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 .
Priority
Acknowledgment is made of applicant’s claim for priority to Provisional Application 63/080912, filed on September 21, 2020.
Status of Claims
Claims 1-21 were rejected in the Non-Final Office action mailed on 03/19/2025. Applicant’s amended claimset, entered on 09/18/2025, amended Claim 21 and canceled Claims 1-20. Herein this Final Office Action, Claim 21 is rejected.
The supplemental reply filed on 03/16/2026 was not entered because supplemental replies are not entered as a matter of right except as provided in 37 CFR 1.111(a)(2)(ii). The supplemental reply is clearly not limited to placement of the application in condition for allowance, as discussed in greater detail below.
Response to Arguments
Applicant’s arguments filed 03/16/2026, with respect to Supplemental Amendments, have been fully considered and are not persuasive. Examiner does not agree, and the Supplemental Amendments have not been entered.
37 C.F.R. 1.111(a)(2)(i) states “A reply that is supplemental to a reply that is in compliance with § 1.111(b) will not be entered as a matter of right except as provided in paragraph (a)(2)(ii) of this section. The Office may enter a supplemental reply if the supplemental reply is clearly limited to: . . . (C) Placement of the application in condition for allowance; . . .” See also MPEP 714.I.F.
By their very nature, the addition of dependent claims cannot place the “application” in condition for allowance, as the independent claim would remain rejected. Applicant is reminded that dependent claims, that would be allowable if rewritten as an independent claim, are objected to under MPEP 608.01(n).V. (“If the base claim is rejected, the dependent claim should be objected to rather than rejected, if it is otherwise allowable.”).
Additionally, Applicants arguments (Pages 5-10) make no mention as to the amendments to Claim 21 in the supplemental Claimset, which differs from the amended Claim 21 submitted on 09/18/2025. Further, Page 1 of the request for entry of the Supplemental Amendment explicitly states that the purpose of the supplemental amendments is “to add additional dependent claims for consideration during examination.” Therefore, in addition to not complying with 37 C.F.R. 1.111(a)(2)(i), there is confusion as to which Claim 21 was intended to be submitted, and whether the supplemental claimset would comply with 37 C.F.R. 1.121(c) (“The claim listing, including the text of the claims, in the amendment document will serve to replace all prior versions of the claims, in the application.”) (Emphasis added).
Finally, Examiner notes that the burden of examining the “mere eight (8) proposed claims” (See Page 5 of arguments) is immaterial in the supplemental amendments not being entered. Applicant should understand that the burden of examining eight new dependent claims, each with different features, is substantially greater than, for example, examining a supplemental amendment that (1) cancels a claim or (2) corrects a typographical error. See 37 C.F.R. 1.111(a)(2)(i).
Applicant’s arguments filed 09/18/2025, with respect to Rejections under 35 U.S.C. 101 for Claim 21, have been fully considered and are not persuasive.
On Page 4 (Section II), Applicant argues that the rejection of Claim 21 under 35 U.S.C. 101 has been overcome. Examiner does not agree as discussed in greater detail below.
On Pages 5-6 (Section II.A), Applicant argues that the “override” mechanism of the “exceptions” is not an abstract idea, but “[b]y embedding exceptions into the core conformance analysis, the method transforms the booking system from a passive tool into an active gatekeeper that enforces policy dynamically and automatically at the point of transaction. This is a practical application of the policy rules because it requires the computer to execute a technical process that changes the output of the system and the availability of transactions.” Applicant further argues that “(i) an override mechanism for managing exceptions, and (ii) conformance of the travel inventory with the corporate travel policy so that only in-policy results are presented to the traveler” is a “technological solution for ensuring corporate travel policy compliance during booking in real time.” Applicant further analogizes the claims to DRR Holdings, SiRF Tech., and Trading Technologies. Examiner does not agree.
Examiner responds that first, the “exception” and “override[[s]],” are not necessarily a part of the “policy” claimed. Claim 21 recites “at least one of a travel criteria and an exception” (emphasis added), and therefore the claim could be embodied without any “exception.”
Examiner responds that an “exception” to a rule, is still a part of the rule, i.e. a sub-rule. The use of an “exception that overrides the travel criteria,” merely provides an additional rule, e.g. { IF [no exception], THEN [travel criteria], ELSE [no travel criteria]; }. Such interpretation is supported by Specification ¶83 (“A travel policy consists of a base policy rule and (optionally) exceptions that allow administrators to apply unique rules based on more specific travel criteria.” (Emphasis added.)). Thus, the “exception” is a part of the abstract idea.
Examiner further responds that enforcing a corporate travel policy is not a technical problem rooted in computer networks, but a business problem, i.e. a part of the abstract idea. Applicant’s claim does not describe a level of detail of technical features similar to DDR Holdings. See MPEP 2106.05(a).I (“Examples that the courts have indicated may show an improvement in computer-functionality: i. A modification of conventional Internet hyperlink protocol to dynamically produce a dual-source hybrid webpage, DDR Holdings, 773 F.3d at 1258-59, 113 USPQ2d at 1106-07; . . .”). Similarly, the claims are not analogous to the improvements of SiRF Tech. and Trading Technologies.
On Pages 7-8 (Section II.B), Applicant argues that “Claim 21 also represents a specific improvement to the functioning of booking systems and computer-based policy enforcement. Conventional booking platforms either (i) apply rigid criteria that exclude any result outside of a baseline rule set, or (ii) allow nonconforming bookings to proceed, leaving reconciliation and exception handling to manual review after the transaction. . . The claimed invention improves on this technological shortcoming by requiring the system itself to process not only standard criteria but also exceptions that explicitly override those criteria. This forces the computer to execute layered conditional logic, where the presence of a qualifying exception can change the result of the conformance analysis in real time.” Applicant further asserts that the system “actively structure[s] policy data,” which enables a single view that accurately reflects the policy. Applicant argues that the “user interface” is improved by displaying a plurality of relevant information, “which are filtered though the exception-aware analysis,” “in one consolidated format.” “In short, the override framework transforms the booking system into a more reliable, efficient, and intelligent platform, reducing errors, eliminating reconciliation delays, and directly improving the operation of the computer system as a tool for policy enforcement.” Applicant further argues that “The invention also provides a technical improvement to computer functionality by reducing unnecessary processing and eliminating extraneous outputs. . . .” Finally, Applicant cites Enfish, McRO, and Ancora Techs., arguing analogous patent eligible improvements. Examiner does not agree.
Examiner responds that the “exceptions” are not a necessary component of the claim, and are a part of the abstract idea. Therefore, the claimed “exceptions” do not provide a patent eligible improvement under MPEP 21016.05(a).
Examiner responds, generally, that the original disclosure fails to explain why the flaws of the conventional system arise from a “technical problem,” i.e. are flaws in technology, not merely flaws in the conventional abstract idea. See MPEP 2106.05(a).I (“Examples that the courts have indicated may not be sufficient to show an improvement in computer-functionality: . . . iii. Mere automation of manual processes, . . .”). “Layered conditional logic” is a part of the abstract idea, e.g. its commonly understood that most social rules have exceptions. The execution of this logic on a computer is mere application of the abstract idea under MPEP 2106.05(f). The claims and original disclosure are silent on actual data structure, e.g. stack, string, or tree. Instead, the claims address what the data represents, i.e. the information of the data. Instead, the computer merely executes a corporate policy to organize business offers (e.g. flights). The claimed user interface displays “at least one of” a variety of related information “in a text, graphical or tabular format.” Thus, the claims provide a broad form of formats to display the broad types of related information, further supporting Examiner’s determination of ineligibility under MPEP 2106.05(f).
Examiner responds that the purported improvements in technology are merely conclusory and the original disclosure fails to provide sufficient “technical explanation” under MPEP 2106.05(a). The asserted “more reliable, efficient, and intelligent platform, reducing errors, eliminating reconciliation delays, and directly improving the operation of the computer system as a tool for policy enforcement” “reducing unnecessary processing and eliminating extraneous outputs” are merely conclusory as they relate to improvements to the technology itself.
Examiner responds that the instant claims are distinguishable Enfish, McRO, and Ancora Techs.. The claims do not reference a self-referential table that improves how computers store and retrieve data as in Enfish. The claims are distinguished from McRO because computer animation is tied to computer technology, however a corporate travel policy and the booking of travel is human activity that exists outside of computer technology. Finally, the claims make no limitations regarding BIOS or specific computer components as to how any of the data is stored, like in Ancora Techs. Therefore, the rejection remains.
On Pages 9-10 (Section II.C), Applicant argues “Claim 21 as a whole recites significantly more. The combination of limitations importing a structured policy, applying criteria and exceptions with override logic, displaying the resulting conforming inventory in an integrated interface, and authorizing booking only if the exception-adjusted policy is satisfied - is not routine, generic, or conventional. The claimed process goes beyond merely automating a business practice and instead introduces a new structural framework that governs how the computer itself evaluates, filters, and authorizes transactions. This framework produces a tangible, technical result: the system itself decides, based on exception-aware analysis, whether a booking can proceed, thereby ensuring that only inventory conforming under both baseline rules and defined exceptions is available to the user. The claimed invention is therefore "significantly more" than the mere idea of applying rules to travel booking, because it specifies how the computer must be programmed to enforce an override structure that is not conventional or generic. Even assuming argument that the claim involves some abstract concepts (policy compliance, authorization), the recited technological features amount to "significantly more." The system (1) imports and applies policy rule sets, (2) enforces policy constraints and exceptions in real time, (3) automatically manages overrides, and (4) dynamically authorizes bookings directly on the provider's website only for conforming results. These are not generic computer functions but rather a specific combination of operations that solve the technological problem of implementing complex corporate policies in online booking environments.” Applicant argues that the claims provide an improvement to a user interface analogous to Core Wireless. Applicant argues that the claims provide a non-conventional solution that prevents non-conforming data from reaching the user, similar to the filtering in BASCOM. Applicant argues that the rules and exception based policy creates a technical architecture that improves booking efficiency similar to the distributed architecture that improved record aggregation in Amdocs. Examiner does not agree.
Examiner responds that the claim as a whole does not recite an improvement to technology, but merely uses the computer components as a tool in their ordinary capacity to apply the abstract idea. Therefore, the claims, when viewed as a whole, do not provide “significantly more” in Step 2B. The claim as a whole is directed to applying a policy (i.e. rules and exceptions) to flight options displayed. The claims provide a broad format and broad details regarding what exactly is being displayed, without significant limitation to the functionality of the computer or a sufficient technical explanation in the disclosure.
The claim recites “displaying via an application program interface (API) module on a website of the travel service provider by means of the non-transitory computer-readable medium in the text, graphical or tabular format the conforming travel inventory.” Using an API to display certain information by means of the non-transitory computer-readable medium on a website is nearly how every website operates, and the original disclosure supports this determination based on the level of technical detail included in discussing this feature. Therefore, the claim is distinguishable from Core Wireless, but is instead analogous to Trading Technologies as discussed in MPEP 2106.05(a).I (“Examples that the courts have indicated may not be sufficient to show an improvement in computer-functionality: . . . viii. Arranging transactional information on a graphical user interface in a manner that assists traders in processing information more quickly, Trading Technologies v. IBG LLC, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019).”).
The advantages of restricting the display to only certain travel options relates is a function of advertising (i.e. certain methods of organizing human activity) that exist outside of computer technology, e.g. a travel agent that knows the corporate travel policy could only provide offers to a corporate employee that comply with the travel policy. Additionally, the original disclosure fails to provide the necessary “technical explanation” for examiner to conclude a technical improvement. Therefore, the filtering of travel offers is distinguishable from the filtering of in BASCOM.
Finally, the claims are distinguishable from Amdocs because the claims do not provide a specific network architecture that provides an improvement, but instead describes a generic website, as discussed in the rejection section below. Therefore, the rejection remains.
Applicant’s arguments filed 09/18/2025, with respect to Rejections under 35 U.S.C. 103 for Claim 21, have been fully considered and are not persuasive.
On Page 11 (Section III), Applicant argues that Wilkinson does not teach aspects of the claim “with respect to when authorization, that is, when the resolution of the conformance of the travel inventory (i.e. search results) to the travel policy occurs.” Examiner does not agree, as discussed below.
On Pages 11-14 (Section III.A), Applicant argues that Wilkinson does not teach that a travel criterion of a corporate travel policy can be overridden by an exception. Applicant further cites to the disclosure providing examples of “an exception.” Examiner does not agree.
Examiner responds, first, that as discussed above and below, because the limitation states that “the corporate travel policy is based upon at least one of a travel criteria and an exception” (emphasis added), Wilkinson need not teach “an exception” to teach the claimed “corporate travel policy.” However, Wilkinson does teach this limitation.
Applicant is reminded that “THE WORDS OF A CLAIM MUST BE GIVEN THEIR ‘PLAIN MEANING’ UNLESS SUCH MEANING IS INCONSISTENT WITH THE SPECIFICATION” (MPEP 2111.01.I) and “IT IS IMPROPER TO IMPORT CLAIM LIMITATIONS FROM THE SPECIFICATION” (MPEP 2111.01.II). The claims make no mention as to the sequence of the computational operations, i.e. exactly how the exception is processed by the computer.
Specification ¶83 states “A travel policy consists of a base policy rule and (optionally) exceptions that allow administrators to apply unique rules based on more specific travel criteria.” (Emphasis added.). As discussed in greater detail below Wilkinson ¶44 teaches applying different rules based on different travel parameters, e.g. international vs domestic. The application of different rules teaches “a travel criteria and an exception, wherein the exception overrides the travel criteria.”
Examiner further notes that ¶44 shows “Travel policies will differ depending on factors such as the traveler, . . .” Thus, Wilkonson teaches that an exception can be based on who the traveler is.
On Pages 14-16 (Section III.B.), Applicant argues that Wilkinson teaches applying policy after generation of the results and showing out of policies result to the user. Applicant argues that Wilkinson doesn’t teach "analyzing via the data sharing module the travel inventory for conformance of the travel inventory with the corporate travel policy.” Examiner does not agree.
Examiner responds, again, with a reminder of the fundamentals of claim construction, including “THE WORDS OF A CLAIM MUST BE GIVEN THEIR ‘PLAIN MEANING’ UNLESS SUCH MEANING IS INCONSISTENT WITH THE SPECIFICATION” (MPEP 2111.01.I) and “IT IS IMPROPER TO IMPORT CLAIM LIMITATIONS FROM THE SPECIFICATION” (MPEP 2111.01.II). Claim 21 recites “. . . the steps of: importing . . . the corporate travel policy . . . ; analyzing . . . the travel inventory for conformance of the travel inventory with the corporate travel policy, . . . ; displaying . . . the conforming travel inventory, . . .; and authorizing the corporate traveler . . . to book the travel inventory . . .” The claim does not include any limitation as to what is displayed or generated before “displaying . . . the conforming travel inventory,” i.e. the claim is not limited to never “displaying” all inventory options, and would include a system that displays all inventory options, and then displays “the conforming travel inventory.”
Examiner responds that Wilkinson ¶45 states “It should be noted that “in-policy booking option” may include results that violate a company's travel policies.” (Emphasis added). Therefore, Wilkinson teaches that the system “may” utilize an exception, or may not utilize an exception.
Wilkinson teaches "analyzing via the data sharing module the travel inventory for conformance of the travel inventory with the corporate travel policy” as discussed in the rejection section below. Applicant is reminded that “the travel inventory” is given its broadest reasonable interpretation per MPEP 2111.
On Pages 16-19 (Section III.C.), Applicant argues that the remaining references do not correct the deficiencies of Wilkinson reference. Examiner holds this point moot, as Examiner did not agree with the deficiencies argued by Applicant.
On Page 20 (Section IV.), Applicant argues that the claims are allowable. Examiner does not agree. As discussed above and below, the rejections remain.
Claim Interpretation
Claim 21 recites “importing via a data sharing module the corporate travel policy, wherein the corporate travel policy is based upon at least one of a travel criteria and an exception, wherein the exception overrides the travel criteria” in the second paragraph. In light of the plain meaning of “at least one of,” the scope of the “corporate travel policy” includes a policy based solely upon “a travel criteria,” without any “exception[s].”
Examiner notes that the claim is given its broadest reasonable interpretation consistent with the specification per MPEP 2111. Examiner follows MPEP 2111.01.I, which states “Under a broadest reasonable interpretation (BRI), words of the claim must be given their plain meaning, unless such meaning is inconsistent with the specification. The plain meaning of a term means the ordinary and customary meaning given to the term by those of ordinary skill in the art at the relevant time.” Examiner frequently considers dictionaries, per MPEP 2111.01.III, such as www.merriam-webster.com, as part of determining the “ordinary and customary meaning” of several of the claimed terms, e.g. policy, exception, criteria, override, ect. Examiner suggests consultation of dictionaries, such as www.merriam-webster.com, and other resources in MPEP 2111.01.III, to better understand the scope of the claims submitted.
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 1-21 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Step 1
Claim 21 recites a method (i.e. a process). Therefore, Claim 21 falls within the one of the four statutory categories of invention of 35 U.S.C. 101.
Step 2A, Prong One
Independent Claim 21 recites the abstract idea of:
“. . . display a travel inventory that conforms to a corporate travel policy . . . in a text, graphical or tabular format enabling a corporate traveler to book directly with a travel service provider, the method comprising the steps of:
importing. . . the corporate travel policy, wherein the corporate travel policy is based upon at least one of a travel criteria and an exception, wherein the exception overrides the travel criteria;
analyzing . . . the travel inventory for conformance of the travel inventory with the corporate travel policy,
wherein such conformance analysis is based upon the travel criteria being at least one of a highest allowed cabin class option, a maximum allowed budget option, an allowed seat upgrade option, an allowed basic economy seat option, and an allowed refundable fare option, and the exception being an airline applicability choice and at least one of a flight duration condition, a flight route condition, a highest allowed cabin class option, a maximum allowed budget option, an allowed seat upgrade option, an allowed basic economy seat option, and an allowed refundable fare option;
displaying [by] the travel service provider . . . in the text, graphical or tabular format the conforming travel inventory,
wherein the text, graphical or tabular format displays data relating to at least one of a registration status of the corporate traveler in a travel management system, a corporate traveler profile, the corporate travel policy, a determination status of a conformity of at least one travel program of the travel service provider to the corporate travel policy, the travel inventory that conforms to the corporate travel policy, a corporate pricing for the travel inventory, a corporate form of payment method, a travel reservation, a travel advisory, and a report; and,
authorizing the corporate traveler, . . . at the time of the display [by] the travel service provider, to book the travel inventory directly [with] the travel service provider provided that the travel inventory is conforming with the corporate travel policy and thereby completing the travel booking process.”
The limitations stated above are processes/ functions that under broadest reasonable interpretation covers (1) importing a corporate travel policy, (2) analyzing travel inventory for conformity with policy, (3) basing conformance analysis on certain criteria, (4) displaying conforming inventory and other information, and (5) authorizing the traveler to book travel with provider, all of which are managing personal behavior by following rules and interacting between people (i.e. sending, receiving, and communicating certain information; and determining compliance with a corporate policy are at least “social activities” and “following rules or instructions”) and commercial or legal interactions (i.e. booking corporate travel are at least “marketing or sales activities or behaviors” and “business relations” and displaying travel options is at least “advertising”), which are certain methods of organizing human activity, an abstract idea, under MPEP 2106.04(a)(2)II. The mere the recitation of generic computer components (i.e., the “computer,” “a non-transitory computer-readable medium,” “a set of program modules,” “data sharing module,” “application program interface (API) module,” and “a website”) implementing the identified abstract idea does not take the claim out of the certain methods of organizing human activity grouping. MPEP 2106.04(d). If a claim limitation, under its broadest reasonable interpretation, covers “managing personal behavior or relationships or interactions between people” and “commercial or legal interactions” but for the recitation of generic computer components, then it falls in the certain methods of organizing human activity grouping of abstract ideas. MPEP 2106.04. Therefore, Claim 1 recites an abstract idea.
Step 2A, Prong Two
The judicial exception is not integrated into a practical application. Claim 1 as a whole amounts to: (i) merely invoking generic components as a tool to perform the abstract idea or “apply it” (or an equivalent) and (ii) generally links the use of a judicial exception to a particular technological environment or field of use. The claim recites the additional elements of:
(i) “computer,”
(ii) “a non-transitory computer-readable medium,”
(iii) “a set of program modules,”
(iv) “data sharing module,”
(v) “application program interface (API) module,” and
(vi) “a website.”
The additional elements of a (i) “computer” (¶36 shows “a computing device having a memory and a processor.” ¶38 shows “User devices such as, but not limited to, a desktop computer, a laptop computer, a mobile phone, a personal digital assistant, and the like.”), (ii) “a non-transitory computer-readable medium” ((¶36 shows “a computing device having a memory and a processor.” (Emphasis added).), (iii) “a set of program modules” (¶12 shows “a database in communication with the server is configured to store data related to, but not limited to, users or travelers, travel managers, companies, travel providers or travel agencies, and the corporate travel.” ¶36 shows “the database comprises one or more modules include, but not limited to, a login module, an application program interface (API) 105, a data sharing module or a transceiver 107, and an admin module 109.”), (iv) “data sharing module” (Fig. 1 and ¶40 shows “the data sharing module or a transceiver 107 is configured to share or transfer data related to the corporate travel to one or more expense providers 123, duty of care (DoC) 125, and also travel management center (TMC) 127.”), (v) “application program interface (API) module” (Fig. 1 and ¶40 shows “application program interface (API) 105.”), and (vi) “a website” (Fig. 7 and ¶¶78-79 shows a website.), are recited at a high-level of generality, such that, when viewed as whole/ordered combination (¶20, ¶24, and Fig. 1, 5A-5C, and 7), they amount to no more than mere instruction to apply the judicial exception using generic computer components or “apply it” (See MPEP 2106.05(f)).
The (i) “computer,” (ii) “a non-transitory computer-readable medium,” (iii) “a set of program modules,” (iv) “data sharing module,” (v) “application program interface (API) module,” and (vi) “a website,” when viewed as whole/ordered combination (¶20, ¶24, and Fig. 1, 5A-5C, and 7), does no more than generally link the use of the judicial exception to a particular technological environment or field of use (i.e. computer interfacing with a network) (See MPEP 2106.05(h)).
Accordingly, this additional element, when viewed as a whole/ordered combination (¶20, ¶24, and Fig. 1, 5A-5C, and 7), do not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Thus, the claim is directed to an abstract idea.
Step 2B
As discussed above with respect to Step 2A Prong Two, the additional element amounts to no more than: (i) “apply it” (or an equivalent) and (ii) generally link the use of a judicial exception to a particular technological environment or field of use, and are not a practical application of the abstract idea. The same analysis applies here in Step 2B, i.e., (i) merely invoking the generic components as a tool to perform the abstract idea or “apply it” (See MPEP 2106.05(f)) and (ii) generally linking the use of a judicial exception to a particular technological environment or field of use (See MPEP 2106.05(h)), does not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B.
Therefore, the additional elements of (i) “computer,” (ii) “a non-transitory computer-readable medium,” (iii) “a set of program modules,” (iv) “data sharing module,” (v) “application program interface (API) module,” and (vi) “a website,” do not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B. Thus, even when viewed as a whole/ordered combination (¶20, ¶24, and Fig. 1, 5A-5C, and 7), nothing in the claims adds significantly more (i.e., an inventive concept) to the abstract idea. Thus, the claim is ineligible.
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 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.
The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
1. Determining the scope and contents of the prior art.
2. Ascertaining the differences between the prior art and the claims at issue.
3. Resolving the level of ordinary skill in the pertinent art.
4. Considering objective evidence present in the application indicating obviousness or nonobviousness.
Claim 21 is unpatentable in light of US-20140278597-A1 (“Wilkinson” assigned to “Skydaddle LLC”) in view of US-20150134372-A1 (“Ruiz” assigned to “Amadeus SAS”).
Regarding Claim 21, Wilkinson teaches “A computer-implemented method executed by a set of program modules to display a travel inventory that conforms to a corporate travel policy on a non-transitory computer-readable medium in a text, graphical or tabular format enabling a corporate traveler to book directly with a travel service provider” (¶¶18-21 shows the system and method for booking corporate travel. ¶18 shows a “server computer.” ¶28 shows “Graphical user interface.” Fig. 4 teaches “a text, graphical or tabular format enabling a corporate traveler to book directly with a travel service provider.” See also ¶38 showing other computer embodiments.), the method comprising the steps of:
“importing via a data sharing module the corporate travel policy, wherein the corporate travel policy is based upon at least one of a travel criteria and an exception, wherein the exception overrides the travel criteria” (Fig. 1 and ¶44 shows “The search module 20 is implemented with a server computer having a computer memory or storage media storing a server process. The server process includes a search results process 26 that can produce from the entered search criteria sets of flights that can satisfy the query. The server process also includes a policy application process 28 which compares the search results 26 with the user's travel policies within travel policy database 29 to produce in-policy booking options. Travel policies relevant to travel management are also stored in the travel policy database 29.” (Emphasis added). Thus, Wilkinson teaches importing the travel policies from the “travel policy database 29.” See also ¶30 showing traveler profile information is passed on to the vendors. ¶44 shows “Travel policies include the company's preferences and policies with regard to how a travel search query may be resolved, which determines whether a search result is in-policy or out-of-policy. For example, a company may have: 1) a price tolerance above a lowest fare criteria; 2) specific supplier preference; and 3) limitations on what class flight can be booked for a given trip. Travel policies will differ depending on factors such as the traveler, the type of travel service, whether the service is domestic or international.” Thus, ¶44 teaches “the corporate travel policy is based upon at least one of a travel criteria and an exception, wherein the exception overrides the travel criteria” because there are additional variables used to determine the travel policy. For example, the policy for domestic service could teach the “travel criteria” and the policy for international service could teach the “exception,” which overrides the travel criteria, and vice versa.);
“analyzing via the data sharing module the travel inventory for conformance of the travel inventory with the corporate travel policy” (Fig. 1 and ¶44 shows “The search module 20 is implemented with a server computer having a computer memory or storage media storing a server process. The server process includes a search results process 26 that can produce from the entered search criteria sets of flights that can satisfy the query. The server process also includes a policy application process 28 which compares the search results 26 with the user's travel policies within travel policy database 29 to produce in-policy booking options. Travel policies relevant to travel management are also stored in the travel policy database 29.” (Emphasis added).),
“wherein such conformance analysis is based upon the travel criteria being at least one of a highest allowed cabin class option, a maximum allowed budget option, an allowed seat upgrade option, an allowed basic economy seat option, and an allowed refundable fare option, and the exception being an airline applicability choice and at least one of a flight duration condition, a flight route condition, a highest allowed cabin class option, a maximum allowed budget option, an allowed seat upgrade option, an allowed basic economy seat option, and an allowed refundable fare option” (¶45 shows “Typically (but not necessarily) an in-policy booking option includes at least a maximum price for a searched travel service. In some scenarios, an in-policy booking option may be a service class, such as ‘any midsize rental car,’ without a specific supplier or maximum price identified. Typically (but again not necessarily) in-policy booking option(s) includes one or more identified suppliers of travel services with whom travelers can complete the in-policy booking option. . . . Nevertheless, in this case, the ‘in-policy booking option’ 102 (shown in FIG. 4) is the policy criteria ‘FLIGHT SHOULD NOT EXCEED $375.’” ¶44 shows “Travel policies include the company's preferences and policies with regard to how a travel search query may be resolved, which determines whether a search result is in-policy or out-of-policy. For example, a company may have: 1) a price tolerance above a lowest fare criteria; 2) specific supplier preference; and 3) limitations on what class flight can be booked for a given trip. Travel policies will differ depending on factors such as the traveler, the type of travel service, whether the service is domestic or international.”);
“displaying via an application program interface (API) module on a website [embedded with] the travel service provider by means of the non-transitory computer-readable medium in the text, graphical or tabular format the conforming travel inventory” (¶47 shows “In some cases, the supplier is integrated through API or an embedded browser, but typically the user interface displays in-policy options with links to third party web sites where the in-policy options may be purchased.” (Emphasis added). Fig. 4, ¶23, and ¶¶44-45 shows a screen shot of a display of search results (i.e. the text, graphical or tabular format the conforming travel inventory).),
“wherein the text, graphical or tabular format displays data relating to at least one of a registration status of the corporate traveler in a travel management system, a corporate traveler profile, the corporate travel policy, a determination status of a conformity of at least one travel program of the travel service provider to the corporate travel policy, the travel inventory that conforms to the corporate travel policy, a corporate pricing for the travel inventory, a corporate form of payment method, a travel reservation, a travel advisory, and a report” (Fig. 4 shows:
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Fig. 4 above teaches displaying data “relating to” (emphasis added) at least one of a registration status of the corporate traveler in the travel management system (i.e. traveler’s name “John,” “Trip ID,” and policy information), a corporate traveler profile (i.e. traveler’s name “John,” “Trip ID,” and policy information), the corporate travel policy(i.e. traveler’s name “John,” “Trip ID,” and policy information), a determination status of a conformity of the at least one travel program of the at least one travel service provider to the corporate travel policy (i.e. traveler’s name “John,” “Trip ID,” and policy information), the travel inventory that conforms to the corporate travel policy (i.e. traveler’s name “John,” “Trip ID,” and policy information), a corporate pricing for the travel inventory (i.e. traveler’s name “John,” “Trip ID,” displayed price, and not to exceed price), a corporate form of payment method, a travel reservation (i.e. traveler’s name “John,” “Trip ID,” policy information, displayed price, and not to exceed price), a travel advisory, and a report (i.e. traveler’s name “John,” “Trip ID,” policy information, displayed price, and not to exceed price).); and,
“authorizing the corporate traveler, via the API module at the time of the display on the website [embedded with] the travel service provider, to book the travel inventory directly on the website of the travel service provider provided that the travel inventory is conforming with the corporate travel policy and thereby completing the travel booking process” (The broadest reasonable interpretation of “at the time of the direct booking” as related to this limitation includes a time of selecting a flight. Put another way, the processes of “booking,” as read in light of the specification could include searching for an offer, selecting an offer, approval of payment, updating airline system with booking, updating corporate system with booking, and receiving a receipt. The “time” of booking is not limited to a particular sub-process of booking. For Example, a “time of the direct booking” could include multiple clicks and navigations of search through checkout screens. Fig. 2 and ¶48 shows “Subsequent interaction of the traveler 610 with the data processing system is further explained in the decision tree of FIG. 2. If the traveler does not like the in-policy booking options presented at 62 as the results of a search, the traveler can modify the search, entering new travel search criteria 22 and generating a new trip record 34. If the traveler likes the option(s), and the company's travel policy requires the additional step of obtaining approval, then manual approval may be obtained at 64. In either case, either automatic or manual approval having been obtained, the trip is approved at 68.” Fig. 1-2 shows step “66” of “Does Travel Policy Allow Automatic approval?,” after “present results and referral links 44,” and before “Trip Approved 68.”).
Wilkinson does not explicitly teach, but Ruiz teaches that “the website [embedded with] the travel service provider” includes “the website of the travel service provider” (Abstract, Fig. 4-5, and ¶28 shows a “self-booking tool” that “applies specific user and/or corporate travel profiles to the search results” by, for example, deleting (or displaying with an indication of the conflict) search results conflicting with corporate travel policies. ¶24 shows that the initial search occurs on “a website associated with the online channel.” ¶6 shows “Online channels may also allow users to buy tickets directly from the airline.” ¶45 shows “Embodiments of the invention may extend management of corporate travel purchases to include online channels, such as online travel agency websites, meta-search websites, airline websites, hotel websites, car rental websites, or any other suitable service website. This may be accomplished by selectively capturing data relating to travel offerings displayed by the website, and enriching this data with the corporate policies and agreements provided by the travel booking system 50.” (Emphasis added). Therefore, at least ¶45 teaches that a display showing travel products in compliance with a company policy occurs on the direct website of the travel service provider.).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine Ruiz with Wilkinson because Ruiz teaches that customers receive several advantages (e.g. customers feel more comfortable using provider’s website) to booking directly on the provider’s website, improving user experience (¶¶1-9, ¶24, and ¶67). Thus, combining Ruiz with Wilkinson furthers the interest taught in Ruiz, and therefore, would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention.
Conclusion
THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
The following prior art made of record and not relied upon is considered pertinent to applicant's disclosure:
“Travel and Expense Policy” (“FM” April 2014, https://gateway.us.travelctm.com/fm/images-cms/FM-MMR-Corporate-Travel-and-Expense-Policy-4-14.pdf) shows a corporate travel policy that domestic travel should be economy class with exceptions including that the domestic leg of an international trip may be first class.
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/MATTHEW PARKER GOODMAN/Examiner, Art Unit 3628
/JESSICA LEMIEUX/Supervisory Patent Examiner, Art Unit 3626
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