Fed. Cir. 2004) (“The prior art’s mere disclosure of more than one alternative does not constitute a teaching away from any of these alternatives because such disclosure does not criticize, discredit, or otherwise discourage the solution claimed...."); In re Grasselli, 713 F.2d 731, 743, 218 USPQ 769, 779 (Fed. Cir. 1983) (“The claimed catalyst which contained both iron and an alkali metal was not suggested by the combination of a reference which taught the interchangeability of antimony and akali metal with the same beneficial result, combined with a reference expressly excluding antimony from, and adding iron to, a catalyst). Specifically, Labrou does not expressly exclude the feature of generating the ID on a user device. Second, the combination does not remove the transaction ID from the invention of Labrou. Instead, the combination modifies the invention of Labrou so the generation of the transaction ID explicitly being performed by the user device. Claim Rejections - 35 USC § 103 The following is a quotation of pre-AIA 35 U.S.C. 103(a) which forms the basis for all obviousness rejections set forth in this Office action: (a) A patent may not be obtained though the invention is not identically disclosed or described as set forth in section 102, if the differences between the subject matter sought to be patented and the prior art are such that the subject matter as a whole would have been obvious at the time the invention was made to a person having ordinary skill in the art to which said subject matter pertains. Patentability shall not be negated by the manner in which the invention was made. Claims 1-3, 9-14, 16-18, 24, 26-27, 29-30 is/are rejected under pre-AIA 35 U.S.C. 103(a) as being unpatentable over United States Patent Application Publication No. 20070022058 to Labrou in view of United States Patent Application Publication No. 20070255652 to Tumminaro. As per claims 1, 16, 26, 27, Labrou teaches: A method of payment processing, comprising: initiating an assignment of one or more assets from a first digital account to a second digital account by generating a unique transaction identification ID, the unique transaction ID being associated with transaction information for assigning the one or more assets from the first digital account to the second digital account, wherein the generated unique transaction ID is specific to the assignment between the first digital account and second digital account wherein the unique transaction ID includes numbers, letters, or a combination of numbers and letters; providing the unique transaction ID in an encrypted format to a payment process system to facilitate the payment process system to verify the transaction information; ([0108]-[0110], “Step 500. The merchant (cashier POS 103) sends a UPTF message to the STS 120 requesting a transaction ID and receives a transaction ID (TID) reply from the STS 120. The merchant displays the details of the transaction on a monitor (as in a normal store). This information may include the amount, a transaction ID and/or a POS ID to identify the merchant. According to an aspect of the embodiments, if the views 402, 404 do not contain a device ID, the transaction ID (since both the mobile device 104 and the POS 103 point to the transaction identifier) can be usable to bind the views 402, 404 for STS 120 authentication and verification. Step 502. The customer launches the mobile POS application 109 and enters the transaction ID and/or the POS ID as obtained from the merchant in operation 500. The customer enters the PIN. The customer selects an account. The mobile POS application 109 sends a UPTF message to the STS 120 using a cellular network 211, called the C-View 402. The encrypted portion 406 contains the transaction ID, the account, the time stamp and may or may not contain the POS ID. Step 504. The STS 120 receives the messages from the merchant 103 and the client 104. The STS 120 decodes the messages and verifies the identity of the parties. The STS authorizes the transaction.”; [0048], “TID: transaction ID, a unique identification number assigned to an agreement, which is maintained by the STS 120 to identify corresponding UPTF agreement views 402, 404.”; [0033], “In FIG. 2, the UPTF SAS protocol encrypts/decrypts a transaction message using a symmetric, secret-key 352.sub.c,m approach where the secret key 352.sub.c,m is producible only by an individual party's mobile device 104 and a trusted third party (e.g., implemented as STS 120) and without transmission of the secret key among the parties. In other words, the UPTF SAS provides an implicit user authentication, because decryption by a trusted third party, such as STS 120, of a sending party's encrypted message, authenticates the sending party.”) receiving, from the payment process system, confirmation that the one or more assets have been assigned, wherein the unique transaction ID is unique to the assignment and is non-reusable for a subsequent transaction associated with the first digital account or the second digital account. ([0110], “The STS authorizes the transaction. The STS 120 sends receipt messages to the merchant using its preferred connection 220 and to the customer over the cellular network 211.”; [0048], “TID: transaction ID, a unique identification number assigned to an agreement, which is maintained by the STS 120 to identify corresponding UPTF agreement views 402, 404. For example, a purchase transaction identifier uniquely identifying a particular purchase.”) Labrou does not explicitly teach, but Tumminaro teaches: initializing an electronic payment function on a user device; generating a unique transaction ID by a processor on the user device and responsive to initializing the electronic payment function; ([0032], “The method may include where the first screen further provides a third option to request payment from another. The method may include where the second screen has a third option which upon selection by the user provides the user access to an address book from which the user may select an entry to use as the target phone number. The transaction information may include a sequence number generated by the mobile phone.”) One of ordinary skill in the art would have recognized that applying the known technique of Tumminaro to the known invention of Labrou would have yielded predictable results and resulted in an improved invention. It would have been recognized that the application of the technique would have yielded predictable results because the level of ordinary skill in the art demonstrated by the references applied shows the ability to incorporate such payment transaction features into a similar invention. Further, it would have been recognized by those of ordinary skill in the art that modifying the invention to generate the unique transaction ID by a processor on the user device and responsive to initializing the electronic payment function results in an improved invention because applying said technique ensures that the user device can confirm the legitimacy of the transaction ID, thus improving the overall security of the invention. As per claims 2, 17, Labrou teaches: wherein the one or more assets to be assigned comprise one or more of: currency, gift card balance, prepaid balance, loyalty points, and coupons. ([0034], “In FIG. 2, after the STS 120 extracts the mobile device POS transaction data from the transaction views received from the parties and the STS 120 verifies the received mobile device POS transaction data, further actions may be needed, which, for example, may be realized by the trusted third party 120 interacting with financial institutions associated with the user payer 102 and the provider (merchant) payee 106 to cause the transfer of the specified funds between the user payer 102 and the provider payee 106.”) As per claims 3, 18, Labrou teaches: wherein the transaction information comprises an amount of the one or more assets to be assigned. ([0034]) As per claim 9, Labrou teaches: wherein the second digital account is associated with a merchant account. ([0034]) As per claim 10, Labrou teaches: wherein the first digital account is associated with a first electronic device and the second digital account is associated with a second electronic device. ([0021], “According to the embodiments, a user 102 uses a mobile device 104, such as (without limitation) a mobile phone or a PDA, with wireless communication capability, to transact with a Point of Sale (POS) device 103, such as (without limitation) a cash register, of a provider 106, for example, to purchase an item or receive a service, etc.”) As per claim 11, Labrou teaches: wherein the first or second electronic device is a smart mobile device. ([0021]) As per claim 12, Labrou teaches: wherein the method is operated over a wired or wireless communications network. ([0021], “The mobile device 104 can be any mobile wireless communication computing device or mobile radio computing device, including, without limitation, a mobile phone, that wirelessly communicates (e.g., wireless Internet or mobile phone network 211) with other mobile devices 104a-n, with a secure transaction server 120, or with a POS 103, or any combinations thereof. According to an aspect of the embodiments, the mobile device 104 has one or more short-range communication methods 210 implemented therein, for example (without limitation), image, audio, and/or RF, to communicate with the POS 103.”) As per claims 13, 29, Labrou teaches: wherein the transaction information comprises a device ID. ([0043]-[0044], “FIG. 3 shows the internal structure and the generation process of a mobile device POS authenticable transaction view messages 402, 404 (i.e., UPTF SAS authenticable transaction messages among a mobile device 104, a POS 103 and an STS 120). The identifiers used in FIG. 3 are explained below: DIDc: device ID, a unique identifier for the mobile POS 104 (the user consumer (c) or source transaction party).”) As per claims 14, 24, 30, Labrou teaches: wherein the confirmation is indicative of one or more of: a transferred asset amount, or one or more transferred asset types. ([0110]) Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure: United States Patent Application Publication No. 20080052182 to Marshall discloses a system and method to accept and settle transaction payments for an unbanked consumer. A consumer initiates a transaction with a merchant, and the merchant may transmit transaction information to a central processing unit using an initiating processing unit. The central processing unit may generate a unique transaction identifier or the merchant may generate the unique transaction identifier which complies with the systems rules and notifies the central processing unit of the transaction information and unique transaction identifier. The system may provide the merchant and consumer the nearest payment processing unit. At the payment processing unit, the consumer presents the unique transaction identifier, which is transmitted to the central processing unit for validation. The consumer may also validate the transaction information. The consumer makes payment at the payment processing unit, and the payment information is transmitted to the central processing unit. The system may generate a confirmation receipt for the consumer, and the central processing unit notifies the merchant of payment by the consumer. The merchant may then fulfill the transaction. The system remits the payment to the merchant. Any inquiry concerning this communication or earlier communications from the examiner should be directed to JAY HUANG whose telephone number is (408)918-9799. The examiner can normally be reached 9:00a - 5:30p PT. 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, Anita Coupe can be reached at (571) 270-3614. 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. /JAY HUANG/Primary Examiner, Art Unit 3619
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Prosecution Timeline

May 30, 2025
Application Filed
Jul 16, 2025
Non-Final Rejection — §101, §103, §112
Aug 11, 2025
Interview Requested
Aug 19, 2025
Applicant Interview (Telephonic)
Aug 20, 2025
Examiner Interview Summary
Sep 12, 2025
Response Filed
Oct 03, 2025
Final Rejection — §101, §103, §112
Dec 05, 2025
Response after Non-Final Action
Dec 17, 2025
Request for Continued Examination
Jan 28, 2026
Response after Non-Final Action
Apr 06, 2026
Non-Final Rejection — §101, §103, §112 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

3-4
Expected OA Rounds
52%
Grant Probability
72%
With Interview (+19.9%)
5y 8m
Median Time to Grant
High
PTA Risk
Based on 467 resolved cases by this examiner. Grant probability derived from career allow rate.

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