DETAILED ACTION
Response to Amendment
This Office Action is responsive to Applicant’s arguments and request for reconsideration of application 17/881,989 (08/05/22) filed on 9/5/25.
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 - 20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter.
ALICE/ MAYO: TWO-PART ANALYSIS
2A. First, a determination whether the claim is directed to a judicial exception (i.e., abstract idea).
Prong 1: A determination whether the claim recites a judicial exception (i.e., abstract idea).
Groupings of abstract ideas enumerated in the 2019 Revised Patent Subject Matter Eligibility Guidance.
Mathematical concepts- mathematical relationships, mathematical formulas or equations, mathematical calculations.
Certain methods of organizing human activity- fundamental economic principles or practices (including hedging, insurance, mitigating risk); commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations); managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions).
Mental processes- concepts performed in the human mind (including an observation, evaluation, judgement, opinion).
Prong 2: A determination whether the judicial exception (i.e., abstract idea) is integrated into a practical application.
Considerations indicative of integration into a practical application enumerated in the 2019 Revised Patent Subject Matter Eligibility Guidance.
Improvement to the functioning of a computer, or an improvement to any other technology or technical field
Applying or using a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition
Applying the judicial exception with, or by use of a particular machine.
Effecting a transformation or reduction of a particular article to a different state or thing
Applying or using the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception
Considerations that are not indicative of integration into a practical application enumerated in the 2019 Revised Patent Subject Matter Eligibility Guidance.
Merely reciting the words “apply it” (or an equivalent) with the judicial exception, or merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea.
Adding insignificant extra-solution activity to the judicial exception.
Generally linking the use of the judicial exception to a particular technological environment or field of use.
2B. Second, a determination whether the claim provides an inventive concept (i.e., Whether the claim(s) include additional elements, or combinations of elements, that are sufficient to amount to significantly more than the judicial exception (i.e., abstract idea)).
Considerations indicative of an inventive concept (aka “significantly more”) enumerated in the 2019 Revised Patent Subject Matter Eligibility Guidance.
Improvement to the functioning of a computer, or an improvement to any other technology or technical field
Applying the judicial exception with, or by use of a particular machine.
Effecting a transformation or reduction of a particular article to a different state or thing
Applying or using the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception NOTE: The only consideration that does not overlap with the considerations indicative of integration into a practical application associated with step 2A: Prong 2.
Considerations that are not indicative of an inventive concept (aka “significantly more”) enumerated in the 2019 Revised Patent Subject Matter Eligibility Guidance.
Merely reciting the words “apply it” (or an equivalent) with the judicial exception, or merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea.
Adding insignificant extra-solution activity to the judicial exception.
Generally linking the use of the judicial exception to a particular technological environment or field of use.
Simply appending well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception. NOTE: The only consideration that does not overlap with the considerations that are not indicative of integration into a practical application associated with step 2A: Prong 2.
See also, 2010 Revised Patent Subject Matter Eligibility Guidance; Federal Register; Vol. 84, No. 4; Monday, January 7, 2019
Claims 1 - 20 is/are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
1: Statutory Category
Applicant’s claimed invention, as described in independent claim 1, is/are directed to a process (i.e. a method).
2(A): The claim(s) are directed to a judicial exception (i.e., an abstract idea).
PRONG 1: The claim(s) recite a judicial exception (i.e., an abstract idea).
Certain Method of Organizing Human Activity
The claim as a whole recites a method of organizing human activity. The claimed invention is involves connecting to one or more internal data sources within an enterprise, one or more external data sources outside of the enterprise; collecting, at user specified intervals, a plurality of internal feed data from the internal data sources and external feed data from the external data sources, the internal feed data relating to one or more employees of the enterprise; performing the operations of: training to determine attrition risk factors; inputting the plurality of internal feed data; and determining based on at least the input internal feed data, a plurality of attrition risk factors for the employees, the attrition risk factors being selected from a prespecified list of potential attrition risk factors including the risk factors of compensation, connection and growth; performing the operations of: providing for display, a first user interface portion depicting separate groupings having an indication of a number of the employees having a particular attrition risk factor determined; and providing for display, a second user interface portion depicting a listing of employees being associated with the particular attrition risk factor, wherein the second user interface portion includes a graphical indication of each of the employees depicted in the listing; determining recommendations for reducing attrition for a group of the employees; providing for display, a third user interface portion depicting a graphical indication of the determined recommendations for reducing attrition, wherein the third user interface portion receives a selection for a recommendation for reducing attrition, and receives a selection for creating a retention task for one or more of the employees; and performing a selected retention task, which is a fundamental economic principles or practices (attrition; training courses); commercial or legal interactions (attrition, training courses); and managing personal behavior or relationships or interactions between people (connecting, collecting, performing, training, inputting, determining, providing).
The mere nominal recitation of “a processing engine comprising: a network module; a feed collector module; a machine learning module; and an output module;” executing “via one or more servers” does not take the claim out of the method of organizing human activity grouping. Thus, the claim recites an abstract idea.
PRONG 2: The judicial exception (i.e., an abstract idea). Is not integrated into a practical application.
The claim recites the combination of additional elements of a “processing engine comprising: a network module; a feed collector module; a machine learning module; and an output module;” and executing “via one or more servers” performing the positively recited step or acts. The claim recites the combination of additional elements of the “processing engine comprising: a network module; a feed collector module; a machine learning module; and an output module;” and executing “via one or more servers” being connected to “one or more client devices”. The claim recites the combination of additional elements of “training”, “inputting” and “determining” using a “machine learning network” and “the machine learning network comprising a neural network, wherein the neural network includes connected nodes that are aggregated into layers and node weights that determine how signals are processed via the connected nodes, wherein the training the machine learning network adjusts the node weights, wherein a strength of ties between the nodes indicates an employee attribution risk”. The claim recites the combination of additional elements of providing for display “to a client device” a plurality of interface portions (i.e., “a first user interface portion”, “a second user interface portion”, “a third user interface portion”. The additional element(s) is/ are recited at a high level of generality (i.e., as a generic computer performing the generic computer functions of (a) data processing (e.g., “connecting”, “performing”, “training”, “inputting”, “determining”, etc. step(s) as claimed); (b) data receipt/ transmission (e.g., “collecting”, etc. step(s) as claimed); (c) data display (e.g., “providing for display to a client device” step(s) as claimed)). The additional element(s) is/ are recited at a high level of generality (i.e., as general means of gathering information for one or more employees of an enterprise, and amounts to mere data gathering, which is a form of insignificant extra-solution activity. The technology used to perform the steps or acts is also recited at a high level of generality, and merely automates the step(s). Accordingly, the additional element(s) does not integrate the abstract idea into a practical application because it does not impose any meaningful limitations on practicing the abstract idea. The claim is directed to an abstract idea.
Since the claim(s) recite a judicial exception and fails to integrate the judicial exception into a practical application, the claim(s) is/are “directed to” the judicial exception. Thus, the claim(s) must be reviewed under the second step of the Alice/ Mayo analysis to determine whether the abstract idea has been applied in an eligible manner.
2(B): The claims do not provide an inventive concept (i.e., The claim(s) do not include additional elements, or combinations of elements, that are sufficient to amount to significantly more than the judicial exception (i.e., abstract idea)).
As discussed with respect to Step 2A Prong Two, the additional element(s) in the claim amounts to no more than mere instructions to apply the exception using a generic computer component. The same analysis applies here in 2B, i.e., mere instructions to apply an exception using a generic computer component cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B.
Furthermore, the additional element(s) under STEP 2A Prong 2 have been evaluated in STEP 2B to determine if it is more than what is well-understood, routine conventional activity in the field. Applicant’s specification as filed 08/05/22 does not provide any indication that there is anything other than a generic, off-the-shelf computer component. Furthermore, the prosecution history of the instant application provides Hull operating in a similar environment, suggesting performing tasks such as (a) data processing (e.g., “connecting”, “performing”, “training”, “inputting”, “determining”, etc. step(s) as claimed); (b) data receipt/ transmission (e.g., “collecting”, etc. step(s) as claimed); (c) data display (e.g., “providing for display to a client device” step(s) as claimed) are well understood, routine and conventional. Furthermore, the courts have recognized that computer functions or tasks analogous to those claimed (a) data processing (e.g., “connecting”, “performing”, “training”, “inputting”, “determining”, etc. step(s) as claimed); (b) data receipt/ transmission (e.g., “collecting”, etc. step(s) as claimed); (c) data display (e.g., “providing for display to a client device” step(s) as claimed) are well understood, routine and conventional. Flook, Bancorp court decisions cited in MPEP § 2106.05(D) (ii) indicate performing repetitive calculations is a well-understood, routine, and conventional function when it is claimed in a merely generic manner (as here). Symantec, TLI, OIP Techs and buySAFE court decisions cited in MPEP § 2106.05(D) (ii) indicate that mere collection or receipt of data over a network is a well-understood, routine, and conventional function when it is claimed in a merely generic manner (as here). SAP America Inc. v. Investpic, LLC, 890 F.3d 1016 USPQ2d 1638 (Fed Cir. 2018) (displaying and disseminating financial information) and Intellectual Ventures 1 LLC v. Capital One Bank (USA) (advanced internet interface providing user display access of customized web pages) indicate displaying information is a well-understood, routine, and conventional function when it is claimed in a merely generic manner (as here). Accordingly, a conclusion that the additional elements are well-understood, routine, conventional activity is supported under Berkheimer.
For these reasons, there is no invention concept in the claim, and thus the claim is ineligible.
Dependent claims 2 - 14 are rejected as ineligible subject matter under 35 U.S.C. 101 based on a rationale similar to the claims from which they depend.
Alice Corp. also establishes that the same analysis should be used for all categories of claims (e.g., product and process claims). Therefore, independent system claim 15 and independent non-transitory computer-readable medium claim 20 is/are also rejected as ineligible subject matter under 35 U.S.C. 101 for substantially the same reasons as the method claims (claims 1 - 14). The component(s) (e.g., “one or more servers each including a processor and memory”, “processing engine, executable via the one or more servers”, etc.) described in independent system claim 15 and the component(s) (e.g., “non-transitory computer-readable medium”, “processing engine executable by one or more servers”) described in independent non-transitory computer-readable medium claim 20, add nothing of substance to the underlying abstract idea. At best, the product (system; non-transitory computer-readable medium) recited in the claim(s) are merely providing an environment to implement the abstract idea.
Dependent claims 16 - 19 are rejected as ineligible subject matter under 35 U.S.C. 101 based on a rationale similar to the claims from which they depend.
Response to Arguments
Objections
Withdrawn in light of applicant’s arguments and/ or amendments.
101
Applicant's arguments have been fully considered but they are not persuasive.
(1)Applicant argues the claim(s) are not directed to a judicial exception (i.e., an abstract idea).
Certain Method of Organizing Human Activity
The claimed invention is directed to certain methods of organizing human activity.
Fundamental economic principles or practices relate to the economy and commerce. The claimed invention encompasses fundamental economic principles or practices as it relates to mitigating risk (e.g., attrition, training courses).
The claimed invention encompasses commercial or legal interactions. The claimed invention relates to mitigating risk (e.g., attrition, training courses). Mitigating risk, in the instant scenario, pertains to agreements in the form of “legal obligations”, “marketing activities or behaviors” and “business relations”.
The claimed invention encompasses managing personal behavior or relationships or interactions (e.g., “connecting”, “collecting”, “performing”, “training”, “inputting”, “determining”, “providing”).
See also, MPEP §2106.04(a)(2)(II).
(2)Applicant argues the judicial exception (i.e., an abstract idea) is integrated into a practical application.
Applicant’s arguments suggesting the claimed invention applies the judicial exception with, or by use of, a particular machine suggests the applicant believes the technical aspects of the invention are substantial. There exists alternative perspectives however.
When determining whether a machine recited in a claim provides significantly more, several factors are relevant such as the particularity or generality of the elements of the machine or apparatus; whether the machine or apparatus implements the steps of the method; and whether it’s involvement is extra-solution activity or a field of use.
First, when looking at the particularity or generality of a machine or apparatus the degree to which the machine in the claim can be specifically identified (not any and all machines) is important. In the instant case most or all of the steps or acts are performed by a general purpose computer (i.e., “processing engine comprising: a network module; a feed collector module; a machine learning module; and an output module;” and executing “via one or more servers” in method claims 1 - 14; “one or more servers each including a processor and memory”, “processing engine, executable via the one or more servers” in system claims 15 - 19; “non-transitory computer-readable medium”, “processing engine executable by one or more servers” in non-transitory computer-readable medium claim 20) that applies the judicial exception by use of conventional computer functions. This does not qualify as a particular machine. This rationale also applies to any suggestion that there is a particular machine because the machine is programmed (i.e., “processing engine”; “processing engine comprising: a network module; a feed collector module; a machine learning module; and an output module;”).
Second, although the claim invention recites computers or other machinery (i.e., “processing engine comprising: a network module; a feed collector module; a machine learning module; and an output module;” and executing “via one or more servers” in method claims 1 - 14; “one or more servers each including a processor and memory”, “processing engine, executable via the one or more servers” in system claims 15 - 19; “non-transitory computer-readable medium”, “processing engine executable by one or more servers” in non-transitory computer-readable medium claim 20), the computers or other machinery are used “merely as a tool to perform an existing process”. This does not amount to significantly more than a judicial exception.
Third, the machine does not impose meaningful limitations on the claim. The machine is limited to (a) “data gathering” (e.g., “collecting, by the feed collector module at user specified intervals, a plurality of internal feed data from the internal data sources and external feed data from the external data sources, the internal feed data relating to one or more employees of the enterprise;”.); (b) “selecting a particular data source or type of data to be manipulated” (e.g., “connecting, by the network module, to one or more internal data sources within an enterprise, one or more external data sources outside of the enterprise, and one or more client devices;”); and (c) “insignificant application” (e.g., “performing by the output module the operations of: providing for display to a client device, a first user interface portion depicting separate groupings having an indication of a number of the employees having a particular attrition risk factor determined by the machine learning network; and providing for display to the client device, a second user interface portion depicting a listing of employees being associated with the particular attrition risk factor, wherein the second user interface portion includes a graphical indication of each of the employees depicted in the listing”; and “providing for display, by the output module, to the client device, a third user interface portion depicting a graphical indication of the determined recommendations for reducing attrition, wherein the third user interface portion receives a selection for a recommendation for reducing attrition, and receives a selection for creating a retention task for one or more of the employees”.).
See also, MPEP §2106.05(b).
With respect to applicant’s suggestion that the claimed invention is integrated into a practical application because it employs machine learning.
The court in Recentive Analytics concluded, “patents that do no more than claim the application of generic machine learning to new data environments, without disclosing improvements to the machine learning models to be applied are patent ineligible under § 101.” See pg. 18 of Recentive Analytics. See Recentive Analytics, Inc. v. Fox Corp. United States Cour of Appeals for the Federal Circuit. 2023-2437.
Applicant suggests the claimed invention presents a “practical application” because it provides a technical solution to a technical problem (e.g., “Accordingly, the presently amended claims are subject-matter eligible a technical solution of optimized machine learning training …..” See pg. 12 of applicant’s arguments/ remarks as filed 9/05/25.); and provides improvements in the functioning of a computer, or to any other technology or technical field (e.g., “Accordingly, any purported abstract idea recited in presently amended claims is integrated into a practical application as the claim limitations improve the functionality of the computer and the improvement of a machine learning model”. See pg. 12 of applicant’s arguments/ remarks as filed 9/05/25.). The Examiner disagrees.
Applicant’s arguments suggesting the claimed invention provides a technical solution to a technical problem; and provides improvements in the functioning of a computer, or to any other technology or technical field suggests the applicant believes the technical aspects of the invention are substantial. There exists alternative perspectives however.
With respect to applicant’s “solution”/ “improvements”. Mitigating risk (e.g., attrition, training courses) is directed to the underlying abstract idea, not the functioning of the computer itself. What applicant is really arguing is the use of a computer as a tool or the benefits of automation itself.
Adding the words “apply it” (or an equivalent) with the judicial exception is not
not indicative of integration into a practical application. See also, MPEP § 2106.05(f). Merely using a computer as a tool to perform an abstract idea; and mere instructions to implement an abstract idea on a computer are not indicative of integration into a practical application. See also, MPEP §2106.05(f).
Furthermore, what applicant characterizes as a “solution”/ “improvement” (e.g. “machine learning model”, “optimized machine learning training”) is really general linking the use of the judicial exception to a particular technological environment or field of use. For example, applicant has not described improvement to “machine learning” itself, but rather it’s use with respect to attrition, training courses. The technology is used as expected.
Collecting information (e.g., “collecting, ….. at user specified intervals, a plurality of internal feed data from the internal data sources and external feed data from the external data sources, the internal feed data relating to one or more employees of the enterprise;” and “wherein the third user interface portion receives a selection for a recommendation for reducing attrition, and receives a selection for creating a retention task for one or more of the employees”); and analyzing it (e.g., “connecting ….. to one or more internal data sources within an enterprise, one or more external data sources outside of the enterprise, and one or more client devices”; “performing ….. the operations of: training a machine learning network to determine attrition risk factors, the machine learning network comprising a neural network, wherein the neural network includes connected nodes that are aggregated into layers and node weights that determine how signals are processed via the connected nodes, wherein the training the machine learning network adjusts the node weights, wherein a strength of ties between the nodes indicates an employee attribution risk; inputting into the trained machine learning network the plurality of internal feed data; and determining, via the trained machine learning network, based on at least the input internal feed data, a plurality of attrition risk factors for the employees, the attrition risk factors being selected from a prespecified list of potential attrition risk factors including the risk factors of compensation, connection and growth”; “determining ….. recommendations for reducing attrition for a group of the employees”; and “performing a selected retention task …..” ) and displaying certain results of the collection and analysis (e.g., “performing ….. the operations of: providing for display to a client device, a first user interface portion depicting separate groupings having an indication of a number of the employees having a particular attrition risk factor determined by the machine learning network; and
providing for display to the client device, a second user interface portion depicting a listing of employees being associated with the particular attrition risk factor, wherein the second user interface portion includes a graphical indication of each of the employees depicted in the listing”; and “providing for display, ….. to the client device, a third user interface portion depicting a graphical indication of the determined recommendations for reducing attrition”) merely indicates a field of use or technical environment in which to apply the judicial exception.
Generally linking the use of the judicial exception to a particular technological environment or field of use is not indicative of integration into a practical application. See also, MPEP §2106.05 (h).
Contrary to applicant’s arguments, features applicant relies upon are “insignificant”. For example, they amount to “necessary data gathering and outputting” (e.g., “collecting, ….. at user specified intervals, a plurality of internal feed data from the internal data sources and external feed data from the external data sources, the internal feed data relating to one or more employees of the enterprise”; and “wherein the third user interface portion receives a selection for a recommendation for reducing attrition, and receives a selection for creating a retention task for one or more of the employees”).
Adding insignificant extra-solution activity to the judicial exception is not indicative of integration into a practical application. See also, MPEP §2106.05 (g).
(3) Applicant argues the claimed invention is significantly more than the judicial exception (i.e., abstract idea).
As discussed with respect to Step 2A Prong Two, the additional element(s) in the claim amounts to no more than mere instructions to apply the exception using a generic computer component. The same analysis applies here in 2B, i.e., mere instructions to apply an exception using a generic computer component cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B.
Furthermore, the additional element(s) under STEP 2A Prong 2 have been evaluated in STEP 2B to determine if it is more than what is well-understood, routine conventional activity in the field. Applicant’s specification as filed 08/05/22 does not provide any indication that there is anything other than a generic, off-the-shelf computer component. Furthermore, the prosecution history of the instant application provides Hull operating in a similar environment, suggesting performing tasks such as (a) data processing (e.g., “connecting”, “performing”, “training”, “inputting”, “determining”, etc. step(s) as claimed); (b) data receipt/ transmission (e.g., “collecting”, etc. step(s) as claimed); (c) data display (e.g., “providing for display to a client device” step(s) as claimed) are well understood, routine and conventional. Furthermore, the courts have recognized that computer functions or tasks analogous to those claimed (a) data processing (e.g., “connecting”, “performing”, “training”, “inputting”, “determining”, etc. step(s) as claimed); (b) data receipt/ transmission (e.g., “collecting”, etc. step(s) as claimed); (c) data display (e.g., “providing for display to a client device” step(s) as claimed) are well understood, routine and conventional. Flook, Bancorp court decisions cited in MPEP § 2106.05(D) (ii) indicate performing repetitive calculations is a well-understood, routine, and conventional function when it is claimed in a merely generic manner (as here). Symantec, TLI, OIP Techs and buySAFE court decisions cited in MPEP § 2106.05(D) (ii) indicate that mere collection or receipt of data over a network is a well-understood, routine, and conventional function when it is claimed in a merely generic manner (as here). SAP America Inc. v. Investpic, LLC, 890 F.3d 1016 USPQ2d 1638 (Fed Cir. 2018) (displaying and disseminating financial information) and Intellectual Ventures 1 LLC v. Capital One Bank (USA) (advanced internet interface providing user display access of customized web pages) indicate displaying information is a well-understood, routine, and conventional function when it is claimed in a merely generic manner (as here). Accordingly, a conclusion that the additional elements are well-understood, routine, conventional activity is supported under Berkheimer.
For these reasons, there is no invention concept in the claim, and thus the claim is ineligible.
Dependent claims 2 - 14 are rejected as ineligible subject matter under 35 U.S.C. 101 based on a rationale similar to the claims from which they depend.
Alice Corp. also establishes that the same analysis should be used for all categories of claims (e.g., product and process claims). Therefore, independent system claim 15 and independent non-transitory computer-readable medium claim 20 is/are also rejected as ineligible subject matter under 35 U.S.C. 101 for substantially the same reasons as the method claims (claims 1 - 14). The component(s) (e.g., “one or more servers each including a processor and memory”, “processing engine, executable via the one or more servers”, etc.) described in independent system claim 15 and the component(s) (e.g., “non-transitory computer-readable medium”, “processing engine executable by one or more servers”) described in independent non-transitory computer-readable medium claim 20, add nothing of substance to the underlying abstract idea. At best, the product (system; non-transitory computer-readable medium) recited in the claim(s) are merely providing an environment to implement the abstract idea.
Dependent claims 16 - 19 are rejected as ineligible subject matter under 35 U.S.C. 101 based on a rationale similar to the claims from which they depend.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant’s disclosure and relates to training courses and/ or employee attrition risk.
US 11715053 B1
US 11651314 B1
US 20220351846 A1
WO 2022051538 A1
US 20210216941 A1
WO 2021092165 A1
WO 2021061669 A1
US 20120233108 A1
US 20090307025 A1
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 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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SARA CHANDLER HAMILTON
Primary Examiner
Art Unit 3695
/SARA C HAMILTON/Primary Examiner, Art Unit 3695