DETAILED ACTION
Introduction
This Office action is responsive to the communications filed March 19, 2026. Claims 1-20 are pending.
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.
In the instant case, claims 1-7 are directed to a method. Claims 8-14 are directed to a device. Claims 15-20 are directed to a non-transitory computer readable storage medium. Therefore, these claims fall within the four statutory categories of invention.
For example, claim 1 recites an abstract idea of providing a transaction token. The claim under its broadest reasonable interpretation recites limitations grouped within the “certain methods of organizing human activity” grouping of abstract ideas. The certain methods of organizing human activity abstract idea grouping is defined as concepts related to fundamental economic principles or practices, commercial or legal interactions including agreements in the form of contracts, legal obligations, advertising, marketing or sales activities or behaviors, and business relations. See MPEP § 2106.04(a)(2), subsection II. The claim limitations reciting the abstract idea are grouped within the “certain methods of organizing human activity” grouping of abstract ideas as they relate to providing a transaction token. More specifically, the following the bolded claim elements recite additional elements while the other claim elements recite the abstract idea. according to MPEP 2106.04(a).
A method comprising:
at a computing device in communication with a management entity:
receiving, from a software application executing on the computing device, a first
request to perform a transaction;
providing, to a management entity, a second request to generate a transaction
token for the transaction, wherein the management entity generates the transaction token;
displaying a user interface, wherein:
in accordance with a determination that the second request includes first
transaction type information, the user interface indicates that the transaction will be performed independent from the software application executing on the computing device; and
in accordance with a determination that the second request includes second transaction type information, the user interface does not indicate that the transaction will be performed independent from the software application executing on the computing device;
while displaying the user interface, receiving approval to perform the transaction;
and
in response to receiving the approval to perform the transaction, providing the
transaction token to the software application or a developer entity associated with the software
application.
Independent claims 8 and 15 recite similar language.
This judicial exception is not integrated into a practical application because, when analyzed under prong two of step 2A of the Alice/Mayo test (See MPEP 2106.04(d)), the additional element(s) of the claim(s) such as the transaction token, software application, user interface, and computing device are merely used as tools to perform an abstract idea and/or generally link the use of a judicial exception to a particular technological environment. Specifically, these additional elements perform the steps or functions of providing a transaction token. Viewed as a whole, the use of transaction token, software application, user interface, and computing device as tools to implement the abstract idea and/or generally linking the use of the abstract idea to a particular technological environment does not integrate the abstract idea into a practical application because it requires no more than a computer or computer networks performing functions that correspond to acts required to carry out the abstract idea. The additional elements do not involve improvements to the functioning of a computer, or to any other technology or technical field (MPEP 2106.05(a)), and the claims do not apply or use the abstract idea in some other meaningful way beyond generally linking the use of the abstract idea to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception (MPEP 2106.05(e) and Vanda Memo). Therefore, the claims do not, for example, purport to improve the functioning of a computer. Nor do they effect an improvement in any other technology or technical field. Accordingly, the additional elements do not impose any meaningful limits on practicing the abstract idea, and the claims are directed to an abstract idea.
The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when analyzed under step 2B of the Alice/Mayo test (See MPEP 2106.05), the additional element(s) of the transaction token, software application, user interface, and computing device to perform the steps amounts to no more than using generic hardware or software to automate and/or implement the abstract idea of providing a transaction token. Viewed as a whole, the combination of elements recited in the claims merely recite the concept of providing a transaction token. Therefore, the use of these additional elements does no more than employ the computer as a tool to automate and/or implement the abstract idea. The use of a computer or processor to merely automate and/or implement the abstract idea cannot provide significantly more than the abstract idea itself (MPEP 2106.05 (f) & (h)). Therefore, the claim is not patent eligible.
The dependent claims further describe the abstract idea such as prior to receiving approval to perform the transaction, displaying, in the user interface:
a first option that, when selected, causes the computing device to display
information about the transaction;
a second option that, when selected, causes the computing device to proceed with
performing the transaction; and
a third option that, when selected, causes the computing device to cancel the
transaction.
The dependent claims do not include additional elements that integrate the abstract idea into a practical application or that provide significantly more than the abstract idea. Therefore, the dependent claims are also not patent eligible.
Claim Rejections - 35 USC § 103
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, 2, 8, 9, 9, and 16 are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Publication No. 2017/0091759 to Selfridge et al. (“Selfridge”) in view of U.S. Publication No. 2024/0362611 to Baskaran et al. (“Baskaran”).
As per claim 1, Selfridge disclose at a computing device in communication with a management entity: receiving, from a software application executing on the computing device, a first request to perform a transaction (abstract – receive a transaction request; paragraph [0012] – mobile application…receive request from customer);
providing, to a management entity, a second request to generate a transaction token for the transaction, wherein the management entity generates the transaction token (abstract -generate a payment token; paragraph [0007]- processing device…to receive request from customer to generate the payment token);
displaying a user interface, wherein (paragraphs [0004]; [0006] – mobile application…prompt the customer to approve or deny the transaction):
while displaying the user interface, receiving approval to perform the transaction; and in response to receiving the approval to perform the transaction, providing the transaction token to the software application or a developer entity associated with the software application (paragraphs [0006] – prompt the customer to approve…in response to the alert indicating the transaction request to the customer, an approval communication from the customer approving the transaction and approve and settle the transaction; [0057] – receiving a request from the customer to generate a payment token, prompt the customer...implement the limitation on the sue of eth token… [0059]- token management interface…may serve as a dashboard for initiating generation and communication of tokens).
Selfridge does not expressly disclose in accordance with a determination that the second request includes first transaction type information, the user interface indicates that the transaction will be performed independent from the software application executing on the computing device;
and in accordance with a determination that the second request includes second transaction type information, the user interface does not indicate that the transaction will be performed independent from the software application executing on the computing device.
Baskaran discloses in accordance with a determination that the second request includes first transaction type information;
and in accordance with a determination that the second request includes second transaction type information, the user interface does not indicate that the transaction will be performed independent from the software application executing on the computing device (abstract – determining a transaction type based on the selection… providing transaction information to a mobile device…based on the determined transaction type).
As for the display indicating the transaction, the user interface indicates that the transaction will be performed independent from the software application executing on the computing device, this is considered non-functional descriptive material and is not functionally involved in the steps. Selfridge discloses the alert on the UI may be intended solely for information purposes However, this difference is only found in the non-functional descriptive material and is not functionally involved in the steps recited. The displaying step would be performed the same regardless of what data is shown. Thus, this descriptive material will not distinguish the claimed invention from the prior art in terms of patentability, see In re Gulack, 703 F.2d 1381, 1385, 217 USPQ 401, 404 (Fed. Cir. 1983); In re Lowry, 32 F.3d 1579, 32 USPQ2d 1031 (Fed. Cir. 1994).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to modify Selfridge by including the features of Baskaran to effectively facilitate electronic transactions. Applying the known technique of Baskaran in Selfridge would have been recognized by those of ordinary skill in the art as resulting in an improved system that would have yielded predictable results.
As per claim 2, Baskaran discloses the first transaction type information includes an indication that the transaction will be performed via at least one webpage that is loaded in a web browser application executing on the computing device; and the second transaction type information includes an indication that the transaction will be performed via the software application (see abstract and claim 1 above).
Claims 8 and 15 are rejected on the same rationale as claim 1.
Claims 9 and 16 are rejected on the same rationale as claim 2.
Claims 3-7, 10-13, and 17-19 are rejected under 35 U.S.C. 103 as being unpatentable over Selfridge and Baskaran as applied to claim 1 above, and further in view of U.S. Publication No. 2019/0122222 to Uechi (“Uechi”).
As per claim 3, Selfridge in combination with Baskaran disclose prior to receiving approval to perform the transaction, displaying, in the user interface: a first option that, when selected, causes the computing device to display information about the transaction;
a second option that, when selected, causes the computing device to proceed with performing the transaction (see claim 1 and Baskaran -paragraphs [0074], [0081]), and [0095]).
The references do not expressly disclose third option that, when selected, causes the computing device to cancel the transaction.
Uechi discloses third option that, when selected, causes the computing device to cancel the transaction (paragraph [0246] – cancel button).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to modify Selfridge by including the features of Baskaran and Uechi to effectively facilitate electronic transactions. Applying the known technique of Baskaran in combination with Uechi in Selfridge would have been recognized by those of ordinary skill in the art as resulting in an improved system that would have yielded predictable results.
As per claim 4, Selfridge in combination with Baskaran and Uechi disclose while displaying the user interface, detecting a user input directed to the third option; and in response to detecting the user input directed to the third option: invalidating the transaction token; and providing, to the management entity, a third request to cancel the transaction token (see claim 3 above; Uechi – paragraph [0225]).
As per claim 5, Selfridge in combination with Baskaran and Uechi disclose prior to the management entity generating the transaction token, verifying that the transaction token is valid, wherein verifying the transaction token is valid includes the management entity authorizing the developer entity associated with the software application (see claim 4 above).
As per claim 6, Selfridge in combination with Baskaran and Uechi disclose in response to receiving the first request to perform the transaction: identifying a user account associated with the computing device; interfacing with the management entity to receive a verification that the user account is valid; and receiving the verification from the management entity; and in response to receiving the verification from the management entity, providing, to the management entity, the second request to generate the transaction token for the transaction (see claim 4 above).
As per claim 7, Selfridge in combination with Baskaran and Uechi disclose the transaction token (see claim 1 above). As for the transaction token including information included, derived from, or obtained in the second request including: a session identifier associated with the second request; a unique identifier associated with the software application; a respective transaction type information; and/or storefront information that includes locale, currency, tax, and commission information associated with the software application, the computing device, the transaction, or some combination thereof, this is considered nonfunctional descriptive material. The providing a second request step would be performed the same regardless of what data is included in the request. Thus, this descriptive material will not distinguish the claimed invention from the prior art in terms of patentability, see In re Gulack, 703 F.2d 1381, 1385, 217 USPQ 401, 404 (Fed. Cir. 1983); In re Lowry, 32 F.3d 1579, 32 USPQ2d 1031 (Fed. Cir. 1994).
Claims 10-14 are rejected on the same rationale as claims 3-7.
Claims 17-20 are rejected on the same rationale as claims 1-7.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to JALATEE WORJLOH whose telephone number is (571)272-6714. The examiner can normally be reached Monday-Friday 6:00am-2:00pm.
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/Jalatee Worjloh/Primary Examiner, Art Unit 3697
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