Prosecution Insights
Last updated: July 17, 2026
Application No. 19/315,220

Transaction Data Processing Systems and Methods

Non-Final OA §101
Filed
Aug 29, 2025
Priority
Dec 23, 2020 — AU 2020904805 +3 more
Examiner
REAGAN, JAMES A
Art Unit
3697
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Xero Limited
OA Round
1 (Non-Final)
71%
Grant Probability
Favorable
1-2
OA Rounds
2y 10m
Est. Remaining
91%
With Interview

Examiner Intelligence

Grants 71% — above average
71%
Career Allowance Rate
624 granted / 877 resolved
+19.2% vs TC avg
Strong +20% interview lift
Without
With
+20.1%
Interview Lift
resolved cases with interview
Typical timeline
3y 9m
Avg Prosecution
30 currently pending
Career history
912
Total Applications
across all art units

Statute-Specific Performance

§101
6.5%
-33.5% vs TC avg
§103
78.8%
+38.8% vs TC avg
§102
5.4%
-34.6% vs TC avg
§112
1.7%
-38.3% vs TC avg
Black line = Tech Center average estimate • Based on career data from 877 resolved cases

Office Action

§101
DETAILED ACTION Acknowledgments The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . This action is in reply to the application filed on 08/29/2025. Claims 1-16 are currently pending and have been examined. Information Disclosure Statement The Information Disclosure Statement filed on 09/08/2025 has been considered. An initialed copy of the Form 1449 is enclosed herewith. 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 1-16 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-patent eligible subject matter because the claim(s) as a whole, considering all claim elements both individually and in combination, do not amount to significantly more than an abstract idea. Step 1: The claims recite a process, system, apparatus, article of manufacture, and/or a nontransitory storage medium with instructions, each of which are proper statutory categories. Step 2A (prong 1): Claim 1 (representative of claims 11 and 16): The claim limitations are grouped as shown immediately following: determining, by an accounting system comprising memory, and one or more processors configured to execute instructions stored in the memory, a candidate financial record associated with a transaction between a first entity and a second entity; (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) determining, by the accounting system, one or more first substrings from a character string of the financial record; (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) training a numerical representation generation model using training data comprising a corpus generated from historical transaction records; (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions)providing, by the accounting system, the one or more first substrings to the numerical representation generation model; (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) generating, by the numerical representation generation model, a numerical representation of the candidate financial record based on the one or more first substrings; (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) training a first entity prediction model using training data comprising example financial records annotated with a respective identifier to generate a first trained entity prediction model; (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) providing, by the accounting system, the numerical representation of the candidate financial record as an input to the first trained entity prediction model; (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) determining, by the first trained entity prediction model, a first predicted entity identifier; (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) training a second entity prediction model using training data comprising example financial records annotated with a respective identifier to generate a second trained entity prediction model, (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) wherein the second trained entity prediction model is a multi-class classifier and wherein the multi-class classifier is configured to classify a candidate financial record as being associated with one of a first set of entity identifiers; (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) providing, by the accounting system, the numerical representation of the candidate financial record as an input to the second trained entity prediction model; (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) determining, by the second trained entity prediction model, a second predicted entity identifier; (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) combining, by the accounting system, the first predicted entity identifier and the second predicted entity identifier to generate a combined predicted entity identifier by determining a longest common sequence between the first predicted identifier and the second predicted identifier; (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) determining, by the accounting system, a first set of suggested entity identifiers for the candidate financial record based on the combined predicted entity identifier; (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) using, by the accounting system, a suggested entity identifier from the first set of suggested entity identifiers to: (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) (i) reconcile the candidate financial record with a respective accounting record of the accounting system; or (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) (ii) create a new accounting record in the accounting system; (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions)wherein generating the numerical representation of the candidate financial record comprises: (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) generating, by the accounting system, a first set of tokens by tokenising each of the one or more first substrings; (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) generating, by the numerical representation generation model, a numerical representation of each token of the first set of tokens; (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) determining the numerical representation of the candidate financial record as a function of the numerical representations of each token of the first set of tokens. (Certain Methods Of Organizing Human Activity - business relations - following rules or instructions) Step 2A (prong 2): Claim 1 (representative of claims 11 and 16): …memory …one or more processors …an accounting system … a non-transient computer-readable storage medium …a computer These remaining claim limitations are delineated as shown immediately preceding. The abstract idea is not integrated into a practical application. There are no improvements to the functioning of a computer, other technology or technical field, a particular machine is not cited, nothing is transformed to a different state or thing, the abstract idea is not more than a drafting effort designed to monopolize the abstract idea. The claim merely uses a computer as a tool to perform the abstract idea, which is generally linked to a particular field of use, in this case, marketing and advertising. Thus, these limitations are recited at a high-level of generality (i.e., as a generic processor and memory performing a generic computer function of processing and storing data) such that it amounts no more than mere instructions to apply the exception using a generic computer component – MPEP 2106.05(f). Further, receiving data, evaluating data and distributing data are data gathering and data outputting, which has no effect on technology and does no more than generally link the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h). Step 2B: The claim limitations do not provide an Inventive Concept. The claim limitations do not recite additional elements that amount to significantly more that the abstract idea because the additional elements of the system comprising a computer processor, computer readable storage medium with instructions, and a memory configured to store information, each recited at a high level of generality in a computer network which only perform the universal computer functions of accessing, receiving, storing, and processing data, transmitting and presenting information. Taking the elements both individually and as an ordered combination, the function performed by the computer at each step of the process is purely orthodox. Using a computer to obtain and display data are some of the most basic functions of a computer. As shown, the individual limitations claimed are some of the most rudimentary functions of a computer. The technical solution described in this invention does not alter hardware structure or its routine, does not transform the character of the information being processed, does not identify a novel source or type of data, does not advance the functionality of a computer as a tool, and does not incorporate specific rules enabling the computer to accomplish innovative utilities. In summary, the individual step and/or component does no more than require a general computer to perform standard computer functions. As discussed above with respect to integration of the abstract idea into a practical application, the additional element of a computer devices amounts to no more than mere instructions to apply the exception using a generic computer component - requiring the use of software to tailor information and provide it to the user on a generic computer, Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 1370-71, 115 USPQ2d 1636, 1642 (Fed. Cir. 2015); Claims 13-16, as recited, are directed toward logic. Such logic can be interpreted as computer code, per se, which is not a statutory category and is therefore unpatentable. However, a computer program can be eligible for patent protection if it is tangibly embodied on a computer readable medium and, when executed by a computer, performs the steps of the invention. Appropriate correction is required. Applicant is also respectfully reminded that like all claim amendments, a claim amendment inserting non-transitory must have clear support or antecedent basis in the original specification. See MPEP §608.01(o) with particular emphasis on MPEP §608.01(o) ¶3. CONCLUSION The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Non Patent Literature: Tookitaki. “What is data reconciliation and what is it used for in finance?”. (20 May 2020). Retrieved online 08/23/2022. https://www.tookitaki.com/compliance_hub/what-is-reconciliation/ SCOR. “ P&C loss development triangles and reserves as of December 2019.” (2019). Retrieved online 08/23/2022. https://www.scor.com/en/download/file?token=def502000af358d4c35cb6e36e1e747623a0f0c3c06f93e75768ec914fb31fe1cf35180e9632058b442404ff60f038debc13ff8dd7ba7b8ce68c872fd577713c94ebaab1e2a6e6410c3c10e5627c9ce4e3338e73d18fbfd17824b88a6bb8ad062156e7389d1040381528764727635250acd19a0c3b403f93b4be3060ecc439c4e2686ceb76 EFRAG. “ACCOUNTING FOR CRYPTO-ASSETS (LIABILITIES): HOLDER AND ISSUER PERSPECTIVE.” (July 2020). Retrieved online 08/23/2022. https://www.efrag.org/Assets/Download?assetUrl=/sites/webpublishing/SiteAssets/EFRAG%2520Discussion%2520Paper-Accounting%2520for%2520Crypto-Assets%2520%28Liabilities%29-%2520July%25202020.pdf Michael Casey et al. “The Impact of Blockchain Technology on Finance: A Catalyst for Change.” (2018). Retrieved online 08/23/2022. https://www.sipotra.it/wp-content/uploads/2018/07/The-Impact-of-Blockchain-Technology-on-Finance-A-Catalyst-for-Change.pdf LAVINIA ANDREEA SAMOILA. “Multiple Entity Reconciliation.” (September 2015). Retrieved online 08/23/2022. http://www.diva-portal.org/smash/get/diva2:928531/FULLTEXT01.pdf Foreign Art: ALEJANDRO LLAVES et al. “APPARATUS AND METHOD FOR GENERATION OF FINANCIAL EVENT DATABASE.” (JP 2018/198046 A) KRIKORIAN, SHARI et al. “METHOD AND SYSTEM FOR PURCHASE CARD UTILIZATION AND DATA RECONCILIATION WITH ENTERPRISE RESOURCE PLANNING/FINANCIAL SOFWARE.” (WO 2006/017630 A2) HODSON, MELISSA. “METHOD AND SYSTEM FOR CONTRACT COMPARISON IN SECURITIES LENDING TRANSACTIONS.” (WO 2007/033095 A2) CONLEY, WILLIAM S. et al. “DATA COLLECTION, MANIPULATION, RECONCILIATION, AND REPORTING FOR MULTIPLE SITES.” (WO 2007/112374 A2) HYNES, ANTHONY et al. “FINANCIAL TRANSACTION PROCESSING METHOD AND SYSTEM.” (WO 2008/036998 A1) Any inquiry of a general nature or relating to the status of this application or concerning this communication or earlier communications from the Examiner should be directed to James A. Reagan (james.reagan@uspto.gov) whose telephone number is 571.272.6710. The Examiner can normally be reached Monday through Friday from 9 AM to 5 PM. If attempts to reach the examiner by telephone are unsuccessful, the Examiner’s supervisor, John Hayes, can be reached at 571.272.6708. Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://portal.uspto.gov/external/portal/pair . Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866.217.9197 (toll-free). Any response to this action should be mailed to: Commissioner for Patents PO Box 1450 Alexandria, Virginia 22313-1450 or faxed to 571-273-8300. Hand delivered responses should be brought to the United States Patent and Trademark Office Customer Service Window: Randolph Building 401 Dulany Street Alexandria, VA 22314. /JAMES A REAGAN/Primary Examiner, Art Unit 3697 james.reagan@uspto.gov 571.272.6710 (Office) 571.273.6710 (Desktop Fax)
Read full office action

Prosecution Timeline

Aug 29, 2025
Application Filed
Jun 24, 2026
Non-Final Rejection mailed — §101 (current)

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Prosecution Projections

1-2
Expected OA Rounds
71%
Grant Probability
91%
With Interview (+20.1%)
3y 9m (~2y 10m remaining)
Median Time to Grant
Low
PTA Risk
Based on 877 resolved cases by this examiner. Grant probability derived from career allowance rate.

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