Prosecution Insights
Last updated: April 19, 2026
Application No. 17/722,139

SYSTEMS AND METHODS FOR TRACKING CHAIN OF TITLE FOR REGISTERED INTERNET OF THINGS UNIVERSAL ID (IOT DEVICES)

Non-Final OA §101
Filed
Apr 15, 2022
Examiner
MONAGHAN, MICHAEL J
Art Unit
3629
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Somos Inc.
OA Round
5 (Non-Final)
36%
Grant Probability
At Risk
5-6
OA Rounds
3y 1m
To Grant
92%
With Interview

Examiner Intelligence

Grants only 36% of cases
36%
Career Allow Rate
46 granted / 126 resolved
-15.5% vs TC avg
Strong +56% interview lift
Without
With
+55.9%
Interview Lift
resolved cases with interview
Typical timeline
3y 1m
Avg Prosecution
37 currently pending
Career history
163
Total Applications
across all art units

Statute-Specific Performance

§101
39.3%
-0.7% vs TC avg
§103
32.7%
-7.3% vs TC avg
§102
11.0%
-29.0% vs TC avg
§112
14.3%
-25.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 126 resolved cases

Office Action

§101
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 . Continued Examination Under 37 CFR 1.114 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 September 29, 2025 has been entered. Drawings The drawings were received on September 29, 2025. These drawings are accepted as the amendments to the drawings are directed to correcting typographical errors. Specification The Specification was received on September 29, 2025. This Specification is accepted as the amendments to the Specification are directed to correcting typographical errors. 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 1-4, 6-9, and 11-22 are rejected under 35 U.S.C 101 because the claimed invention is directed to an abstract idea without significantly more. Step 1: Claims 1-4, 6-9, 11, and 21-22 recite an apparatus (machine), Claims 12-17 recite a method (process), and Claims 18-20 recite a system (machine) and therefore fall into a statutory category. Step 2A – Prong 1 (Is a Judicial Exception Recited?): The claims as a whole recites an apparatus, a method and a system for a manner of managing information related to IOT devices for validating a supply chain, which under its broadest reasonable interpretation, covers concepts for Certain Methods of Organizing Human Activity. The abstract idea portion of the claims is as follows: (Claim 1) [An apparatus, comprising: a registration circuit structured to] interpret a device registration request value that includes device property data corresponding to a device, wherein the device property data includes device ownership data corresponding to an owner of the device; [an Internet of Things Universal Identification (IoT UID) generation circuit structured to] generate, in response to the device registration request value, an IoT UID, wherein the IoT UID comprises one or more hashes corresponding to a meta identity component, a service identity component, a network identity component, and a physical identity component; [an IoT UID provisioning circuit structured to] transmit the IoT UID; [an IoT UID processing circuit structured to] interpret a query that includes the IoT UID; [a record management circuit structured to:] store the device property data with the IoT UID in a record in a database, and identify, based at least in part on the IoT UID in the query, the record [in the database]; [an ownership analysis circuit structured to] interpret the device ownership data, stored in the record, that corresponds to the device; [an ownership provisioning circuit structured to] transmit the device ownership data; [a supply chain validation circuit structed to:] validate a supply chain for the device based at least in part on the device ownership data; and transmit verification data in response to the validation of the supply chain; and [a security notification provisioning circuit structured to:] compare the device ownership data to a record of authorized owner; and generate a security notification if the device ownership data is not included in the record of authorized owners. (Claim 12) A method, comprising: interpreting,[ via a registration circuit], a device registration request value that includes device property data corresponding to a device, wherein the device property data includes device ownership data corresponding to an owner of the device; generating, [via an Internet of Things Universal Identification (IoT UID) generation circuit], in response to the device registration request value, an IoT UID, wherein the IoT UID comprises one or more hashes corresponding to a meta identity component, a service identity component, a network identity component, and a physical identity component; storing, [via a record management circuit], the device property data with the IoT UID in a record [in a database]; transmitting, [via an IoT UID provisioning circuit], the IoT UID; interpreting, [via an Internet of Things Universal Identification (IoT UID) processing circuit], an IoT UID corresponding to a device; identifying, [via the record management circuit ]and based at least in part on the IoT UID in the query, the record [in the database]; interpreting, [via an ownership analysis circuit] the device ownership data, stored in the record, that corresponds to the device; transmitting, [via an ownership provisioning circuit], the device ownership data; validating, [via a supply chain validation circuit], a supply chain for the device based at least in part on the device ownership data; and transmitting, [via the supply chain validation circuit], verification data in response to the validation of the supply chain; comparing, [via a notification provisioning circuit], the device ownership data to a record of authorized owners; and generating, [via the notification provisioning circuit], a security notification if the device ownership data is not included in the record of authorized owners. (Claim 18) [A system, comprising: a database structured to] store a plurality records associating Internet of Things Universal Identifications (IoT UIDs) with device ownership data; [and a server structured to: communicate with the database]; interpret a device registration request value that includes device property data corresponding to a device, wherein the device property data includes device ownership data corresponding to an owner of the device; generate, in response to the device registration request value, an IoT UID, wherein the IoT UID comprises one or more hashes corresponding to a meta identity component, a service identity component, a network identity component, and a physical identity component; store the device property data with the IoT UID in a record of the plurality of records; transmit the IoT UID; interpret a query that includes the IoT UID; identify, based at least in part on the IoT UID in the query, the record, of the plurality of records stored [in the database], the record including the device ownership data associated with the device; interpret, based at least in part on the record, the device ownership data; and transmit the device ownership data; validate a supply chain for the device based at least in part on the device ownership data; transmit verification data in response to the validation of the supply chain; compare the device ownership data to a record of authorized owners; and generate a security notification if the device ownership data is not included in the record of authorized owners. Where the portions not bracketed recite the abstract idea. Here the claims recite concepts covering managing personal behavior (following rules or instructions) but for the recitation of generic computer components. Additionally, the claims recite concepts covering commercial or legal interactions (business relations) but for the recitation of generic computing components. In the present application the claims recite concepts for managing information related to IoT devices for validating a supply chain. (See paragraphs 4-5). If a claim limitation, under its broadest reasonable interpretation, covers concepts capable of being performed in commercial or legal interactions or managing personal behavior or relationships or interactions between people it falls under the Certain Method of Organizing Human Activity, grouping of abstract ideas. See MPEP 2106.04. Accordingly, the claims recite an abstract idea. Step 2A-Prong 2 (Is the Exception Integrated into a Practical Application?): The Examiner views the following as the additional elements: An apparatus. (See paragraph 362 of the Specification.) A registration circuit. (See paragraphs 657 and 673 of the Specification.) An IoT UID generation circuit. (See paragraphs 657 and 673 of the Specification.) A record management circuit. (See paragraphs 657 and 673 of the Specification.) An IoT UID provisioning circuit. (See paragraphs 657 and 673 of the Specification.) An IoT UID processing circuit. (See paragraphs 657 and 673 of the Specification.) A record management circuit. (See paragraphs 657 and 673 of the Specification.) An ownership analysis circuit. (See paragraphs 657 and 673 of the Specification.) An ownership provisioning circuit. (See paragraphs 657 and 673 of the Specification.) A supply chain validation circuit. (See paragraphs 657 and 673 of the Specification.) A system. (See paragraphs 657 of the Specification.) A database. (See paragraphs 180 of the Specification.) A server. (See paragraph 657 of the Specification.) A security notification provisioning circuit. (See paragraphs 657 and 673 of the Specification.) A notification provisioning circuit. (See paragraphs 657 and 673 of the Specification.) These additional elements are recited at a high-level of generality such that they act to merely “apply” the abstract idea using generic computing components and do not integrate the abstract idea into a practical application. (See MPEP 2106.05 (f)) The combination of these additional elements and/or results oriented steps are no more than mere instructions to apply the exception using generic computing components. (See Id.) Accordingly, even in combination these 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. Step 2B (Does the claim recite additional elements that amount to Significantly More than the Judicial Exception?): As noted above, the claims as a whole merely describes a method and system that generally “apply” the concepts discussed in prong 1 above. (See MPEP 2106.05 f (II)) In particular applicant has recited the computing components at a high-level of generality such that it amounts to no more than mere instructions to apply the exception using generic computer components. As the court stated in TLI Communications v. LLC v. AV Automotive LLC, 823 F.3d 607, 613 (Fed. Cir. 2016) merely invoking generic computing components or machinery that perform their functions in their ordinary capacity to facilitate the abstract idea are mere instructions to implement the abstract idea within a computing environment and does not add significantly more to the abstract idea. Accordingly, these additional computer components do not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Therefore, even when viewed as a whole, nothing in the claim adds significantly more (i.e. an inventive concept) to the abstract idea and as a result the claim is not patent eligible. Dependent claims 2, 7, 13-16, and 19-21 further define the abstract idea as identified and do not integrate the abstract idea into a practical application or add significantly more. Therefore claims 2, 7, 13-16, and 19-21 are considered to be patent ineligible. Dependent claims 3-4 further define the abstract idea as identified. Additionally, the claim recites the additional elements of generic ownership data update provisioning circuit (See paragraphs 657 and 673) at a high-level of generality such that it amounts to no more than mere instructions to apply the exception using generic computing components and does not integrate the abstract idea into a practical application or add significantly more. Therefore claims 3-4 are considered to be patent ineligible. Dependent claim 6 further defines the abstract idea as identified. Additionally, the claim recites the additional elements of the trust indicator provisioning circuit (See paragraphs 657 and 673) at a high-level of generality such that it amounts to no more than mere instructions to apply the exception using generic computing components and does not integrate the abstract idea into a practical application or add significantly more. Therefore claim 6 is considered to be patent ineligible. Dependent claims 8-9 further define the abstract idea as identified. Additionally, the claim recites the additional elements of the asking price evaluation circuit (See paragraphs 657 and 673) at a high-level of generality such that it amounts to no more than mere instructions to apply the exception using generic computing components and does not integrate the abstract idea into a practical application or add significantly more. Therefore claims 8-9 are considered to be patent ineligible. Dependent claim 11 further defines the abstract idea as identified. Additionally, the claim recites the additional elements of the carbon rating provisioning circuit (See paragraphs 657 and 673) at a high-level of generality such that it amounts to no more than mere instructions to apply the exception using generic computing components and does not integrate the abstract idea into a practical application or add significantly more. Therefore claim 11 is considered to be patent ineligible. Dependent claim 17 further defines the abstract idea as identified. Additionally, the claim recites the additional elements of the IoT device registry (See paragraphs 180 and 515) at a high-level of generality such that it amounts to no more than mere instructions to apply the exception using generic computing components and does not integrate the abstract idea into a practical application or add significantly more. Therefore claim 17 is considered to be patent ineligible. Dependent claim 22 further defines the abstract idea as identified. Additionally, the claim recites the additional elements of the IoT UID generation circuit (See paragraphs 657 and 673) at a high-level of generality such that it amounts to no more than mere instructions to apply the exception using generic computing components and does not integrate the abstract idea into a practical application or add significantly more. Therefore claim 22 is considered to be patent ineligible. In conclusion the claims do not provide an inventive concept, because the claims do not recite additional elements or a combination of elements that amount to significantly more than the judicial exception of the claims. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology, and the collective functions merely provide conventional computer implementation. Therefore, whether taken individually or as an order combination, the claims are nonetheless rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter. Response to Arguments Applicant's arguments filed September 29, 2025 have been fully considered. Regarding Applicant’s amendments and arguments, on pages 14-25 of the Remarks, pertaining to the 101 rejection the Examiner finds unpersuasive. Applicant argues that the Examiner fails to explain how the identified abstract idea falls into commercial or legal interactions (business relations) because the Office Action does not identify what the alleged contracts or legal obligation is, nor provide a reasoned argument how said contract or legal obligation concerns business relations. Applicant contends that the Examiner does not provide any analysis demonstrating how the pending claims are similar to examples found by the courts and/or provided by the MPEP to be directed towards commercial or legal interactions. The Examiner respectfully disagrees viewing that the identified abstract idea is a commercial or legal interaction and in particular relating to business relations through managing information related to IoT devices for validating a supply chain. While Applicant contends that the claims do not recite concepts that relate to business relations, the Examiner respectfully disagrees as the steps pertaining to the registration of the IoT devices, including the amendment further defining the IoT UID comprises different hashes, is for assisting in the validation of a supply chain, i.e. validating a supply chain based on the ownership data, transmit verification data based on the validation, comparing ownership information, and generating a notification based on the comparison potentially. The Examiner maintains that they established a prima facie case that the claims recite an abstract idea by identifying the claim limitations viewed as part of the identified abstract idea and the appropriate grouping of abstract idea under Step 2A Prong 1. See MPEP 2106.04 (a) Applicant contends that the Examiner fails to provide any comparison and/or analysis demonstrate the recited claims are similar to an example provided by the court the MPEP, and/or other USPTO subject matter eligibility guidance for concepts related to managing of personal behavior or a relationship or an interaction between people. The Examiner respectfully disagrees maintaining the Examiner established a prima facie case that the claims recite an abstract idea by identifying the claim limitations viewed as part of the identified abstract idea and the appropriate grouping of abstract idea under Step 2A Prong 1. See MPEP 2106.04 (a). Furthermore, addressing Applicant’s concern that the Examiner has not discussed the claims in particular the Examiner only needed to identify what limitations recite the abstract idea. The Examiner maintains that the claims outline a series of steps (rules) to take in validating a supply chain including the identified limitations reciting aspects of processing registration of a IoT device (interpreting device registration request value including device property data, generating the corresponding IoT UID with the hashed information, transmitting the IoT UID, processing the IoT UID and storing the IoT UID and device property data together), identify a record based on the IoT UID, identify the device ownership information and communicate this, validate the supply chain for the device based on the device ownership information, transmit verification information based on the validation, and generating a security notification if the device ownership data is not included in the record of authorized owners based on the comparison of device ownership data to a record of authorized owner as part of the identified abstract idea of managing information related to IoT devices for validating a supply chain. Applicant argues under Step 2A Prong 2 that the IoT UIDs and registration of devices improve the transportation and distribution arts by providing for increased trust in product sourcing and transfers in the transportation and distribution arts, and therefore integrate any alleged abstract idea into a practical application. (See paragraphs 177, 188, and 236). The Examiner respectfully disagrees viewing that the IoT UIDs and registration of devices constitute steps of the abstract idea and the related benefits directed to the supply chain validation process are an improvement to a business practice and not an improvement to technological field or other consideration enumerated under MPEP 2106.04 (d). Applicant argues under Step 2B that the claims recite additional element that are not well known in the art in particular referencing claim 1: an Internet of Things Universal Identification (IoT UID) generation circuit structured to generate, in response to the device registration request value, an IoT UID, wherein the IoT UID comprises one or more hashes corresponding to a meta identity component, a service identity component, a network identity component, and a physical identity component; a supply chain validation circuit structed to: validate a supply chain for the device based at least in part on the device ownership data; a security notification provisioning circuit structured to: compare the device ownership data to a record of authorized owner; and generate a security notification if the device ownership data is not included in the record of authorized owners. The Examiner respectfully disagrees viewing the additional elements ((IoT UID) generation circuit supply chain validation circuit, and security notification provisioning circuit) identified in the Step 2A Prong 1 Analysis were deemed to be mere instructions to apply the abstract idea using generic computing components and does not integrate the abstract idea into a practical application or adds significantly more to the abstract idea. MPEP 2106.05 (f) According to Applicant, the registration of devices and validation of their supply chains using IOT UIDs is not a well-known computer function. The Examiner respectfully disagrees viewing the additional elements as mere instructions to apply the abstract idea using generic computing components and do not integrate the abstract idea into a practical or adds significantly more. (MPEP 2106.05 (f)). The Examiner reiterates they view the registration process and subsequent validation as part of the abstract idea rather than additional elements. Applicant contends that the Examiner must provide evidence supporting an additional element is well-understood, routine, and conventional. The Examiner cites MPEP 2106.05: Although the conclusion of whether a claim is eligible at Step 2B requires that all relevant considerations be evaluated, most of these considerations were already evaluated in Step 2A Prong Two. Thus, in Step 2B, examiners should: Carry over their identification of the additional element(s) in the claim from Step 2A Prong Two; Carry over their conclusions from Step 2A Prong Two on the considerations discussed in MPEP §§ 2106.05(a) - (c), (e) (f) and (h): Here the Examiner identified the additional elements as mere instructions to implement the abstract idea using generic computing components as discussed above. (See MPEP 2106.05 (f)). Therefore, the Examiner carried their conclusions from the Step 2A Prong 2 Analysis for Step 2B and does not view the additional elements as adding significantly more to the abstract idea. The Examiner further identified the associated paragraphs of the Specification in the Step 2A Prong 2 Analysis to bolster their position that these additional elements are mere instructions to apply the abstract idea using generic computing components and do not integrate the abstract idea into a practical application or adds significantly more. The Examiner further notes regarding Applicant’s contention that the Examiner must provide a citation the Examiner notes MPEP 2106.07(a)(III): At Step 2A Prong Two or Step 2B, there is no requirement for evidence to support a finding that the exception is not integrated into a practical application or that the additional elements do not amount to significantly more than the exception unless the examiner asserts that additional limitations are well-understood, routine, conventional activities in Step 2B. Examiners should not assert that an additional element (or combination of elements) is well-understood, routine, or conventional unless the examiner finds, and expressly supports the rejection in writing with one or more of the following: (A) A citation to an express statement in the specification or to a statement made by an applicant during prosecution that demonstrates the well-understood, routine, conventional nature of the additional element(s). A specification demonstrates the well-understood, routine, conventional nature of additional elements when it describes the additional elements as well-understood or routine or conventional (or an equivalent term), as a commercially available product, or in a manner that indicates that the additional elements are sufficiently well-known that the specification does not need to describe the particulars of such additional elements to satisfy 35 U.S.C. 112(a). A finding that an element is well-understood, routine, or conventional cannot be based only on the fact that the specification is silent with respect to describing such element. The Examiner maintains they provided adequate evidence that the additional elements do not add significantly more than the abstract idea in view of the Specification. Therefore, for the foregoing reasons the Examiner has maintained the 101 rejection. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Bartlett et al. (US 20200169460) – directed to pre-enrollment and network pre-configuration of IOT devices. Park et al. (US 20200201988) – directed to managing information of an IOT device using blockchain. Clernon (US 20170187807) – directed to IOT provisioning. Any inquiry concerning this communication or earlier communications from the examiner should be directed to MICHAEL J MONAGHAN whose telephone number is (571)270-5523. The examiner can normally be reached on Monday- Friday 8:30 am - 5:30 pm. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Sarah Monfeldt can be reached on (571) 270-1833. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /Michael J. Monaghan/Examiner, Art Unit 3629
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Prosecution Timeline

Apr 15, 2022
Application Filed
Jan 26, 2024
Non-Final Rejection — §101
Feb 29, 2024
Applicant Interview (Telephonic)
Mar 02, 2024
Examiner Interview Summary
Jun 03, 2024
Response Filed
Aug 19, 2024
Final Rejection — §101
Nov 15, 2024
Request for Continued Examination
Nov 18, 2024
Response after Non-Final Action
Jan 25, 2025
Non-Final Rejection — §101
Apr 30, 2025
Response Filed
May 27, 2025
Final Rejection — §101
Sep 29, 2025
Request for Continued Examination
Oct 05, 2025
Response after Non-Final Action
Oct 24, 2025
Non-Final Rejection — §101
Mar 05, 2026
Interview Requested
Mar 05, 2026
Applicant Interview (Telephonic)
Mar 07, 2026
Examiner Interview Summary

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

5-6
Expected OA Rounds
36%
Grant Probability
92%
With Interview (+55.9%)
3y 1m
Median Time to Grant
High
PTA Risk
Based on 126 resolved cases by this examiner. Grant probability derived from career allow rate.

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