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 . This office action is in response to Applicant’s communication filed August 04, 2025 in which claims 1-20 are pending in the application.
Claim Interpretation
2. The following is a quotation of 35 U.S.C. 112(f):
(f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.
The following is a quotation of pre-AIA 35 U.S.C. 112, sixth paragraph:
An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.
The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked.
As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph:
(A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function;
(B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and
(C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function.
Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function.
Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function.
Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action.
This application includes one or more claim limitations that do not use the word “means,” but are nonetheless being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, because the claim limitation(s) uses a generic placeholder that is coupled with functional language without reciting sufficient structure to perform the recited function and the generic placeholder is not preceded by a structural modifier. Such claim limitation(s) is/are: a money movement platform and a funds control system in claim 11.
Because this/these claim limitation(s) is/are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it/they is/are being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof.
If applicant does not intend to have this/these limitation(s) interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, applicant may: (1) amend the claim limitation(s) to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph (e.g., by reciting sufficient structure to perform the claimed function); or (2) present a sufficient showing that the claim limitation(s) recite(s) sufficient structure to perform the claimed function so as to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph.
Claim Rejections - 35 USC § 101
3. 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.
The Examiner has identified independent Claim 1 as the claim that represents the claimed invention for analysis and is similar to independent Claim 11.
The claims 1-10 are directed to a method and claims 11-20 are directed to a non-transitory machine-readable medium which is one of the statutory categories of invention (Step 1: YES).
The claim 1 recites : receiving, by a funds control workflow orchestrator computer program executed by an electronic device and from a money movement platform, a funds control request for a transaction for a client; requesting, by the funds control workflow orchestrator computer program, funding for the request from a liquidity matching computer program; determining, by the liquidity matching computer program, whether the request can be funded based on account balances for the client retrieved from or synchronized with an account ledger or an approved credit extension; generating, by the liquidity matching computer program, a liquidity snapshot for the client and storing the liquidity snapshot in an available liquidity snapshot store; receiving, by the funds control workflow orchestrator computer program, a positive determination on liquidity; returning, by the funds control workflow orchestrator computer program, the positive determination to the money movement platform, wherein the money movement platform executes the transaction; and updating, by the funds control workflow orchestrator computer program, a workflow status. These limitations (with the exception of italicized portions), are a process that covers Certain methods of organizing human activity such as a Commercial or legal interaction. Matching liquidity can be characterized as a commercial or legal interaction (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations). The claim also recites additional elements (as shown above in italics) which do not necessarily restrict the claim from reciting an abstract idea. That is, other than, the recited additional elements (as shown above in italics), nothing in the claim precludes the steps from being performed as a method of organizing human activity. If the claim limitations, under the broadest reasonable interpretation, covers methods of organizing human activity but for the recitation of generic computer components, then it falls within the “Certain methods of organizing human activity” grouping of abstract ideas. Accordingly, the claim 1 recites an abstract idea (Step 2A: Prong 1: YES).
This judicial exception is not integrated into a practical application. The additional elements of a funds control workflow orchestrator computer program, an electronic device, a money movement platform, a liquidity matching computer program, an account ledger and the liquidity snapshot store result in no more than simply applying the abstract idea using generic computer elements. The specification describes the additional elements of a funds control workflow orchestrator computer program, an electronic device, a money movement platform, a liquidity matching computer program, an account ledger and the liquidity snapshot store to be generic computer elements (see Fig. 1, Fig. 7). Hence, the additional elements in the claims are all generic components suitably programmed to perform their respective functions. The additional elements (as shown above in italics) are recited at a high level of generality and under their broadest reasonable interpretation comprises a generic computer arrangement. The presence of a generic computer arrangement is nothing more than mere instructions to implement the abstract idea on a computer (MPEP 2106.05(f)). 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. Hence, the claims as a whole are not integrated into a practical application. Therefore, the claim 1 is directed to an abstract idea (Step 2A - Prong 2: NO).
The claim 1 does not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements as described above are recited at a high level of generality in that it results in no more than simply applying the abstract idea using generic computer elements. 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 (MPEP 2106.05(f)). The additional elements, when considered separately and as an ordered combination, does not add significantly more (also known as an “inventive concept”) to the exception. The additional elements of the instant underlying process, when taken in combination, together do not amount to significantly more than the sum of the functions of the elements when each is taken alone. Thus, claim 1 is not patent eligible (Step 2B: NO).
Similar analysis can he extended to other independent claim 11 and hence the claim 11 is rejected on similar grounds as claim 1. In addition, claim 11 also recites a funds control system which amounts to generic computer implementation.
The dependent claims have been given the full two-part analysis including analyzing the additional limitations both individually and in combination. Dependent claims 2-10 and 12-20 are held to be patent ineligible under 35 U.S.C. 101 because the additional recited limitations narrow the abstract idea further and thus correspond to Certain Methods of Organizing Human Activity and hence are abstract for the reasons presented above. Claims 2, 7, 12 and 17 recite new additional elements that are not present in independent claims 1 or 11 and require further analysis under Prong Two of Step 2A and Step 2B.
Claims 2 and 12 recite the additional elements of a debit funding algorithm and a ledger reconciliation computer program. A debit funding algorithm and a ledger reconciliation computer program, recited in the claim, are recited at a high level of generality and amounts to generic computer implementation. Hence, they do not integrate the abstract idea into a practical application or provide significantly more than the abstract idea when considered individually and as an ordered combination.
Claims 7 and 17 recite the additional element of a credit extension approval system. A credit extension approval system, recited in the claim, is recited at a high level of generality and amounts to generic computer implementation. Hence, they do not integrate the abstract idea into a practical application or provide significantly more than the abstract idea when considered individually and as an ordered combination.
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 a combination, the additional limitations do not amount to a claim as a whole that is significantly more than the abstract idea. Accordingly, claim(s) 1-20 are ineligible.
No Prior Art Rejections
4. Based on the prior art search results, the prior art of record fails to anticipate or render obvious the claimed subject matter of claims 1-20. While some individual features of claims 1-20 may be shown in the prior art of record, no known reference, alone or in combination, would provide the invention of claims 1-20. The prior art most closely resembling the applicant’s claimed invention are :
1) Hoffmann (US 2010/0125533 A1) – The invention relates generally to systems and methods for obtaining increased liquidity from an alternative fund without the need to determine value for the existing investments in the fund. This is done by bifurcating the existing and the unfunded positions of an investment in an alternative investment fund, leaving the existing investments with the current investor and instead laying off exposure of a percentage of the committed but uninvested capital to a prospective investor.
2) Lutnick (US 2005/0010481 A1) - The invention relates generally to provide systems and methods that may provide speculators an opportunity to invest in items and markets that, in the past, were not liquid enough to allow for investment by the general public. Systems and methods for creating indices for these items or markets can help improve their overall liquidity.
3) Marques (US 2007/0094119 A1) – The invention relates to a system of improving liquidity in large block transactions of securities by employing portfolio analysis. Asset liquidity is improved in a transaction network by identifying a potential party to an asset transaction based on an analysis of asset portfolio data. The portfolio data is analyzed in view of the transaction proposal data to determine if at least one predetermined financial threshold would be satisfied in the portfolio by accepting the proposed transaction. An alert message can then be provided to the asset manager client identifying the transaction proposal if a predetermined financial threshold is triggered during the evaluating step.
4) Jayaram (US 2019/0156416 A1) - The invention relates to financial systems and, more particularly, to systems and methods that manage financial risk and liquidity. A financial management system identifies data associated with a plurality of events in a financial market in substantially real time. The financial management system analyzes the data associated with the plurality of events and, based on the analysis, determines a liquidity demand, a liquidity profile, and a risk profile associated with a particular financial institution. The financial management system then communicates the financial institution's liquidity demand, liquidity profile, and risk profile to the financial institution.
Examiner Request
5. The Applicant is request to indicate where in the specification there is support for amendments to claims should Applicant amend. The purpose of this is to reduce potential 35 U.S.C. §112(a) or §112 1st paragraph issues that can arise when claims are amended without support in the specification. The Examiner thanks the Applicant in advance.
Conclusion
6. Any inquiry concerning this communication or earlier communications from the examiner should be directed to BHAVIN SHAH whose telephone number is (571)272-2981. The examiner can normally be reached on M-F 9AM-6PM.
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, Bennett Sigmond can be reached on 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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/BHAVIN D SHAH/Examiner, Art Unit 3694
August 21, 2026
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