Prosecution Insights
Last updated: April 19, 2026
Application No. 17/726,015

CONTENT DISTRIBUTION VIA USAGE TRACKING NON-FUNGIBLE TOKENS

Final Rejection §101§103
Filed
Apr 21, 2022
Examiner
ROSEN, ELIZABETH H
Art Unit
3693
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Bitvore Corp.
OA Round
6 (Final)
47%
Grant Probability
Moderate
7-8
OA Rounds
3y 3m
To Grant
99%
With Interview

Examiner Intelligence

Grants 47% of resolved cases
47%
Career Allow Rate
104 granted / 223 resolved
-5.4% vs TC avg
Strong +52% interview lift
Without
With
+52.1%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
52 currently pending
Career history
275
Total Applications
across all art units

Statute-Specific Performance

§101
34.0%
-6.0% vs TC avg
§103
29.8%
-10.2% vs TC avg
§102
6.3%
-33.7% vs TC avg
§112
21.2%
-18.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 223 resolved cases

Office Action

§101 §103
DETAILED ACTION Status of Application This action is a Final Rejection. This action is in response to the amendment and response filed on October 14, 2025. Claims 1, 10, 11, and 20 have been amended. Claims 1-20 are pending and are rejected. The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . 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. Response to Arguments Regarding step 2A, prong two of the rejection under 35 U.S.C. § 101, Applicant argues that the claims “recite a specific access-control pipeline that improves the functioning of the content-distribution computer system by (i) eliminating credential reuse via on-chain gating prior to decryption, (ii) providing tamper-resistant auditability at the point of access, and (iii) reducing reliance on third-party DRM by embedding usage terms into verifiable smart-contract conditions that must be satisfied before the client can decrypt the container. This is a particular implementation that affects the transformation of encrypted data from an unreadable state to a readable state only upon machine-verifiable satisfaction of on-chain conditions, i.e., a technological solution to the technical problem of secure, decentralized usage enforcement.” Remarks at 9. However, Applicant has not shown that these features improve the content-distribution computer system. For example, Applicant has not shown that the Specification describes a technological improvement that is reflected in the claims. See MPEP 2106.04(d)(1). Instead, the system and technology are being used to allegedly improve the business process. Applicant further argues, with respect to step 2B, that “[t]he recited combination of wallet-plugin authentication + UT-NFT-supplied keys + on-chain verification + conditional decryption + atomic on-chain logging and payment splitting is not a generic ‘apply it’ on a computer. It is a coordinated set of specific components (Dapp, wallet plugin, encrypted container, UT-NFT, smart contract) operating in a prescribed sequence that imposes a meaningful limit on any alleged abstract idea of ‘organizing licensing.’ The OA distinguishes DDR/Enfish on grounds that those cases improved technology. Here, the amended claims likewise improve the technology of content access control in decentralized systems, providing real-time, tamper resistant gating at the decryption boundary. This is an improvement grounded in the disclosed architecture.” Remarks at 9. Although the claims recite the additional elements of Dapp, wallet plugin, encrypted container, UT-NFT, and smart contract, these additional elements are existing technology or software. These additional elements, either individually or as an ordered combination, are not being improved. Instead, they are being used to perform a business process, i.e., abstract idea. As such, the rejection under 35 U.S.C. 101 is maintained. Claim Rejections - 35 U.S.C. § 101 35 U.S.C. § 101 reads as follows: Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title. Claims 1-20 are rejected under 35 U.S.C. § 101 as being directed to non-statutory subject matter because the claimed invention is directed to an abstract idea without significantly more. Step 1: Does the Claim Fall within a Statutory Category? (see MPEP 2106.03) Yes, with respect to claims 1-10, which recite a system and, therefore, are directed to the statutory class of machine or manufacture. Yes, with respect to claims 11-20, which recite a method and, therefore, are directed to the statutory class of process. Step 2A, Prong One: Is a Judicial Exception Recited? (see MPEP 2106.04(a)) The following claims identify the limitations that recite additional elements in bold and abstract idea in regular text: 1. A system comprising: one or more processors; and memory comprising a decentralized web application (Dapp), wherein the one or more processors are configured by the Dapp to: receive one or more digital items from one or more licensors; generate, via a secure library generator integrated with a blockchain, a usage-tracking, non-fungible token (UT-NFT) according to the one or more digital items from one or more licensors, wherein the UT-NFT is programmed with encrypted data unique to the digital items and the licensor; store the UT-NFT on a decentralized blockchain ledger to prevent tampering or unauthorized access; dynamically generate, via a contract generator of the Dapp, a blockchain-based smart contract that securely computes a relevancy score associated with the UT-NFT, usage reports associated with the UT-NFT, and a license fee associated with the UT-NFT, wherein the smart contract ensures that usage data is updated in real-time and verified across the network; program the usage reports into the UT-NFT, wherein the usage reports relate to data associated with a use of the one or more digital items associated with the UT-NFT and comprise one or more of: what device can access the one or more digital items, where the one or more digital items can be accessed, and when the one or more digital items can be accessed, wherein the usage reports are updated and recorded on the blockchain for secure and immutable tracking of access rights; authenticate, via a wallet plugin, a request to access a container that holds the digital items; retrieve, from the UT-NFT, decryption credentials for an encrypted content container; verify on-chain, via the smart contract, that the usage reports are satisfied; and only upon successful verification, decrypt the container to enable access, while recording the access transaction on the blockchain and effecting payment splits specified by the smart contract. 2. The system of claim 1, wherein: the system comprises a wallet associated with the library generator, and the wallet is configured to record details associated with an access to the one or more digital items via the UT-NFT. 3. The system of claim 1, wherein: the one or more digital items comprise one or more pieces of information and at least one additional digital item, and the library generator is configured to generate a different UT-NFT according to a subset of the one or more pieces of information and the at least one additional digital item. 4. The system of claim 1, wherein: the one or more digital items comprise an artificial intelligence (AI) model that uses one or more pieces of information. 5. The system of claim 1, wherein: the system comprises a self-service portal configured to generate one or more non-fungible tokens (NFTs) according to the one or more pieces of information, and the library generator is configured to generate the UT-NFT according to the one or more NFTs. 6. The system of claim 1, wherein: the library generator is operable to generate and store a plurality of UT-NFTs according to a plurality of articles, and the one or more digital items are selected, from among the plurality of articles, by a customer. 7. The system of claim 1, wherein: the usage reports specify a wallet of at least one of the one or more licensors. 8. The system of claim 1, wherein: the dynamically generated relevancy score is derived according to: how often the one or more digital items have been accessed, and/or how often the one or more digital items are expected to be accessed in the future. 9. The system of claim 1, wherein: the license fee is determined according to the relevancy score and the usage reports wherein the usage reports comprise one or more of: who can access the one or more digital items, and why the one or more digital items are being accessed. 10. The system of claim 1, wherein: a license fee is paid, via a cryptocurrency, to the one or more licensors, wherein each of the one or more licensors are paid according to a predetermined share of the license fee. 11. A method implemented via one or more computers, comprising: using a decentralized web application (Dapp), wherein one or more processors are configured by the Dapp for: receiving one or more digital items from one or more licensors; generating a usage-tracking, non-fungible token (UT-NFT) according to one or more digital items from one or more licensors; dynamically generating, for the UT-NFT, a relevancy score, usage reports and a license fee; programming the usage reports into the UT-NFT, wherein the usage reports relate to data associated with a use of the one or more digital items associated with the UT-NFT and comprise one or more of: what device can access the one or more digital items, where the one or more digital items can be accessed, and when the one or more digital items can be accessed; authenticating, via a wallet plugin, a request to access an encrypted container associated with the UT-NFT; obtaining, from the UT-NFT, decryption credentials; verifying, on-chain, compliance with the usage reports via the smart contract; and responsive to the verification, decrypting the container to enable access and recording the access as a blockchain transaction that triggers smart-contract payment splitting. . 12. The method of claim 11, wherein the method comprises: maintaining a record of details associated with an access to the one or more digital items via the UT-NFT. 13. The method of claim 11, wherein: the one or more digital items comprise one or more articles and at least one additional digital item, and the method comprises generating a different UT-NFT according to a subset of the one or more articles and the at least one additional digital item. 14. The method of claim 11, wherein: the one or more digital items comprise an artificial intelligence (AI) model that uses one or more articles. 15. The method of claim 11, wherein the method comprises: generating one or more non-fungible tokens (NFTs) according to the one or more articles, and generating the UT-NFT according to the one or more NFTs. 16. The method of claim 11, wherein: the one or more digital items are selected, from among a plurality of digital items, by a customer. 17. The method of claim 11, wherein: the usage reports specify a wallet of at least one of the one or more licensors. 18. The method of claim 11, wherein the method comprises: deriving the relevancy score according to: how often the one or more digital items have been accessed, and/or how often the one or more digital items are expected to be accessed in the future. 19. The method of claim 11, wherein the method comprises: determining the license fee according to the relevancy score and the usage reports, wherein the usage reports comprise one or more of: who can access the one or more digital items, and why the one or more digital items are being accessed. 20. The method of claim 11, wherein the method comprises: requiring the license fee to be paid, via a cryptocurrency, to the one or more licensors, wherein each of the one or more licensors are paid according to a predetermined share of the license fee. Yes. But for the recited additional elements as shown above in bold, the remaining limitations of the claims recite certain methods of organizing human activity. The claims are directed to method and system for tracking content so that content producers can be paid. This type of method of organizing human activity is similar to a fundamental economic practice such as a payment, or a commercial interaction such as agreements in the form of contracts, legal obligations, sales activities or behaviors, or business relations. Thus, the claims recite an abstract idea. Step 2A, Prong Two: Is the Abstract Idea Integrated into a Practical Application? (see MPEP 2106.04(d)) No. The claims as a whole merely use known computing technology as a tool to perform the abstract idea. The computing components (i.e., additional elements that are in bold above) are recited at a high level of generality and are merely invoked as a tool to perform the abstract idea. Simply implementing the abstract idea using generic computers or devices is not a practical application of the abstract idea. Furthermore, the abstract idea is merely being linked to a particular technological environment, i.e., blockchain. Employing well known technology within a blockchain environment to execute the abstract idea, even when limiting the use of the abstract idea to this environment, does not integrate the exception into a practical application or add significantly more. Additionally, there is no improvement to the functioning of a computer or technology. Therefore, the abstract idea is not integrated into a practical application. Step 2B: Does the Claim Provide an Inventive Concept? (see MPEP 2106.05) No. As discussed with respect to Step 2A, Prong 2, the additional elements in the claims, both individually and in combination, amount to no more than tools to perform the abstract idea. Merely performing the abstract idea using a computer cannot provide an inventive concept. Therefore, the claims do not provide an inventive concept. As such, the claims are not patent eligible. 35 U.S.C. § 103 The rejections under 35 U.S.C. § 103 are withdrawn in light of Applicant’s amendments. Although individual claimed features and concepts were found in the art, the independent claims as a whole are not obvious in light of the prior art. Other Relevant Prior Art Hung, U.S. Patent Application Publication Number 2022/0337414 A2. Hung teaches a multi-tier encryption NFT system. Leung et al., U.S. Patent Application Publication Number 2023/0209116 A1. Leung reference teaches the integration of platforms for multi-platform content access. Specifically, this reference teaches that access to content may be “timed so that access to the information expires after a predetermined time.” See paragraph 0020. 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 extension fee 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. Any inquiry concerning this communication or earlier communications from the examiner should be directed to ELIZABETH H ROSEN whose telephone number is (571) 270-1850 and email address is elizabeth.rosen@uspto.gov. The examiner can normally be reached Monday - Friday, 10 AM ET - 7 PM ET. 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, Michael Anderson, can be reached at 571-270-0508. 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. /ELIZABETH H ROSEN/Primary Examiner, 3693
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Prosecution Timeline

Apr 21, 2022
Application Filed
Nov 18, 2023
Non-Final Rejection — §101, §103
Feb 05, 2024
Response Filed
Mar 05, 2024
Final Rejection — §101, §103
May 06, 2024
Response after Non-Final Action
Jun 03, 2024
Request for Continued Examination
Jun 04, 2024
Response after Non-Final Action
Jul 18, 2024
Non-Final Rejection — §101, §103
Sep 30, 2024
Response Filed
Oct 13, 2024
Final Rejection — §101, §103
Apr 10, 2025
Request for Continued Examination
Apr 14, 2025
Response after Non-Final Action
Apr 19, 2025
Non-Final Rejection — §101, §103
Oct 14, 2025
Response Filed
Nov 09, 2025
Final Rejection — §101, §103 (current)

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

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Prosecution Projections

7-8
Expected OA Rounds
47%
Grant Probability
99%
With Interview (+52.1%)
3y 3m
Median Time to Grant
High
PTA Risk
Based on 223 resolved cases by this examiner. Grant probability derived from career allow rate.

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