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 .
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 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Step 1:
Claims 1-20 fall into at least one of the four categories of statutory subject matter. The eligibility analysis proceeds to Step 2A.1.
Step 2A.1:
The limitations of independent claim 1 have been denoted with letters by the Examiner for easy reference. Independent claim 11 recites similar distinguishing features as claim 1, therefore the following eligibility analysis shall apply to both independent claims 1 and 11. The judicial exceptions recited in claim 1 are identified in bold below:
A premises security system, comprising:
a cryptocurrency management device comprising a hardware-based cryptocurrency wallet configured to store cryptocurrency;
first processing circuitry configured to:
monitor a premises via a plurality of premises devices;
detect at least one premises alarm condition based on the monitoring; and
in response to the at least one premises alarm condition, indicate, to the cryptocurrency management device, at least one cryptocurrency action to perform; and
the cryptocurrency management device comprising:
second processing circuitry configured to:
perform the at least one cryptocurrency action according to the indication.
Under the broadest reasonable interpretation, D-E recite limitations that are reasonably categorized under mental processes. To monitor a premise and detect an alarm condition based on the monitoring can be practically performed in the human mind. F and I recite limitations that are reasonably categorized under certain methods of organizing human activity. Performing a cryptocurrency action in response to an indication based on the detected alarm condition is analogous to managing personal behavior or relationships or interactions between people in the form of following rules or instructions.
Claims 1 and 11 recite at least one abstract idea. The eligibility analysis proceeds to Step 2A.2.
Step 2A.2
The judicial exception is not integrated into a practical application. In particular, claim 1 recites the additional element(s) not in bold above.
A-C, G-H, “via a plurality of premises devices” in D, and “to the cryptocurrency management device” in F have all been recited at a high-level of generality such that they amount to no more than generic computing components. Therefore, when the additional elements are considered individually and as an ordered combination with the abstract idea, the claims amount to no more than mere software instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea. 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.
Furthermore, “a hardware-based cryptocurrency wallet configured to store cryptocurrency” is considered an insignificant extra-solution activity because the limitation does not impose any meaningful limits on the structure of the cryptocurrency management device or the method performed by a premises security system.
Claims 1 and 11 do not recite additional elements that integrate the judicial exception into a practical application. The eligibility analysis proceeds to Step 2B.
Step 2B:
The additional elements, both individually and as an ordered combination, do not amount to significantly more than the judicial exception because the outcome of the considerations at Step 2B will be the same when considerations from Step 2A.2 are re-evaluated. Furthermore, storing information (limitation B) is considered by the courts to be well-understood, routine, and conventional activity (see MPEP 2106.05(d)(II), “storing and retrieving information in memory,” Versata). As discussed above with respect to integration of the abstract idea into a practical application, the additional elements amount to no more than mere instructions to apply the exception using a generic computer component. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept.
Claims 1 and 11 are not patent eligible.
Dependent Claims
Dependent claims 2, 4, 6, 12, 14, and 16 further define the at least one cryptocurrency action. These actions elaborate on the abstract idea(s) without reciting any new additional elements. When the limitations are considered individually and as a whole in combination with the independent claims from which they depend, the claims do not recite additional elements that amount to significantly more than the judicial exception.
Dependent claims 3, 5, 7, 13, 15, and 17 further define the alarm condition. These conditions elaborate on the abstract idea(s) without reciting any new additional elements. When the limitations are considered individually and as a whole in combination with the independent claims from which they depend, the claims do not recite additional elements that amount to significantly more than the judicial exception.
Dependent claim 8-10 and 18-20 introduce new additional elements: security base station and remote monitoring center. However, they have also been recited at a high-level of generality such that they amount to no more than generic computing components. Therefore, when the additional elements are considered individually and as an ordered combination with the abstract idea, the claims amount to no more than mere software instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea. 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.
In summary, the dependent claims considered both individually and as an ordered combination do not provide meaningful limitations to transform the abstract idea(s) into a patent eligible application such that the abstract idea amounts to significantly more than the abstract idea itself. The claims do not recite an improvement to another technology or technical field, an improvement to the functioning of the computer itself, or provide meaningful limitations beyond generally linking an abstract idea to a particular technological environment. Therefore, claims 1-20 are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter.
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.
Claims 1, 6-11, and 16-20 are rejected under 35 U.S.C. 103 as being unpatentable over Bansal et al. U.S. 2018/0174136 (herein as “Bansal”) in view of Islam et al. U.S. 2020/0097953 (herein as “Islam”).
Re Claims 1 and 11, Bansal discloses a premises security system, comprising:
a […] management device comprising a hardware-based […] wallet configured to store […] financial instruments [0020] – “a wallet platform 114 may be an aggregator of multiple financial instruments,” [0024] – “The wallet platform 114 may use a processor with memory”;
first processing circuitry configured to [0015] – “sensors associated with the alarm system 106”:
monitor a premises via a plurality of premises devices [0013] – “The alarm system 106 may be any of a number of systems that actively or passively monitor property”;
detect at least one premises alarm condition based on the monitoring [0031] – “an alarm notification may be received from a personal property alarm of the person”; and
in response to the at least one premises alarm condition, indicate, to the […] management device, at least one […] action to perform [0023] – “the alarm system may independently send an alarm signal to the wallet platform 114,” [0017] – an alarm signal may have an actionable alarm type, and the actionable alarm type may have a one-to-one mapping to a contingent action; and
the […] management device comprising:
second processing circuitry configured to [0024] – “The wallet platform 114 may use a processor with memory”:
perform the at least one […] action according to the indication [0025] – “The wallet platform 114 may implement the appropriate contingent action or contingent actions,” based on the received alarm signal [0024].
However, Bansal does not expressly disclose
the management device is a cryptocurrency management device,
the wallet is a cryptocurrency wallet,
the financial instruments are cryptocurrency,
the action is a cryptocurrency action.
Islam discloses system and method for management of cryptocurrency systems. Specifically, Islam discloses
the management device is a cryptocurrency management device [0018] – “cryptocurrency management system”,
the wallet is a cryptocurrency wallet [0018] – “cryptocurrency management system (e.g., a cryptocurrency wallet)”,
the financial instruments are cryptocurrency [0018] – cryptocurrency assets can be monitored for different attacks,
the action is a cryptocurrency action [0021] – “executing a predetermined action” such as “halting transactions for the cryptocurrency asset.”
It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify Bansal’s management device, wallet, financial instruments, and action to be for cryptocurrency as taught in Islam. The modification is a simple substitution of one known element, i.e. cryptocurrency, for another to obtain predictable results. Furthermore, one would be motivated to make the modification to improve security for cryptocurrency assets by minimizing risk of attacks Islam, [0027], [0035].
Re Claims 6 and 16, Bansal in view of Islam teach the premises security system of claim 1, and Bansal in view of Islam further teach wherein the at least one cryptocurrency action comprises one or both of locking the hardware-based cryptocurrency wallet Bansal, [0032] – “putting a proactive hold on all accounts associated with financial instruments held by the user” and resetting at least one key for interacting with the hardware-based cryptocurrency wallet.
Re Claims 7 and 17, Bansal in view of Islam teach the premises security system of claim 6, and Bansal in view of Islam further teach wherein the at least one premises alarm condition corresponds to detecting motion proximate the cryptocurrency management device while the premises security system is in an armed state Bansal, [0016] – alarm types may include “unexpected movements in an interior of the property.”
Since the claimed invention and the specification do not define what is considered “proximate,” under the broadest, most reasonable interpretation, detecting unexpected movements in a property monitored by an alarm system, i.e. armed, and triggering the alarm signal to be sent to the wallet platform 114 [0016-17], [0023] is analogous to detecting motion proximate the cryptocurrency management device because the wallet platform is associated with the monitored user’s property Fig. 2, [0020], and therefore any detection of motion at such property is detection of motion proximate the wallet platform 114.
Re Claims 8 and 18, Bansal in view of Islam teach the premises security system of claim 1, and Bansal in view of Islam further teach wherein the cryptocurrency management device and the first processing circuitry are part of a security system base station Bansal, Fig. 1.
Re Claims 9 and 19, Bansal in view of Islam teach the premises security system of claim 1, and Bansal in view of Islam further teach wherein the first processing circuitry is part of a security base station that is separate from the cryptocurrency management device Bansal, Fig. 1 – wallet platform 114 analogous to cryptocurrency management device, alarm system 106 analogous to first processing circuitry, both elements are separate. System in Fig. 1 as a whole is analogous to the security base station.
Re Claims 10 and 20, Bansal in view of Islam teach the premises security system of claim 9, and Bansal in view of Islam further teach wherein the cryptocurrency management device and the security base station are monitored by a remote monitoring center Bansal, Fig. 1 – alarm monitoring service 107, Bansal, [0013], [0026] – the alarm monitoring service 107 can send/receive from both alarm system 106 and wallet platform 114.
Claims 2-3 and 12-13 are rejected under 35 U.S.C. 103 as being unpatentable over Bansal et al. U.S. 2018/0174136 (herein as “Bansal”) in view of Islam et al. U.S. 2020/0097953 (herein as “Islam”) as applied to claims 1 and 11 above, and further in view of Godsey et al. U.S. 2017/0193504 (herein as “Godsey”).
Re Claims 2 and 12, Bansal in view of Islam teach the premises security system of claim 1, however, Bansal in view of Islam do not explicitly teach wherein the at least one cryptocurrency action comprises initiating a transfer of cryptocurrency to a predefined location that is off-site from the premises.
Godsey discloses financial management systems and associated methods. Specifically, Godsey discloses
wherein the at least one cryptocurrency action comprises initiating a transfer of cryptocurrency to a predefined location that is off-site from the premises [0048] – “upon determining that the at least one condition has…been met, financial management application 177 may convey a signal…wherein electronic wallet application 127, in response to the signal, may perform one or more actions (e.g…transfer money (e.g, from one account to another)…).”
Condition can be defined by the user [0011]. Therefore, the location is “predefined.” Furthermore, the user account(s) exist at the payment provider server Fig. 1 170, which is separate from the user device Fig. 1 110, and is reasonably interpreted to be “off-site from the premises,” wherein premises is analogous to a user device and/or where a user is located.
It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to combine Bansal in view of Islam’s property alarm system to protect financial instruments with the teachings of initiating a transfer of money, i.e. cryptocurrency, to a predefined location that is off-site from the premises in Godsey. One would be motivated to make this combination to provide a customizable financial management system and thereby allow a user to customize their finances Godsey, [0037-39].
Re Claims 3 and 13, Bansal in view of Islam and Godsey teach the premises security system of claim 2, and Bansal in view of Islam and Godsey further teach wherein the at least one premises alarm condition corresponds to a fire condition or a flood condition Bansal, [0016] – “fire or smoke alarms.”
Claims 4-5 and 14-15 are rejected under 35 U.S.C. 103 as being unpatentable over Bansal et al. U.S. 2018/0174136 (herein as “Bansal”) in view of Islam et al. U.S. 2020/0097953 (herein as “Islam”) as applied to claims 1 and 11 above, and further in view of Hamilton et al. U.S. 2017/0337390 (herein as “Hamilton”).
Re Claims 4 and 14, Bansal in view of Islam teach the premises security system of claim 1, however, Bansal in view of Islam do not explicitly teach wherein the at least one cryptocurrency action comprises resetting one or both of a secret key and a factory key for interacting with the hardware-based cryptocurrency wallet.
Hamilton discloses data protection at factory reset. Specifically, Hamilton discloses
wherein the at least one cryptocurrency action comprises resetting one or both of a secret key and a factory key for interacting with the hardware-based cryptocurrency wallet [0062] – “Replacing the previously stored factory reset value with the new factory reset value” in response to a request for factory reset of the computing device, which can include financial information [0023], i.e. “hardware-based cryptocurrency wallet.”
It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to combine Bansal in view of Islam’s property alarm system to protect financial instruments with the teachings of resetting a factory key for interacting with the computing device, i.e. hardware-based cryptocurrency wallet, in Hamilton. One would be motivated to make the combination to protect information stored on the computing device Hamilton, [0002].
Re Claims 5 and 15, Bansal in view of Islam and Hamilton teach the premises security system of claim 4, and Bansal in view of Islam and Hamilton further teach wherein the at least one premises alarm condition corresponds to an intrusion alarm that is associated with an intrusion at the premises Bansal, [0029], Table 1 – “Home Intrusion.”
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Hubner et al. U.S. 2012/0084857 directed to device security system. See at least [0018]
Lohe et al. U.S. 2021/0266167 directed to conditional triggered transaction. See at least [0361].
Any inquiry concerning this communication or earlier communications from the examiner should be directed to CHRISTINE DANG whose telephone number is (571)270-5880. The examiner can normally be reached M-F 9-5pm MT.
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/CHRISTINE DANG/Examiner, Art Unit 3698
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