DETAILED ACTION
Claim 1-8, 10-17, 19-22 are presented for examination. Claims 1-3, 6, 10-13, 15, 19 are amended. Claim 18 is cancelled. Claim 22 is added.
This office action is in response to remarks entered on 10/22/2025.
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 1-8, 10-17, 19-22 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Regarding Claim 1:
Step 1 – Is the claim directed to a process, machine, manufacture, or composition of
matter? – Yes, the claim is directed to a process (a method).
Step 2A – Prong 1 – Is the claim directed to a law of nature, a natural phenomenon
(product of nature) or an abstract idea? – Yes, the claim recites the abstract ideas:
generating a quality score for each record of the record set based on application of the trained model to each record of the record set - This limitation is directed to the generation/calculation of a quality score, which is a mathematical calculation, being a mathematical concept (mathematical relationships, mathematical formulas or equations, and mathematical calculations [see MPEP 2106.04(a)(2)]). The application of the trained model is discussed next at Prong 2.
calculating, for the record set, a first data quality index based on averaging the quality scores for each record of the record set - This limitation is directed to calculating a quality index, being a mathematical concept (mathematical relationships, mathematical formulas or equations, and mathematical calculations [see MPEP 2106.04(a)(2)]).
reapplying the trained model to each record of the processed record set to generate a revised quality score for each record of the processed record set based on application of the trained model to each record of the processed record set - This limitation is directed to the generation/calculation of an additional/revised quality score, which is another mathematical calculation, being a mathematical concept (mathematical relationships, mathematical formulas or equations, and mathematical calculations [see MPEP 2106.04(a)(2)]). The re-application of the trained model is discussed next at Prong 2.
calculating, for the processed record set, a second data quality index based on averaging the quality score for each record of the processed record set - This limitation is directed to calculating an additional quality index, being a mathematical concept (mathematical relationships, mathematical formulas or equations, and mathematical calculations [see MPEP 2106.04(a)(2)]).
determining whether to modify one or more record operations or maintain application of the one or more record operations based on a comparison of the first data quality index for the record set and the second data quality index for the processed record set - This limitation is directed to the abstract idea of a mental process (concepts performed in the human mind, including observation and evaluation [see MPEP 2106.04(a)(2) III. C.]). Comparing quality indices mirrors the cognitive activity of a person observing the indices, evaluating them, and making a conclusive judgment about their differences. It is a mental process, as it falls in the same category as observations, evaluations, judgments, and opinions [see MPEP 2106.04(a)(2) III].
Step 2A – Prong 2 – Does the claim recite additional elements that integrate the judicial
exception into a practical application? – No, there are no additional elements that integrate the judicial exception into a practical application. The additional elements:
training a model based on a first set of approved records and a second set of declined records, where the first set of records and the second set of records each comprise a plurality of records - This limitation recites the training of a model at a high level of generality; therefore, it amounts to no more than mere instructions to apply the exception using a generic computer component [see MPEP 2106.05(f)] and fails to integrate the judicial exception into a practical application.
applying the trained model to each record of a record set of interest - This limitation recites the application of a model at a high level of generality; therefore, it amounts to no more than mere instructions to apply the exception using a generic computer component [see MPEP 2106.05(f)] and fails to integrate the judicial exception into a practical application.
generating a quality score for each record of the record set based on application of the trained model to each record of the record set- This limitation further recites the application of a model at a high level of generality; therefore, it amounts to no more than mere instructions to apply the exception using a generic computer component [see MPEP 2106.05(f)] and fails to integrate the judicial exception into a practical application.
applying one or more record operations to the record set to create a processed record set - This limitation is directed to manipulating data/records, which is not an inventive concept because it is an insignificant extra-solution activity [see MPEP 2106.05(g)] and fails to integrate the judicial exception into a practical application.
reapplying the trained model to each record of the processed record set to generate a revised quality score for each record of the processed record set based on application of the trained model to each record of the processed record set - This limitation recites the application of a model at a high level of generality; therefore, it amounts to no more than mere instructions to apply the exception using a generic computer component [see MPEP 2106.05(f)] and fails to integrate the judicial exception into a practical application.
Step 2B – Does the claim recite additional elements that amount to significantly more
than the judicial exception? – No, there are no additional elements that amount to significantly more than the judicial exception. The additional elements:
training a model based on a first set of approved records and a second set of declined records, where the first set of records and the second set of records each comprise a plurality of records - This limitation recites the training of a model at a high level of generality; therefore, it amounts to no more than mere instructions to apply the exception using a generic computer component [see MPEP 2106.05(f)] and fails to amount to significantly more than the judicial exception.
applying the trained model to each record of a record set of interest - This limitation recites the application of a model at a high level of generality; therefore, it amounts to no more than mere instructions to apply the exception using a generic computer component [see MPEP 2106.05(f)] and fails to amount to significantly more than the judicial exception.
generating a quality score for each record of the record set based on application of the trained model to each record of the record set- This limitation recites the application of a model at a high level of generality; therefore, it amounts to no more than mere instructions to apply the exception using a generic computer component [see MPEP 2106.05(f)] and fails to amount to significantly more than the judicial exception.
applying one or more record operations to the record set to create a processed record set - This limitation is directed to the activity of data manipulation, which is not an inventive concept because it is an insignificant extra-solution activity [see MPEP 2106.05(d)(II)] and fails to amount to significantly more than the judicial exception. The courts have found limitations directed to manipulating information electronically, recited at a high level of generality, to be well-understood, routine, and conventional [See MPEP § 2106.05(d)(II), “receiving or transmitting data over a network,” "electronic record keeping,” and "storing and retrieving information in memory.”].
reapplying the trained model to each record of the processed record set to generate a revised quality score for each record of the processed record set based on application of the trained model to each record of the processed record set - This limitation recites the re-application of a model at a high level of generality; therefore, it amounts to no more than mere instructions to apply the exception using a generic computer component [see MPEP 2106.05(f)] and fails to amount to significantly more than the judicial exception.
Regarding Claim 2:
Step 1 – Is the claim directed to a process, machine, manufacture, or composition of matter? – Yes, the claim is directed to a process (a method).
Step 2A – Prong 1 – Is the claim directed to a law of nature, a natural phenomenon (product of nature) or an abstract idea? – Yes, the claim recites the abstract idea:
modifying the one or more record operations in response to the second data quality index for the processed record set being less than the first data quality index for the record set - This limitation is directed to the abstract idea of a mental process (concepts performed in the human mind, including observation and evaluation [see MPEP 2106.04(a)(2) III. C.]). Modifying a record operation based on a quality index mirrors the cognitive activity of a person observing the operation, evaluating it, and making a conclusive decision about why it should be changed. It is a mental process, as it falls in the same category as observations, evaluations, judgments, and opinions [see MPEP 2106.04(a)(2) III].
Step 2A – Prong 2 and Step 2B– Does the claim recite additional elements that integrate the judicial exception into a practical application? – Yes, this limitation also recites data manipulation, which is not an inventive concept because it is an insignificant extra-solution activity [see MPEP 2106.05(d)(II)] and fails to amount to significantly more than the judicial exception. The courts have found limitations directed to manipulating information electronically, recited at a high level of generality, to be well-understood, routine, and conventional [See MPEP § 2106.05(d)(II), “receiving or transmitting data over a network,” "electronic record keeping,” and "storing and retrieving information in memory.”].
Regarding Claim 3:
Step 1 – Is the claim directed to a process, machine, manufacture, or composition of
matter? – Yes, the claim is directed to a process (a method).
Step 2A – Prong 1 – Is the claim directed to a law of nature, a natural phenomenon
(product of nature) or an abstract idea? – Yes, the claim recites the abstract idea:
maintaining the one or more record operations in response to the first data quality index for the record set being less than or equal to the second data quality index for the processed record set - This limitation is directed to the abstract idea of a mental process (concepts performed in the human mind, including observation and evaluation [see MPEP 2106.04(a)(2) III. C.]). Maintaining a record operation based on a quality index mirrors the cognitive activity of a person observing the operation, evaluating it, and making a conclusive decision about why it should not be changed. It is a mental process, as it falls in the same category as observations, evaluations, judgments, and opinions [see MPEP 2106.04(a)(2) III].
Step 2A – Prong 2 and Step 2B– Does the claim recite additional elements that integrate the judicial exception into a practical application? – Yes, this limitation also recites maintaining/manipulating data, which is not an inventive concept because it is an insignificant extra-solution activity [see MPEP 2106.05(d)(II)] and fails to amount to significantly more than the judicial exception. The courts have found limitations directed to manipulating information electronically, recited at a high level of generality, to be well-understood, routine, and conventional [See MPEP § 2106.05(d)(II), “receiving or transmitting data over a network,” "electronic record keeping,” and "storing and retrieving information in memory.”].
Regarding Claim 4:
Step 1 – Is the claim directed to a process, machine, manufacture, or composition of
matter? – Yes, the claim is directed to a process (a method).
Step 2A – Prong 1 – Is the claim directed to a law of nature, a natural phenomenon
(product of nature) or an abstract idea? – No, the claim is not directed to an abstract idea.
Step 2A – Prong 2 – Does the claim recite additional elements that integrate the judicial exception into a practical application? – No, there are no additional elements that integrate the judicial exception into a practical application. The additional elements:
each record of the record set comprises a weight for each field in the record, each weight indicating a relative importance of the respective field relative to other fields of the record - This limitation amounts to merely indicating a field of use or technological environment [see MPEP 2106.05(h)] and fails to integrate the judicial exception into a practical application.
Step 2B – Does the claim recite additional elements that amount to significantly more
than the judicial exception? – No, there are no additional elements that amount to significantly more than the judicial exception. The additional elements:
each record of the record set comprises a weight for each field in the record, each weight indicating a relative importance of the respective field relative to other fields of the record - This limitation amounts to merely indicating a field of use or technological environment [see MPEP 2106.05(h)] and fails to amount to significantly more than the judicial exception.
Regarding Claim 5:
Step 1 – Is the claim directed to a process, machine, manufacture, or composition of
matter? – Yes, the claim is directed to a process (a method).
Step 2A – Prong 1 – Is the claim directed to a law of nature, a natural phenomenon
(product of nature) or an abstract idea? – Yes, the claim is directed to an algorithm, being a mathematical concept/ abstract idea.
Step 2A – Prong 2 – Does the claim recite additional elements that integrate the judicial exception into a practical application? – No, there are no additional elements that integrate the judicial exception into a practical application.
Step 2B – Does the claim recite additional elements that amount to significantly more than the judicial exception? – No, there are no additional elements that amount to significantly more than the judicial exception.
Regarding Claim 6:
Step 1 – Is the claim directed to a process, machine, manufacture, or composition of
matter? – Yes, the claim is directed to a machine (a system).
Step 2A – Prong 1 – Is the claim directed to a law of nature, a natural phenomenon
(product of nature) or an abstract idea? – Yes, the claim recites the abstract idea:
apply an ML model to the record to generate a quality score for the record - This limitation is directed to the abstract idea of a mathematical concept, as generating/calculating a score abouts to a calculation (mathematical relationships, mathematical formulas or equations, and mathematical calculations [see MPEP 2106.04(a)(2)]). The use of the ML model is discussed next at Prong 2.
average the quality score for each of the plurality of records to generate a first data quality index for the plurality of records - This limitation is directed to the abstract idea of a mathematical concept (mathematical relationships, mathematical formulas or equations, and mathematical calculations [see MPEP 2106.04(a)(2)]).
apply the ML model to each record of the plurality of processed records to generate a revised quality score for each record of the plurality of processed records based on application of the ML model to each record of the plurality of processed records - This limitation is directed to the generation/calculation of a revised quality score, which is a mathematical calculation, being a mathematical concept (mathematical relationships, mathematical formulas or equations, and mathematical calculations [see MPEP 2106.04(a)(2)]). The application of the ML model is discussed next at Prong 2.
calculate, for the plurality of processed records, a second data quality index based on averaging the quality score for each record of the plurality of processed records- This limitation is directed to calculating a quality index, being a mathematical concept (mathematical relationships, mathematical formulas or equations, and mathematical calculations [see MPEP 2106.04(a)(2)]).
determine whether to modify the record operation or maintain application of the record operation based on a comparison of the first data quality index for the record set and the second data quality index for the plurality of processed records- This limitation is directed to the abstract idea of a mental process (concepts performed in the human mind, including observation and evaluation [see MPEP 2106.04(a)(2) III. C.]). Comparing quality indices mirrors the cognitive activity of a person observing the indices, evaluating them, and making a conclusive judgment about their differences. It is a mental process, as it falls in the same category as observations, evaluations, judgments, and opinions [see MPEP 2106.04(a)(2) III].
Step 2A – Prong 2 – Does the claim recite additional elements that integrate the judicial exception into a practical application? – No, there are no additional elements that integrate the judicial exception into a practical application. The additional elements:
a database of records comprising a plurality of records, each record including a plurality of record fields and a quality field - This limitation amounts to data stored in a database, which is considered an insignificant extra solution activity as it is merely storing data/records which is a conventional computer function, therefore, it does not impose meaningful limits on the claim such that it is not nominally or tangentially related to the invention per 2106.05(g);
a request interface configured to receive a request for a record from the database of records - This limitation recites receiving a request for a record, which is analogous to retrieving data from the database, which is considered an insignificant extra solution activity as it is merely retrieving data which is a conventional computer function, therefore, it does not impose meaningful limits on the claim such that it is not nominally or tangentially related to the invention per 2106.05(g);
a processor; a memory configured to stored instructions that, when executed by the processor, cause the processor to - This limitation recites a processor at a high level of generality; therefore, it amounts to no more than mere instructions to apply the exception using a generic computer component [see MPEP 2106.05(f)] and fails to integrate the judicial exception into a practical application.
retrieve the plurality of records stored in the database - This limitation recites retrieving data from the database, which is considered an insignificant extra solution activity as it is merely retrieving data which is a conventional computer function, therefore, it does not impose meaningful limits on the claim such that it is not nominally or tangentially related to the invention per 2106.05(g);
for each record: apply an ML model to the record to generate a quality score for the record - This limitation further recites the application of a model at a high level of generality; therefore, it amounts to no more than mere instructions to apply the exception using a generic computer component [see MPEP 2106.05(f)] and fails to integrate the judicial exception into a practical application.
store the generated quality score in the quality field of the record; update the record in the plurality of records - This limitation amounts to storing and updating data, which is considered an insignificant extra solution activity as it is merely storing data/records which is a conventional computer function, therefore, it does not impose meaningful limits on the claim such that it is not nominally or tangentially related to the invention per 2106.05(g);
apply a record operation to the plurality of records to generate a plurality of processed records- This limitation is directed to manipulating data/records, which is not an inventive concept because it is an insignificant extra-solution activity [see MPEP 2106.05(g)] and fails to integrate the judicial exception into a practical application.
Step 2B – Does the claim recite additional elements that amount to significantly more than the judicial exception? – No, there are no additional elements that amount to significantly more that the judicial exception. The additional elements:
a database of records comprising a plurality of records, each record including a plurality of record fields and a quality field - This limitation recites storing data which amounts to storing and retrieving information in memory, further considered well-understood, routine and conventional under MPEP 2106.05(d) II (iv).
a request interface configured to receive a request for a record from the database of records - This limitation recites retrieving data which amounts to storing and retrieving information in memory, further considered well-understood, routine and conventional under MPEP 2106.05(d) II (iv).
a processor; a memory configured to stored instructions that, when executed by the processor, cause the processor to - This limitation recites a processor at a high level of generality; therefore, it amounts to no more than mere instructions to apply the exception using a generic computer component [see MPEP 2106.05(f)] and fails to amount to significantly more than the judicial exception.
retrieve the plurality of records stored in the database - This limitation recites retrieving data which amounts to storing and retrieving information in memory, further considered well-understood, routine and conventional under MPEP 2106.05(d) II (iv).
for each record: apply an ML model to the record to generate a quality score for the record - This limitation recites the application of a model at a high level of generality; therefore, it amounts to no more than mere instructions to apply the exception using a generic computer component [see MPEP 2106.05(f)] and fails to amount to significantly more than the judicial exception.
store the generated quality score in the quality field of the record; update the record in the plurality of records - This limitation recites storing data which amounts to storing and retrieving information in memory, further considered well-understood, routine and conventional under MPEP 2106.05(d) II (iv).
apply a record operation to the plurality of records to generate a plurality of processed records- This limitation is directed to the activity of data manipulation, which is not an inventive concept because it is an insignificant extra-solution activity [see MPEP 2106.05(d)(II)] and fails to amount to significantly more than the judicial exception. The courts have found limitations directed to manipulating information electronically, recited at a high level of generality, to be well-understood, routine, and conventional [See MPEP § 2106.05(d)(II), “receiving or transmitting data over a network,” "electronic record keeping,” and "storing and retrieving information in memory.”].
Regarding claims 7 and 8, although varying in scope, the limitations of claims 7 and 8 are substantially the same as the limitations of claims 4 and 5, respectively. Thus, claims 7 and 8 are rejected using the same reasoning and analysis as claims 4 and 5 above.
Regarding claims 10 and 11, although varying in scope, the limitations of claims 10 and 11 are substantially the same as the limitations of claims 2 and 3, respectively. Thus, claims 10 and 11 are rejected using the same reasoning and analysis as claims 2 and 3 above.
Regarding Claim 12:
Step 1 – Is the claim directed to a process, machine, manufacture, or composition of matter? – Yes, the claim is directed to a process (a method).
Step 2A – Prong 1 – Is the claim directed to a law of nature, a natural phenomenon (product of nature) or an abstract idea? – Yes, the claim recites the abstract idea:
determining whether the data set of records comprises a dataset quality index - This limitation is directed to the abstract idea of a mental process (concepts performed in the human mind, including observation and evaluation [see MPEP 2106.04(a)(2) III. C.]). Determining if a data set comprises a quality index mirrors the cognitive activity of a person observing the data set, evaluating it, and making a conclusive judgment about their observations. It is a mental process, as it falls in the same category as observations, evaluations, judgments, and opinions [see MPEP 2106.04(a)(2) III].
upon a determination that the data set of records comprises the data set quality index, applying the record process to the data set of records to generate a processed data set based on the data set comprising the data set quality index, wherein the data set quality index has been calculated based on record set quality indices for records of the data set of records generated by applying a trained machine learning (ML) model to the records of the data set of records - This limitation is directed to the abstract idea of a mental process (concepts performed in the human mind, including observation and evaluation [see MPEP 2106.04(a)(2) III. C.]). Determining if data set of records comprises or not the data set quality index mirrors the cognitive activity of a person observing the records, evaluating them, and making a conclusive judgment about the inclusion of the quality index. It is a mental process, as it falls in the same category as observations, evaluations, judgments, and opinions [see MPEP 2106.04(a)(2) III]. Further, the statement about the data set quality index being calculated is directed to mathematical calculations as it explicitly recites the previous calculation of this said index, being a mathematical concept (mathematical relationships, mathematical formulas or equations, and mathematical calculations [see MPEP 2106.04(a)(2)]).
calculate a processed data set quality index for the processed data set based on the revised record set quality indices - This limitation is directed to calculating another quality index, being a mathematical concept (mathematical relationships, mathematical formulas or equations, and mathematical calculations [see MPEP 2106.04(a)(2)]).
comparing the data set quality index and the processed data set quality index - This limitation is directed to the abstract idea of a mental process (concepts performed in the human mind, including observation and evaluation [see MPEP 2106.04(a)(2) III. C.]). Comparing quality indices mirrors the cognitive activity of a person observing the indices, evaluating them, and making a conclusive judgment about their differences. It is a mental process, as it falls in the same category as observations, evaluations, judgments, and opinions [see MPEP 2106.04(a)(2) III].
determining whether to modify the record process or maintain application of the record process to the data set of records based on a comparison of the data set quality index for the original record set - This limitation is directed to the abstract idea of a mental process (concepts performed in the human mind, including observation and evaluation [see MPEP 2106.04(a)(2) III. C.]). Comparing quality indices mirrors the cognitive activity of a person observing the indices, evaluating them, and making a conclusive judgment about their differences. It is a mental process, as it falls in the same category as observations, evaluations, judgments, and opinions [see MPEP 2106.04(a)(2) III].
Step 2A – Prong 2 – Does the claim recite additional elements that integrate the judicial exception into a practical application? – No, there are no additional elements that integrate the judicial exception into a practical application. The additional elements:
receiving a record process to apply to a data set of records stored in a database - This limitation is directed to the activity of data gathering, which is not an inventive concept because it is an insignificant extra-solution activity [see MPEP 2106.05(g)] and fails to integrate the judicial exception into a practical application.
upon a determination that the data set of records comprises the data set quality index, applying the record process to the data set of records to generate a processed data set based on the data set comprising the data set quality index, wherein the data set quality index has been calculated based on record set quality indices for records of the data set of records generated by applying a trained machine learning (ML) model to the records of the data set of records - This limitation is directed to processing/manipulating records in response to a determination (mental process), which is not an inventive concept because it is an insignificant extra-solution activity [see MPEP 2106.05(g)] and fails to integrate the judicial exception into a practical application.
reapplying the trained ML model to the records of the processed data set to generate revised record set quality indices - This limitation recites the reapplication of a model at a high level of generality; therefore, it amounts to no more than mere instructions to apply the exception using a generic computer component [see MPEP 2106.05(f)] as it is merely used as a tool to perform an existing process (generating data) and fails to integrate the judicial exception into a practical application.
Step 2B – Does the claim recite additional elements that amount to significantly more
than the judicial exception? – No, there are no additional elements that amount to significantly more than the judicial exception. The additional elements:
receiving a record process to apply to a data set of records stored in a database - This limitation is directed to the activity of data gathering, which is not an inventive concept because it is an insignificant extra-solution activity [see MPEP 2106.05(d)(II)] and fails to amount to significantly more than the judicial exception. The courts have found limitations directed to obtaining and storing information electronically, recited at a high level of generality, to be well-understood, routine, and conventional [See MPEP § 2106.05(d)(II), “receiving or transmitting data over a network”].
upon a determination that the data set of records comprises the data set quality index, applying the record process to the data set of records to generate a processed data set based on the data set comprising the data set quality index, wherein the data set quality index has been calculated based on record set quality indices for records of the data set of records generated by applying a trained machine learning (ML) model to the records of the data set of records - This limitation is directed to the activity of data manipulation, which is not an inventive concept because it is an insignificant extra-solution activity [see MPEP 2106.05(d)(II)] and fails to amount to significantly more than the judicial exception. The courts have found limitations directed to manipulating information electronically, recited at a high level of generality, to be well-understood, routine, and conventional [See MPEP § 2106.05(d)(II), “receiving or transmitting data over a network,” "electronic record keeping,” and "storing and retrieving information in memory.”].
reapplying the trained ML model to the records of the processed data set to generate revised record set quality indices - This limitation recites the reapplication of a model at a high level of generality; therefore, it amounts to no more than mere instructions to apply the exception using a generic computer component [see MPEP 2106.05(f)] as it is merely used as a tool to perform an existing process (generating data) and fails to integrate the judicial exception into a practical application.
Regarding claims 13-16, although varying in scope, the limitations of claims 13-16 are substantially the same as the limitations of claims 2-5, respectively. Thus, claims 13-16 are rejected using the same reasoning and analysis as claims 2-5 above.
Regarding Claim 17:
Step 1 – Is the claim directed to a process, machine, manufacture, or composition of matter? – Yes, the claim is directed to a process (a method).
Step 2A – Prong 1 – Is the claim directed to a law of nature, a natural phenomenon (product of nature) or an abstract idea? – Yes
generating the data set quality index for the data set of records - This limitation is directed to generating/calculating a quality index, which is the calculation of a value being considered a mathematical concept.
Step 2A – Prong 2 – Does the claim recite additional elements that integrate the judicial exception into a practical application? – No, there are no additional elements that integrate the judicial exception into a practical application.
Step 2B – Does the claim recite additional elements that amount to significantly more than the judicial exception? – No, there are no additional elements that amount to significantly more than the judicial exception.
Regarding Claim 19:
Step 1 – Is the claim directed to a process, machine, manufacture, or composition of matter? – Yes, the claim is directed to a process (a method).
Step 2A – Prong 1 – Is the claim directed to a law of nature, a natural phenomenon (product of nature) or an abstract idea? – Yes, the claim recites the abstract idea:
averaging the record set quality indices for each record of the data set, wherein the data set quality index comprises the average of the record set quality indices for each record of the data set - This limitation is directed to the abstract idea of a mathematical concept (mathematical relationships, mathematical formulas or equations, and mathematical calculations [see MPEP 2106.04(a)(2)]).
Step 2A – Prong 2 – Does the claim recite additional elements that integrate the judicial exception into a practical application? – No, there are no additional elements that integrate the judicial exception into a practical application.
Step 2B – Does the claim recite additional elements that amount to significantly more than the judicial exception? – No, there are no additional elements that amount to significantly more than the judicial exception.
Regarding Claim 20:
Step 1 – Is the claim directed to a process, machine, manufacture, or composition of matter? – Yes, the claim is directed to a process (a method).
Step 2A – Prong 1 – Is the claim directed to a law of nature, a natural phenomenon (product of nature) or an abstract idea? – No, the claim is not directed to an abstract idea.
Step 2A – Prong 2 – Does the claim recite additional elements that integrate the judicial exception into a practical application? – No, there are no additional elements that integrate the judicial exception into a practical application. The additional elements:
the processed data set quality index reflects an ML output probability reflecting validity or invalidity of a record - This limitation amounts to merely indicating a field of use or technological environment [see MPEP 2106.05(h)] and fails to integrate the judicial exception into a practical application.
Step 2B – Does the claim recite additional elements that amount to significantly more than the judicial exception? – No, there are no additional elements that amount to significantly more than the judicial exception.
the processed data set quality index reflects an ML output probability reflecting validity or invalidity of a record - This limitation amounts to merely indicating a field of use or technological environment [see MPEP 2106.05(h)] and fails to amount to significantly more than the judicial exception.
Regarding Claim 21:
Step 1 – Is the claim directed to a process, machine, manufacture, or composition of matter? – Yes, the claim is directed to a system.
Step 2A – Prong 1 – Is the claim directed to a law of nature, a natural phenomenon (product of nature) or an abstract idea? – No.
Step 2A – Prong 2 and Step 2B– Does the claim recite additional elements that integrate the judicial exception into a practical application? – Yes,
wherein the record operation comprises a record cleansing operation, and wherein modifying the record operation comprises determining an alternative source of information with which to populate missing fields for one or more records of the plurality of processed records- This limitation recites data manipulation, which is not an inventive concept because it is an insignificant extra-solution activity [see MPEP 2106.05(d)(II)] and fails to amount to significantly more than the judicial exception. The courts have found limitations directed to manipulating information electronically, recited at a high level of generality, to be well-understood, routine, and conventional [See MPEP § 2106.05(d)(II), “receiving or transmitting data over a network,” "electronic record keeping,” and "storing and retrieving information in memory.”].
Regarding Claim 22, although varying in scope, the limitations of claim 22 are substantially the same as the limitations of claim 21. Thus, claim 22 is rejected using the same reasoning and analysis as claim 21 above.
Examiner’s comments
For claims 1-8, 10-17, 19-22, no art rejection is made for these claims, they are only rejected under 35 USC 101 as explained above in this office action.
Response to Arguments
Applicant's arguments filed 10/22/2025 have been fully considered.
In reference to Applicant’s arguments:
- Claim rejections under 35 USC 112.
Examiner’s response:
Rejections are withdrawn in view of amendments and applicant’s arguments.
In reference to Applicant’s arguments:
- Claim rejections under 35 USC 101.
Examiner’s response:
Examiner respectfully disagrees. After careful reconsideration, Examiner still understands that the claims are directed to a judicial exception without significantly more.
First, Applicant points to USPTO’s 2024 updated guidance stating “A claim does not recite a mathematical concept (i.e, the claim limitation do not fall within the mathematical concept grouping) if it is only based on or involves a mathematical concept” and asserts the claims do not recite mathematical concept, however, Examiner respectfully disagrees. After careful reconsideration, Examiner still concludes the limitations do recite mathematical concepts as they explicitly recite mathematical calculations. For example, the limitation “generating a quality score for each record of the record set based on application of the trained model to each record of the record set” is directed to the generation/calculation of a quality score under broadest reasonable interpretation, as a score being generated is a score being calculated. Examiner points to MPEP 2106.04 (a)(2) which states “It is important to note that a mathematical concept need not be expressed in mathematical symbols, because "[w]ords used in a claim operating on data to solve a problem can serve the same purpose as a formula"”; therefore, even though the generation of the score is not expressed in a mathematical formula, the objective of this limitation is directed to the calculation/generation of the score, being a mathematical concept.
Second, Applicant asserts that the determination operation cannot be performed manually, however, Examiner respectfully disagrees. Based on the broadest reasonable interpretation of the limitation “determining whether to modify one or more record operations or maintain application of the one or more record operations based on a comparison of the first data quality index for the record set and the second data quality index for the processed record set”, the limitation is merely stating a comparison between two indices, which reasonably amounts to an observation and evaluation steps, in order to determine if a modification is needed, which reasonably amounts to a judgement call.
Third, Applicant points to MPEP 2106.04 (a)(1)(viii) which is an example of a claim that do not recite an abstract idea and asserts that independent claim 1 of the present application similarly recites limitations/features regarding training a model. Examiner respectfully would like to clarify that this example is found eligible because it does not recite an abstract idea at all (none of the limitations are directed to an abstract idea), however, the claims in the instant application does recite the abstract ideas of Mental Processes and Mathematical Concepts, as explained above. The training limitation found in the current claims is not directed to an abstract idea, as it is addressed under Step 2A: Prong 2 and Step 2B, as explained above in this office action. Applicant further asserts that paragraphs [0010-0012] explain why the training of the model is important, however, no specific training of the model is explained in order to reasonably conclude that this training of the model provides an improvement to the technology, as it merely recites the training of a model to apply a judicial exception as it recites no more than an idea of a solution or outcome. Applicant further asserts that the limitation "determining whether to modify one or more record operations or maintain application of the one or more record operations based on a comparison of the first data quality index for the record set and the second data quality index for the processed record set" is a realization of improvement to a technology or operation of a computer that is used to process/analyze data records to determine how to treat/access those data records based on their quality, however, Examiner respectfully disagrees. Examiner points to MPEP 2106.05 (a) which states “It is important to note, the judicial exception alone cannot provide the improvement. The improvement can be provided by one or more additional elements”, and this limitation amounts to a comparison between two indices, which reasonably amounts to an observation and evaluation steps. The main point of this limitation is directed to the determination, not to the modification; therefore, since no modification is actually described in the limitation in order to potentially reflect an improvement or practical application, the limitation reasonably amounts just to a judgement call (determine if the modification should be done or not, without actually performing it). Therefore, this limitation cannot provide an improvement to a technology or operation of a computer. Independent claims 6 and 12 are still rejected based on the similar rationale as claim 1 as being analogous claims.
Rejections are still maintained.
In reference to Applicant’s arguments:
- Claim rejections under 35 USC 103.
Examiner’s response:
Rejections are withdrawn in view of amendments and applicant’s arguments.
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.
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/LUIS A SITIRICHE/Primary Examiner, Art Unit 2126