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 .
Status of Claims
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 01/30/2026 has been entered.
This application claims earliest foreign priority to 1718505.9, filed 11/09/2017.
Claims 1, 9, and 12 have been amended and claim 13 cancelled.
Claims 3-12 being dependent on either of independent claims 1 and 14-20.
Claims 1, 3-12 & 14-20 are currently pending and have been examined.
Response to Arguments
Applicant's arguments filed 01/30/2026 have been fully considered but they are not persuasive.
Under Step 2A, Prong One, Applicant contends that the claims are not directed to an abstract idea because they recite a specific blockchain-based verification mechanism involving distributed nodes, cryptographic keys, and validation of conditions prior to transfer of a digital asset. This argument is not persuasive. The claims when considered as a whole, are directed to facilitating a transfer of ownership or control of a digital asset based on satisfaction of conditions and verification of performance, including receiving transaction data, evaluating conditions, verifying results, and authorizing a transfer. Such activity constitutes certain methods of organizing human activity, including commercial or financial transactions and agreements between parties, which are recognized abstract ideas. See MPEP § 2106.044(a)(2).
Applicant argues that the claimed processors are not performed in the human mind and therefore are not mental processes. However, the claims need only fall within one abstract idea grouping to be ineligible. Even if not a mental process, the claims still recite commercial interactions involving conditional transfer of assets, which fall squarely within organizing human activity. Accordingly, this argument is not persuasive. Applicant further asserts that the claims are directed to blockchain-specific technology and cryptographic verification techniques. However, recitation of a technological environment, such as “blockchain”, “distributed nodes”, “verification keys”, or “multiplication gates”, does not change the fundamental focus of the claims, which is performing a conditional transaction based on verification. These elements merely describe the environment in which the abstract idea is implemented. See MPEP § 2106.05(a).
Under Step 2A, Prong Two, Applicant argues that the claims integrate the abstract idea into a practical application by improving distributed computing systems and blockchain validation processes. This argument is not persuasive. The additional elements, including distributing tasks to worker nodes, generating evaluation and verification keys, receiving proofs, and verifying computation results amount to data processing, validation and result verification; which are themselves abstract operations. These steps do not impose a meaningful limit on the judicial exception but instead apply the abstract idea using generic distributed computing components.
Applicant asserts that the claims improve computer technology by enabling verification of untrusted nodes without precomputation. However, the claims do not recite a specific improvement to computer functionality or a specific improvement in how computers operate. Instead, they use computers as tools to perform verification and validation of transactional condition. Improvements to business logic, trust models, or transactional reliability do not constitute improvements to computer technology. See MPEP § 2106.05(a).
Applicant’s reliance on the alleged “specific method” of verification (e.g., multiplication gates, evaluation keys, verification keys) is also not persuasive. The claims recite these elements at a high-level of generality without specifying a particular technical implementation that improves computer performance. Rather, they describe results-oriented functional language for verifying correctness of computations.
Applicant’s argument that the Examiner improperly “generalized” the claims is not persuasive. The Examiner has considered the claims as a whole and has identified the abstract idea based on the actual recited limitations, not an overgeneralization. The characterization of the claims as performing conditional validation and transfer based on verification is consistent with the claim language.
Applicant argues that blockchain technology is inherently technical and cannot be performed mentally or with pen and paper. While blockchain systems involve technical components, the claimed invention is not directed to improving blockchain technology itself. Instead, the claims use blockchain as a platform to perform a conditional transfer of assets based on verification, which remains an abstract idea. Implementing an abstract idea in a technological environment does not render the claim patent-eligible.
Under Step 2B, Applicant argues that the ordered combination of elements provides significantly more than the abstract idea, citing BASCOM Global Internet Services, Inc. v. AT&T Mobility LLC. This argument is not persuasive. Unlike BASCOM, where the claims recited a specific, non-conventional arrangement of filtering components, the present claims recite generic distributed computing components performing conventional functions, such as receiving data, distributing tasks, verifying results, and recording transactions.
The additional elements, including processors, memory, distributed nodes, and cryptographic keys, perform their well-understood, routine, and conventional functions of processing, transmitting, and verifying data. The claimed steps of generating keys, receiving proofs, and verifying computations represent generic data processing and validation operations.
Applicant’s reliance on the arrangement of elements is also not persuasive. The ordered combination of receiving transaction data, validating conditions, verifying computation, and recording the transaction merely reflects a conventional sequence of data processing steps used to implement the abstract idea, and does not amount to an inventive concept.
Accordingly, when considered as a whole, the claims are directed to an abstract idea (organizing human activity), do not integrate the abstract idea into a practical application and do not recite additional elements sufficient to amount to significantly more than the abstract idea. For the above reasoning, the 35 USC 101 rejection is upheld.
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, 3-12 & 14-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. Claims 1 and 3-20 are directed to Method of Organizing Human Activity. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional computer elements, which are recited at a high-level of generality, provide conventional computer functions that do not add meaningful limits to practicing the abstract idea.
Additionally, independent claim 1 recites, in part, receiving a blockchain transaction to be validated; validating the one or more conditions; providing a task to a worker, the task specifying a computation to perform; and verifying, that the computation is correctly performed by the worker, the computation based on a circuit having a set of multiplication gates, by at least: generating an evaluation key and a verification key; providing the evaluation key to the worker; receiving a proof from the worker, the proof based at least in part on the evaluation key; and verifying that the computation is correct using the proof and the verification key, process blockchain transactions and performing the verifying that the computation performed during validation of the blockchain transaction, and in response to successful validation of the one or more conditions by verifying the computation is correct, adding the blockchain ... These limitations are directed to the concepts of commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations). Hence, it falls within the “Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
This judicial exception is not integrated into a practical application. The additional elements i.e. “client computer systems including a computing device having a processor and a memory storing executable instructions”, “worker computer systems”, “blockchain”, and a “circuit” are recited at a high-level of generality (processing data) such that it amounts no more than adding the words “apply it” with the judicial exception to implement an abstract idea on a computer i.e. processors with memory suitably programmed. Accordingly, the 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. Claim 1 is directed to an abstract idea as are independent claims 14-20 based on similar analysis.
Next the claims as a whole are analyzed to determine whether any element, or combination of elements, are sufficient to ensure the claims amount to significantly more than an abstract idea. As discussed with respect to Step 2A, the claim as a whole merely describes additional elements performing the abstract idea on a generic device i.e., abstract idea and generally applying the use of the judicial exception to a particular technological environment. See MPEP 2106.05(h). There is no improvement to computer technology or computer functionality MPEP 2106.05(a) nor a particular machine MPEP 2106.05(b) nor a particular transformation MPEP 2106.05(c). Given the above reasons, even when viewed as a whole, nothing in the claims add significantly more (i.e. an inventive Concept) to the abstract idea. Thus, claim 1 is not patent eligible. Independent claims 14-20 are not eligible under the same analysis.
The dependent claims 3-12 have been given the full two-part analysis (Step 2A – 2-prong tests and step 2B) including analyzing the additional limitations both individually and in combination. The dependent claim(s) when analyzed both individually and in combination are held to be patent ineligible under 35 U.S.C. 101 because further limiting the abstract idea does not amount to significantly more than the abstract idea. Claims 3-12 further narrow the abstract idea without providing significantly more than the abstract idea. In some examples, "nodes" refers to peer-to-peer electronic devices that are distributed among the blockchain network”’ and “In some embodiments, the nodes 102 can be comprised of any suitable computing device (e.g., by a server in a data center, by a client computing device (e.g., a desktop computer, laptop computer, tablet computer, smartphone, etc.), by multiple computing devices in a distributed system of a computing resource service provider, or by any suitable electronic client device such as the computing- device 600 of figure 6). Clearly, the additional recited limitations in the dependent claims only refine the abstract idea further. Further refinement of an abstract idea does not convert an abstract idea into something concrete. As such, the claims, when considered as a whole, are nothing more than the instruction to implement the abstract idea in a particular, albeit well-understood, routine and conventional technological environment.
Accordingly, the Examiner concludes that there are no meaningful limitations in the claims that transform the judicial exception into a patent eligible application such that the claims amount to significantly more than the judicial exception itself or integrate the judicial exception into a practical application.
Conclusion
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/T.P.K./Examiner, Art Unit 3696
/MATTHEW S GART/Supervisory Patent Examiner, Art Unit 3696