CTFR 17/840,408 CTFR 94439 DETAILED ACTION Notice of Pre-AIA or AIA Status 07-03-aia AIA 15-10-aia The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA. 12-151 AIA 26-51 12-51 Status of Claims This office action is in response to the claim amendments filed on November 26, 2026. 12-151-10 AIA 12-51-10 Claim s 1-20, 22-38, 43 have been canceled. Claims 21, 39-42 and 44-50 and are pending. Claims 21, 39-42 and 44-50 have been examined. Response to Arguments With respect to Claim Rejections - 35 U.S.C. 112(b) Applicant’s amendments to the claims have overcome this ground of rejection. Accordingly, this ground of rejection is withdrawn. With respect to Claim Rejections - 35 USC § 103 Applicant’s arguments, see pages 8-11, with respect to claims 21, 39-42 and 44-46 have been fully considered and are persuasive. The 35 USC § 103 rejection of claims 21, 39-42 and 44-46 have been withdrawn. With respect to Claim Rejections - 35 USC § 101 With respect to claim 42 is rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter. Applicant’s amendments to the claims have overcome this ground of rejection. Accordingly, this ground of rejection is withdrawn. With respect claims 21, 39-42 and 44-50 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. Applicant’s arguments: Applicant argues: Claim 42 stands rejected under 35 USC§ 101 because the claimed invention is directed to non-statutory subject matter without significantly more. Claims 21, 39-42 and 44-46 stand rejected under 35 USC §101 because the claimed invention is directed to an abstract idea without significantly more. Claims 21 and 42 now recite "wherein the distributed ledger circuitry is configured to verify device locations by cross-correlating independently posted proximity records from multiple computing devices to establish attestation of the device locations" which integrates any abstract idea into a practical application by providing a concrete technological solution to the technical problem of location verification susceptible to spoofing. Accordingly, for at least the reasons set forth above, Applicant respectfully requests the withdrawal of the rejection of claims 21 and 42 and their dependent claims. See Applicant’s Arguments page 7. Examiner, respectfully disagrees: The Examiner, however, respectfully disagrees. As a preliminary matter, the Examiner follows the 2019 Patent Eligibility Guidance (“2019 PEG”) which is a synthesis of the case law of Alice and its progeny. Additionally, the reasoning for this rejection is the same as was laid out in the Office Action Non-Final Rejection, dated 08/27/2025 (hereinafter, “Office Action”). Furthermore, while Applicant has amended the claim to recite additional subject matter, for example, amended claim recite: wherein the proximity records are provided to an entity offering products or services in response to a query placed by the entity to verify a location-based transaction, wherein the distributed ledger circuitry is configured to verify device locations by cross-correlating independently posted proximity records from multiple computing devices to establish attestation of the device locations , further describe the abstract idea of storing data on a distributed ledger. Furthermore, wherein the proximity records are provided to an entity offering products or services in response to a query placed by the entity to verify a location-based transaction, wherein the distributed ledger … is configured to verify device locations by cross-correlating independently posted proximity records from multiple computing devices to establish attestation of the device locations , can be performed by using a pen and paper and/or that can be performed mentally. The courts consider a mental process (thinking) that "can be performed in the human mind, or by a human using a pen and paper" to be an abstract idea. Additionally, a computing device, processing circuitry coupled to a memory, the processing circuitry having distributed ledger circuitry does not necessarily restrict the claim from reciting an abstract idea. Accordingly, the claims (e.g., the amended claims) recite an abstract idea (See MPEP 2106.04). (Step 2A-Prong 1: YES) The claims (e.g., the amended claims) also fail to recite a practical application of the abstract ideas. According to the 2019 PEG, the additional claim elements are considered when determining whether the claim recites a practical application, such as a technological improvement, of the abstract idea. However, the claims fail to introduce any such additional elements. Again, wherein the proximity records are provided to an entity offering products or services in response to a query placed by the entity to verify a location-based transaction, wherein the distributed ledger circuitry is configured to verify device locations by cross-correlating independently posted proximity records from multiple computing devices to establish attestation of the device locations are not considered as additional claim elements. Therefore, the claims do not, for example, purport to improve the functioning of a computer. And the claims are directed to an abstract idea. Thus, claims do not integrate the abstract idea into a practical application. Therefore, this analysis is the same as was laid out in the Office Action. (Step 2A-Prong 2: NO) The claims also fail to recite significantly more than the abstract idea. According to the 2019 PEG, the additional elements, when considered individually and as a combination, are analyzed to determine whether the claims recite significantly more than the abstract idea. However, the claims (e.g., the amended claims) fail to recite any new additional elements. As noted in the Office Action, the additional elements serve to implement the abstract idea in a computing environment. Furthermore, the claims (e.g., the amended claims) recite, wherein the proximity records are provided to an entity offering products or services in response to a query placed by the entity to verify a location-based transaction, wherein the distributed ledger circuitry is configured to verify device locations by cross-correlating independently posted proximity records from multiple computing devices to establish attestation of the device locations , it does not appear that the amended claim would result in any improvement to the recited technology. Therefore, the claims limitations do not include additional elements that integrate the abstract idea into a practical application or that provide significantly more than the abstract idea. Therefore, the claim is not patent eligible. (Step 2B: NO) . See detail rejection below. Accordingly, this ground of rejection is maintained. The Examiner propose having the claims be amended to include the technical features of what the Applicant deems as their invention in order to re-analyze the claims to determine whether they are patent eligible. The Examiner recommends by way of example only, positively recite subject matter of Fig. 7. Claim Rejections - 35 USC § 101 07-04-01 AIA 07-04 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. Claim Rejections - 35 USC § 101 07-04-01 AIA 07-04 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 21, 39-42 and 44-50 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. In the instant case, claims 21 and 39-41 are directed to a computing device, claims 42 and 44-46 are directed to a non-transitory computer-readable storage medium, and 47-50 are directed to a method. Therefore, these claims fall within the four statutory categories of invention. The claims recite an abstract idea of storing data on a distributed ledger. Specifically, the claims recite “storing of proximity records, sharing records of the proximity records, or receipt records of the proximity records, wherein the one or more of the proximity records, the sharing records, or the receipt records are associated with one or more computing devices that are proximally located of each other as posted in a distributed ledger, wherein the distributed ledger having proximity records is implemented using a blockchain establishing an evidence trail relating to assertions regarding one or more times or one or more locations indicating one or more observations relating to the one or more computing devices, wherein the evidence trail is established while maintaining anonymity with respect to the information in the distributed ledger, wherein the proximity records to identify and prove one or more locations of the one or more computing devices, wherein the proximity records are provided to an entity offering products or services in response to a query placed by the entity to verify a location-based transaction, wherein the distributed ledger circuitry is configured to verify … locations by cross-correlating independently posted proximity records from multiple computing … to establish attestation of the … locations”, which is grouped within the “certain methods of organizing human activity” grouping of abstract ideas in prong one of step 2A of the Alice/Mayo test ( See MPEP 2106.04(a)) because it describes a process for carrying out a commercial interaction between parties that involves communicating data needed to complete a transaction to the parties. Accordingly, the claims recite an abstract idea ( See MPEP 2106.04). This judicial exception is not integrated into a practical application because, when analyzed under prong two of step 2A of the Alice/Mayo test ( See MPEP 2106.04(a or d)), the additional element(s) of the claim(s) such as a computing device, processing circuitry coupled to a memory, the processing circuitry having distributed ledger circuitry merely use(s) a computer as a tool to perform an abstract idea. Specifically, the computing device, processing circuitry coupled to the memory, the processing circuitry having distributed ledger circuitry perform(s) the steps or functions of “processing circuitry coupled to a memory, the processing circuitry having distributed ledger circuitry to facilitate storing of proximity records, sharing records of the proximity records, or receipt records of the proximity records, wherein the one or more of the proximity records, the sharing records, or the receipt records are associated with one or more computing devices that are proximally located of each other as posted in a distributed ledger, wherein the distributed ledger having proximity records is implemented using a blockchain establishing an evidence trail relating to assertions regarding one or more times or one or more locations indicating one or more observations relating to the one or more computing devices, wherein the evidence trail is established while maintaining anonymity with respect to the information in the distributed ledger, wherein the proximity records to identify and prove one or more locations of the one or more computing devices, wherein the proximity records are provided to an entity offering products or services in response to a query placed by the entity to verify a location-based transaction, wherein the distributed ledger circuitry is configured to verify device locations by cross-correlating independently posted proximity records from multiple computing devices to establish attestation of the device locations.” The use of a processor/computer as a tool to implement the abstract idea does not integrate the abstract idea into a practical application because it requires no more than a computer performing functions that correspond to acts required to carry out the abstract idea. The additional elements do not involve improvements to the functioning of a computer, or to any other technology or technical field ( See MPEP 2106.05(a)), the claims do not apply the abstract idea with, or by use of, a particular machine ( See MPEP 2106.05(b)), the claims do not effect a transformation or reduction of a particular article to a different state or thing ( See MPEP 2106.05(c)), and the claims do not apply or use the abstract idea in some other meaningful way beyond generally linking the use of the abstract idea to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception (MPEP 2106.05(e) and Vanda Memo). Therefore, the claims do not, for example, purport to improve the functioning of a computer. Nor do they effect an improvement in any other technology or technical field. Accordingly, the additional elements do not impose any meaningful limits on practicing the abstract idea, and the claims are directed to an abstract idea. The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when analyzed under step 2B of the Alice/Mayo test ( See MPEP 2106.05), the additional element(s) of using a computing device, processing circuitry coupled to a memory, the processing circuitry having distributed ledger circuitry to perform the steps amounts to no more than using a computer or processor to automate and/or implement the abstract idea of storing data on a distributed ledger. As discussed above, taking the claim elements separately, the computing device, processing circuitry coupled to the memory, the processing circuitry having distributed ledger circuitry perform(s) the steps or functions of “processing circuitry coupled to a memory, the processing circuitry having distributed ledger circuitry to facilitate storing of proximity records, sharing records of the proximity records, or receipt records of the proximity records, wherein the one or more of the proximity records, the sharing records, or the receipt records are associated with one or more computing devices that are proximally located of each other as posted in a distributed ledger, wherein the distributed ledger having proximity records is implemented using a blockchain establishing an evidence trail relating to assertions regarding one or more times or one or more locations indicating one or more observations relating to the one or more computing devices, wherein the evidence trail is established while maintaining anonymity with respect to the information in the distributed ledger, wherein the proximity records to identify and prove one or more locations of the one or more computing devices, wherein the proximity records are provided to an entity offering products or services in response to a query placed by the entity to verify a location-based transaction, wherein the distributed ledger circuitry is configured to verify device locations by cross-correlating independently posted proximity records from multiple computing devices to establish attestation of the device locations”. These functions correspond to the actions required to perform the abstract idea. Viewed as a whole, the combination of elements recited in the claims merely recite the concept of storing data on a distributed ledger. Therefore, the use of these additional elements does no more than employ the computer as a tool to automate and/or implement the abstract idea. The use of a computer or processor to merely automate and/or implement the abstract idea cannot provide significantly more than the abstract idea itself (MPEP 2106.05(I)(A)(f) & (h)). Therefore, the claim is not patent eligible. Regarding dependent claims Dependent claims 39-41, 44-46 and 48-50 further describe the abstract idea of storing data on a distributed ledger. Claims 39, 44 and 48 recite: wherein the distributed ledger is implemented using a blockchain, wherein the distributed ledger circuitry is further to update the distributed ledger in response to one or more changes to status or proximity of the one or more computing devices. Claims 40, 45 and 49 recite: wherein the transaction circuitry is further to determine the one or more locations of the computing devices based on a proximity device graph posted in the distributed ledger. Claims 41, 46 and 50: wherein the one or more computing devices comprises one or more mobile computing devices, wherein the processing circuitry comprises one or more of application processing circuitry or graphics processing circuitry. The dependent claims do not include additional elements that integrate the abstract idea into a practical application or that provide significantly more than the abstract idea. Therefore, the dependent claims are also not patent eligible. Conclusion 07-40 AIA Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL . See MPEP § 706.07(a). 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 date of this final action. 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If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /JAHED ALI/Examiner, Art Unit 3699 /NEHA PATEL/Supervisory Patent Examiner, Art Unit 3699 Application/Control Number: 17/840,408 Page 2 Art Unit: 3699 Application/Control Number: 17/840,408 Page 3 Art Unit: 3699 Application/Control Number: 17/840,408 Page 4 Art Unit: 3699 Application/Control Number: 17/840,408 Page 5 Art Unit: 3699 Application/Control Number: 17/840,408 Page 7 Art Unit: 3699 Application/Control Number: 17/840,408 Page 8 Art Unit: 3699 Application/Control Number: 17/840,408 Page 9 Art Unit: 3699 Application/Control Number: 17/840,408 Page 10 Art Unit: 3699 Application/Control Number: 17/840,408 Page 11 Art Unit: 3699 Application/Control Number: 17/840,408 Page 12 Art Unit: 3699