Prosecution Insights
Last updated: October 04, 2026
Application No. 17/882,201

TOOTH MOVEMENT CONTROL BASED ON SURFACE ENGAGEMENT

Final Rejection §101§103
Filed
Aug 05, 2022
Examiner
WHITE, JAY MICHAEL
Art Unit
2188
Tech Center
2100 — Computer Architecture & Software
Assignee
Sdc U S Smilepay Spv
OA Round
2 (Final)
47%
Grant Probability
Moderate
3-4
OA Rounds
0m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 47% of resolved cases
47%
Career Allowance Rate
8 granted / 17 resolved
-7.9% vs TC avg
Strong +100% interview lift
Without
With
+100.0%
Interview Lift
resolved cases with interview
Typical timeline
4y 2m
Avg Prosecution
30 currently pending
Career history
46
Total Applications
across all art units

Statute-Specific Performance

§101
27.6%
-12.4% vs TC avg
§103
34.9%
-5.1% vs TC avg
§102
11.3%
-28.7% vs TC avg
§112
24.2%
-15.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 17 resolved cases

Office Action

§101 §103
DETAILED ACTION This Final Office Action is responsive to the claims filed on June 17, 2026. Claims 1-20 are under examination. Claims 1-20 are rejected under 35 USC 101 as ineligible. Claims 1-20 are rejected under 35 USC 103 over Morton and Kukk. Response To Arguments/Amendments Claim Objections: The Applicant’s arguments and amendments have been considered and are persuasive. The objections are withdrawn. 35 USC 101: The Applicant’s arguments and amendments have been considered but are not persuasive. The Applicant’s arguments will be treated in the order presented in the Applicant’s response. The Claims Allegedly Do Not Recite An Abstract Idea: The Applicant is looking at the claim as a whole to see whether the whole of the claim is an abstract idea. That is not the test, The question is whether any of the limitations qualify as an abstract idea. The Applicant attempts to argue that the faces of the tooth would be too numerous for a person to calculate. The Applicant misconstrues the standard for practical limitations to mental processes, as the CAFC Recentive case states, Finally, the claimed methods are not rendered patent eligible by the fact that (using existing machine learning technology) they perform a task previously undertaken by humans with greater speed and efficiency than could previously be achieved. We have consistently held, in the context of computer-assisted methods, that such claims are not made patent eligible under § 101 simply because they speed up human activity. See, e.g., Content Extraction, 776 F.3d at 1347; DealerTrack, 674 F.3d at 1333. Whether the issue is raised at step one or step two, the increased speed and efficiency resulting from use of computers (with no improved computer techniques) do not themselves create eligibility. See, e.g., Trinity Info Media, LLC v. Covalent, Inc., 72 F.4th 1355, 1363 (Fed. Cir. 2023) (rejecting argument that “humans could not mentally engage in the ‘same claimed process’ because they could not perform ‘nanosecond comparisons’ and aggregate ‘result values with huge numbers of polls and members’”) (internal citation omitted); Customedia Techs., LLC v. Dish Network Corp., 951 F.3d 1359, 1365 (Fed. Cir. 2020) (holding claims abstract where “[t]he only improvements identified in the specification are generic speed and efficiency improvements inherent in applying the use of a computer to any task”); compare McRo, 837 F.3d at 1314– Case: 23-2437 Document: 51 Page: 15 Filed: 04/18/2025 RECENTIVE ANALYTICS, 16 INC. v. FOX CORP. 16 (finding eligibility of claims to use specific computer techniques different from those humans use on their own to produce natural-seeming lip motion for speech) Further, the Applicant’s response not only confirms that the features identified as abstract ideas are mental processes but further concedes that each of these operations the Office identified as mental processes are also mathematical concepts, illustrating that all of the steps identified as elements of the abstract idea are directed to the math performed. The Applicant then attempts to say that the claims are directed to a technical solution within the section that argues the recitation of an abstract idea in a claim. This argument is misplaced, as it belongs in Step 2A, Prong 2, rather than Step 2A, Prong 1. Also, the Applicant attempts to analogize the Applicant’s claims to Enfish and McRO, but the claims are nothing like the claims in Enfish or McRO. Enfish claimed a new data structure that improved computer functionality. McRO similarly renders information into a specific computerized format that is then used and applied to create desired results. These are essentially data structures that invoke computing itself, e.g., in the context of providing improved computer functionality. The Applicant’s claims do not generate new data structures/formats because the computing elements are easily separable to make the claim limitations performable without the computer. Therefore, the Applicant has failed to demonstrate that the claims do not recite an abstract idea. The Claims Allegedly Recite A Practical Application: The Applicant correctly recites the standard that the Applicant is expected to identify additional limitations that integrate the abstract idea into a practical application. The Applicant then fails to do so. The Applicant then attempts to assert that the claimed invention improves the control of teeth during repositioning, but the claim does not recite this limitation. The Applicant then attempts to characterize a geometry of a model as tangible, which the data representation inherently is not. The Applicant then says that the determinations of the claims enables manufacture of modeled elements. However, this is no different from making a diagnosis, which is considered a mental process or insignificant extra-solution activity as a data gathering step. As it stands, all of the asserted improvements, if the claim elements indeed confer the improvements, are conferred by the abstract idea. The Applicant generically states that the claim confers an improvement, however, the Applicant has failed to identify any additional limitation in the claim that integrates the abstract idea into a practical application. Accordingly, the Applicant’s arguments and amendments are not persuasive, and the rejections are maintained. 35 USC 103: The Applicant’s amendments have been considered and are persuasive. However, a new art rejection necessitated by the Applicant’s amendments has been introduced. 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. Subject Matter Eligibility Claims 1-20 are rejected under 35 U.S.C. 101 for being directed to a judicial exception without significantly more. Step 1 Claims 1-15 are directed to processes. Claims 16-20 are directed to machines. Independent Claims Step 2A, Prong 1 Independent claims -----1, 12, and 16 recite a mental process, an abstract idea. Claim 1 Claim 1 recites A method comprising: […] Determining […] a factor of engagement for each of the plurality of tooth faces based on a degree of normality of each tooth face with respect to a direction of a movement for the at least one tooth; (Mental Evaluation, Mental Process – The determination of engagement factors for tooth faces based on the orientation and direction of motion of the teeth is an evaluation practically performable in the mind or with aid of pen and paper. Orthodontists performed these analyses long before relying on software for assistance.) Determining […] an addressable area of the at least one tooth based on the factors of engagement of the plurality of tooth faces, wherein the addressable area comprises at least one of the plurality of tooth faces, wherein the factor of engagement for each tooth face in the at least one of the plurality of tooth faces satisfies a threshold; (Mental Evaluation, Mental Process – The determination of whether engagement factors for tooth faces based on the orientation and direction of motion of the teeth satisfy criteria/thresholds is an evaluation practically performable in the mind or with aid of pen and paper. Orthodontists performed these analyses long before relying on software for assistance.) Identifying […] an area of engagement of the at least one tooth, wherein the area of engagement comprises at least a portion of the addressable area, the portion comprising at least one tooth face accessible by a dental appliance to apply a force to the at least one tooth to effectuate the movement; (Mental Evaluation, Mental Process – The identification of where to have an aligner apply pressure on a tooth to apply a force is an evaluation practically performable in the mind or with aid of pen and paper. Orthodontists performed these analyses long before relying on software for assistance.) outputting, by the one or more processors, a controllability score for the at least one tooth based on the area of engagement, wherein the controllability score indicates an ability to control a movement of the at least one tooth; and (Mental Evaluation, Mental Process – The determination and output of a score is an evaluation practically performable in the mind or with aid of pen and paper. Orthodontists performed these analyses long before relying on software for assistance.) generate, by the one or more processors, an inner surface geometry of a digital model of a dental appliance based on the first movement to increase the area of engagement between the dental appliance and the at least one tooth. (Mental Evaluation, Mental Process – The generation of a geometry of a surface based on data is an evaluation practically performable in the mind and with aid of pen and paper.) Claim 1 recites mental processes and, hence, under MPEP 2106.04(a)(2)(III), an abstract idea. Claims 12 and 16 Claim 16 recites, identify an area of engagement of at least one tooth represented in a digital model of a dentition for applying a first force to move the at least one tooth according to a first movement as part of a treatment plan or a second force to move the at least one tooth according to a second movement as part of the treatment plan, wherein the treatment plan is configured to move the at least one tooth from an initial position to a final position, and wherein the area of engagement comprises a portion of the at least one tooth that is capable of engaging with a dental aligner to be manufactured to apply the first force or the second force to the at least one tooth via the area of engagement to move the at least one tooth; (Mental Evaluation, Mental Process – The identification of where to have an aligner apply pressure on a tooth to apply a force based on available force and engagement knowledge is an evaluation practically performable in the mind or with aid of pen and paper. Orthodontists performed these analyses long before relying on software for assistance.) determine a first controllability score for the first movement and a second controllability score for the second movement based on the area of engagement, the first force associated with the first movement, and the second force associated with the second movement, wherein the first controllability score indicates an ability to achieve the first movement and the second controllability score indicates an ability to achieve the second movement;; (Mental Evaluation, Mental Process – Quantifying a quality of controllability of a particular treatment plan based on the orientation and direction of motion of the teeth is an evaluation practically performable in the mind or with aid of pen and paper. Orthodontists performed these analyses long before relying on software for assistance.) select the first movement for the treatment plan based on the first controllability score and the second controllability score; and (Mental Evaluation, Mental Process – Determining a treatment plan based on how well you can control tooth movement is an evaluation practically performable in the mind or with aid of pen and paper. Orthodontists performed these analyses long before relying on software for assistance.) generating, by the one or more processors, an inner surface geometry of a digital model of a dental appliance based on the first movement to increase the area of engagement between the dental appliance and the at least one tooth. (Mental Evaluation, Mental Process – The generation of a geometry of a surface based on data is an evaluation practically performable in the mind and with aid of pen and paper.) Regarding claim 12, claim 12 recites the operations that the system of claim 16 is configured to perform and recites an abstract idea for at least the same reasons Claims 1, 12, and 16 recite an abstract idea. Step 2A, Prong 2 The claims fail to recite additional limitations that integrate the abstract idea into a practical application. Claim 1 Claim 1 recites the following additional limitations: receiving […] a digital model of a dentition, the digital model comprising at least one tooth comprising a plurality of tooth faces; The receiving step is mere data gathering, which is insignificant extra-solution activity similar to the MPEP 2106.05(g) examples: “e.g., a step of obtaining information about credit card transactions, which is recited as part of a claimed process of analyzing and manipulating the gathered information by a series of steps in order to detect whether the transactions were fraudulent.” “iv. Obtaining information about transactions using the Internet to verify credit card transactions” “v. Consulting and updating an activity log” “vi. Determining the level of a biomarker in blood” “iii. Selecting information, based on types of information and availability of information in a power-grid environment, for collection, analysis and display.” The receiving step is insignificant extra-solution activity, and, under MPEP 2106.05(g), fails to integrate the abstract idea into a practical application at Step 2A, Prong 2. […], by the one or more processors, […] […] digital model […] These are generic computing elements recited at a high level of generality, which, under MPEP 2106.05(f), fail to integrate the abstract idea into a practical application at Step 2A, Prong 2. Also, the real-world quantities the data represents, if any, merely limit the abstract idea to a field of technology and, under MPEP 2106.05(h), fail to integrate the abstract idea into a practical application. Claim 1 fails to recite any additional limitations that integrate the abstract idea into a practical application. Claim 16 Claim 16 recites the following additional limitations: A system comprising: one or more processors; and a memory coupled with the one or more processors, wherein the memory stores instructions that, when executed by the one or more processors, cause the one or more processors to: These are generic computing elements recited at a high level of generality, which, under MPEP 2106.05(f), fail to integrate the abstract idea into a practical application at Step 2A, Prong 2. Also, the real-world quantities the data represents, if any, merely limit the abstract idea to a field of technology and, under MPEP 2106.05(h), fail to integrate the abstract idea into a practical application. Claim 12 Claim 12 recites the following additional limitations: […], by the one or more processors, […] These are generic computing elements recited at a high level of generality, which, under MPEP 2106.05(f), fail to integrate the abstract idea into a practical application at Step 2A, Prong 2. Also, the real-world quantities the data represent, if any, merely limit the abstract idea to a field of technology and, under MPEP 2106.05(h), fail to integrate the abstract idea into a practical application. Claims 1, 12, and 16 fail to recite any additional limitations that integrate the abstract idea into a practical application at Step 2A, Prong 2. Claims 1, 12, and 16 are directed to the abstract idea. Step 2B The claims fail to recite additional limitations that combine with the other elements of the claim to provide significantly more than the abstract idea that would confer an inventive concept. Claim 1 Claim 1 recites the following additional limitations: receiving […] a digital model of a dentition, the digital model comprising at least one tooth comprising a plurality of tooth faces; The receiving step is well-understood, routine, and conventional (WURC) activity similar to the MPEP 2106.05(d) examples: “i. Receiving or transmitting data over a network” “iii. Electronic recordkeeping” “iv. Storing and retrieving information in memory” “v. Electronically scanning or extracting data from a physical document” “i. Determining the level of a biomarker in blood by any means” The receiving step is WURC and, as previously demonstrated, insignificant extra-solution activity, and, under MPEP 2106.05(d) and 2106.05(g), fails to combine with the other elements of the claim to provide significantly more than the abstract idea that would confer an inventive concept at Step 2B. […], by the one or more processors, […] […] digital model […] These are generic computing elements recited at a high level and, under MPEP 2106.05(f), fail to combine with the other elements of the claim to provide significantly more than the abstract idea that would confer an inventive concept at Step 2B. Should it be found otherwise, these limitations merely limit the abstract idea top a particular technological field and, under MPEP 2106.05(h), fail to combine with the other elements of the claim to provide significantly more than the abstract idea that would confer an inventive concept at Step 2B. Also, the real-world quantities the data represents, if any, merely limit the abstract idea to a field of technology and, under MPEP 2106.05(h), fail to combine with the other elements of the claim to provide significantly more than the abstract idea that would confer an inventive concept at Step 2B. Claim 16 Claim 16 recites the following additional limitations: A system comprising: one or more processors; and a memory coupled with the one or more processors, wherein the memory stores instructions that, when executed by the one or more processors, cause the one or more processors to: […] digital model […] These are generic computing elements recited at a high level and, under MPEP 2106.05(f), fail to combine with the other elements of the claim to provide significantly more than the abstract idea that would confer an inventive concept at Step 2B. Should it be found otherwise, these limitations merely limit the abstract idea top a particular technological field and, under MPEP 2106.05(h), fail to combine with the other elements of the claim to provide significantly more than the abstract idea that would confer an inventive concept at Step 2B. Also, the real-world quantities the data represents, if any, merely limit the abstract idea to a field of technology and, under MPEP 2106.05(h), fail to combine with the other elements of the claim to provide significantly more than the abstract idea that would confer an inventive concept at Step 2B. Claim 12 Claim 12 recites the following additional limitations: […], by the one or more processors, […] […] digital model […] These are generic computing elements recited at a high level of generality, which, under MPEP 2106.05(f), fail to combine with the other elements of the claim to provide significantly more than the abstract idea that would confer an inventive concept at Step 2B. Should it be found otherwise, these limitations merely limit the abstract idea top a particular technological field and, under MPEP 2106.05(h), fail to combine with the other elements of the claim to provide significantly more than the abstract idea that would confer an inventive concept at Step 2B. Also, the real-world quantities the data represents, if any, merely limit the abstract idea to a field of technology and, under MPEP 2106.05(h), fail to combine with the other elements of the claim to provide significantly more than the abstract idea that would confer an inventive concept at Step 2B. Claims 1, 12, and 16 fail to provide additional limitations that combine with the other elements of the claim to provide significantly more than the abstract idea that would confer an inventive concept. Claims 1, 12, and 16 are ineligible. Dependent Claims: The dependent claims are also ineligible for the following reasons. Note: The hardware of the system, memory, and one or more processors have already been addressed in the independent claims as failing to confer eligibility under MPEP 2106.05(f), and will not be further addressed with respect to the dependent claims. Also, claims identifying what data represents merely limits the abstract idea to a particular technological field and, under MPEP 2106.05(h), fails to confer eligibility. Claim 2 further comprising selecting the movement for a treatment plan configured to move the at least one tooth from an initial position to a final position based on the controllability score. The selection of movement in a treatment plan based on available data is a mental evaluation, a mental process, abstract idea that is practically performable in the mind or with aid of a pen, paper, and/or calculator. This limitation merges with the abstract idea of the independent claim. Claim 2 fails to provide any additional limitations that confer eligibility at Step 2A, Prong 2 and Step 2. Claim 2 is ineligible. Claim 3 Determining […] a face normalized unit vector for each of the plurality of tooth faces; determining, by the one or more processors, a movement normalized unit vector for each of the plurality of tooth faces; and determining, by the one or more processors, a relative angle between the face normalized unit vector and the movement normalized unit vector for each tooth face. These determinations are all ones that an orthodontist considers when creating or adjusting a treatment plan. They are evaluations practically performable in the mind or with aid of pen, paper, and/or a calculator. Therefore, there are mental processes, abstract ideas that merge with the abstract idea of the independent claim. Claim 3 fails to provide any additional limitations that confer eligibility at Step 2A, Prong 2 and Step 2. Claim 3 is ineligible. Claim 4 wherein the addressable area is an actual addressable area, This merely qualifies what the data represents and merely limits the abstract idea to a particular area of technology, which, under MPEP 2106.05(h), fails to confer eligibility. and determining the actual addressable area comprises: (This is addressed in the independent claim) determining […] a total addressable area, wherein the total addressable area comprises a first subset of the plurality of tooth faces of the at least one tooth, wherein the factors of engagement of the first subset of the plurality of tooth faces satisfy the threshold; Determining an area on the tooth available for potential engagement is an evaluation practically performable in the mind or with aid of pen and paper, so it is a mental process, an abstract idea that merges with the abstract idea of the independent claim. Identifying […] an obstruction that prevents at least one of the plurality of tooth faces of the first subset from being able to receive the force; and Determining an obstruction along a planned path of movement is an evaluation practically performable in the mind or with aid of pen and paper, so it is a mental process, an abstract idea that merges with the abstract idea of the independent claim. Determining […] the actual addressable area, wherein the actual addressable area comprises the at least one tooth face, wherein the at least one tooth face is capable of receiving the force despite the obstruction. Determining where to apply force by an aligner in response to an obstruction is an evaluation practically performable in the mind or with aid of pen and paper, so it is a mental process, an abstract idea that merges with the abstract idea of the independent claim. Claim 4 fails to provide any additional limitations that confer eligibility at Step 2A, Prong 2 and Step 2. Claim 4 is ineligible. Claim 5 wherein outputting the controllability score comprises: (This output itself was addressed in the independent claim.) determining […] an available force vector for the at least one tooth face within the area of engagement; determining […] an available moment vector for the at least one tooth face within the area of engagement; and These determinations are evaluations practically performable in the mind or with the aid of pen, paper, and/or a calculator, so they are mental processes, abstract ideas. summing, by the one or more processors, the available force vectors and the available moment vectors. Summing is an evaluation that is practically performable in the mind or with aid of pen, paper, and/or a calculator, so it is a mental process, and abstract idea. Further, summing is a mathematical operation, a mathematical calculation, an abstract idea.) Claim 5 fails to provide any additional limitations that confer eligibility at Step 2A, Prong 2 and Step 2. Claim 5 is ineligible. Claim 6 wherein the controllability score is a first controllability score, the method further comprising: This describes the data in the claim and merely limits the claim to a particular technological environment and, under MPEP 2106.05(h), fails to confer eligibility at Step 2A, Prong 2 and Step 2B receiving […] a model dental appliance; This receiving step is mere data gathering and fails to confer eligibility for at least the same reason as the receiving step of claim 1. adjusting […] the area of engagement by modifying a geometry of the model dental appliance; and Modifying the geometry of a model is an evaluation that can be practically performed in the mind or with the aid of pen and paper, so this is a mental evaluation, an abstract idea. determining […] a second controllability score for the at least one tooth based on the adjusted area of engagement, wherein the second controllability score is greater than the first controllability score. Determining a controllability score based on an adjusted area of engagement is practically performable in the mind or with the aid of pen, paper, and a calculator, so this is a mental evaluation, an abstract idea. Claim 6 fails to provide any additional limitations that confer eligibility at Step 2A, Prong 2 and Step 2. Claim 6 is ineligible. Claim 7 Receiving […] the digital model of the dentition, the digital model comprising a plurality of teeth; This receiving step is mere data gathering and fails to confer eligibility for at least the same reason as the receiving step of claim 1. Identifying […] the area of engagement for each of the plurality of teeth; and Identifying an area of engagement of an aligner to a tooth is an evaluation that can be practically performed in the mind or with the aid of pen and paper, so this is a mental evaluation, an abstract idea. Determining […] a dentition controllability score based on the area of engagement for each of the plurality of teeth. Determining a controllability score based on an adjusted area of engagement is practically performable in the mind or with the aid of pen, paper, and a calculator, so this is a mental evaluation, an abstract idea. Claim 7 fails to provide any additional limitations that confer eligibility at Step 2A, Prong 2 and Step 2. Claim 7 is ineligible. Claim 8 receiving, by the one or more processors, the digital model of the dentition, the digital model comprising a plurality of teeth; This receiving step is mere data gathering and fails to confer eligibility for at least the same reason as the receiving step of claim 1. determining, by the one or more processors, a movement for at least one tooth of the plurality of teeth; Determining a movement of a tooth within a treatment plan is practically performable in the mind or with the aid of pen, paper, and a calculator, so this is a mental evaluation, an abstract idea. outputting, by the one or more processors, a first controllability score based on the movement of the at least one tooth; This outputting step fails to confer eligibility for the same reasons as the output step of claim 1. determining, by the one or more processors, an alternative movement for the at least one tooth; and Determining an alternative movement of a tooth within a treatment plan is practically performable in the mind or with the aid of pen, paper, and a calculator, so this is a mental evaluation, an abstract idea. outputting, by the one or more processors, a second controllability score based on the alternative movement for the at least one tooth. This outputting step fails to confer eligibility for the same reasons as the prior outputting step of this claim and the outputting step of claim 1. Claim 8 fails to provide any additional limitations that confer eligibility at Step 2A, Prong 2 and Step 2. Claim 8 is ineligible. Claim 9 comparing, by the one or more processors, the first controllability score and the second controllability score; and A comparison of two scores is practically performable in the mind or with the aid of pen, paper, and a calculator, so this is a mental evaluation, an abstract idea. generating, by the one or more processors, a step of the treatment plan based on the comparison of the first controllability score and the second controllability score. Determining or modifying a step of a treatment plan based on whether one number is higher than another is practically performable in the mind or with the aid of pen, paper, and a calculator, so this is a mental evaluation, an abstract idea. Claim 9 fails to provide any additional limitations that confer eligibility at Step 2A, Prong 2 and Step 2. Claim 9 is ineligible. Claim 10 determining, by the one or more processors, a plurality of movements for the at least one tooth based on a treatment plan, wherein each of the plurality of movements corresponds with a step of the treatment plan; and Determining movements of a tooth within a treatment plan is practically performable in the mind or with the aid of pen, paper, and a calculator, so this is a mental evaluation, an abstract idea. determining, by the one or more processors, a treatment plan controllability score based on the plurality of movements for the at least one tooth. Determining a controllability score based on movements of a tooth within a determined treatment plan is practically performable in the mind or with the aid of pen, paper, and a calculator, so this is a mental evaluation, an abstract idea. Claim 10 fails to provide any additional limitations that confer eligibility at Step 2A, Prong 2 and Step 2. Claim 10 is ineligible. Claim 11 further comprising determining a pushing force configured to move the at least one tooth from a first position to a second position. Determining a pushing force on a tooth within a determined treatment plan is practically performable in the mind or with the aid of pen, paper, and a calculator, so this is a mental evaluation, an abstract idea. Claim 11 fails to provide any additional limitations that confer eligibility at Step 2A, Prong 2 and Step 2. Claim 11 is ineligible. Claims 13 and 17 wherein the first movement is selected for the treatment plan based on the first controllability score exceeding the second controllability score. Selecting a first movement within a determined treatment plan based on a score exceeding another score is practically performable in the mind or with the aid of pen, paper, and a calculator, so this is a mental evaluation, an abstract idea. Claims 13 and 17 fail to provide any additional limitations that confer eligibility at Step 2A, Prong 2 and Step 2. Claims 13 and 17 are ineligible. Claims 14 and 18 determining, by the one or more processors, a third controllability score for a third movement subsequent to the first movement; and Determining a controllability score for a tooth movement within a determined treatment plan is practically performable in the mind or with the aid of pen, paper, and a calculator, so this is a mental evaluation, an abstract idea. determining, by the one or more processors, a fourth controllability score for a fourth movement subsequent to the second movement; Determining a controllability score for a tooth movement after another movement (e.g., a sequence of movements) within a determined treatment plan is practically performable in the mind or with the aid of pen, paper, and a calculator, so this is a mental evaluation, an abstract idea. wherein the first movement is selected for the treatment plan based on a summation of the first controllability score and the third controllability score exceeding a summation of the second controllability score and the fourth controllability score. Selecting a treatment plan based on a first sum of scores exceeding a second sum of scores is practically performable in the mind or with the aid of pen, paper, and a calculator, so this is a mental evaluation, an abstract idea. Also, the summations themselves are mathematical calculations, mathematical operations, abstract ideas. Claims 14 and 18 fail to provide any additional limitations that confer eligibility at Step 2A, Prong 2 and Step 2. Claims 14 and 18 are ineligible. Claims 15 and 20 wherein the at least one tooth is a first tooth, and wherein the first movement is selected for the treatment plan based on a controllability score of a movement selected to be applied to a second tooth represented in the digital model of the dentition. Selecting a movement for a tooth based on the controllability of a movement to be applied to a second tooth is practically performable in the mind or with the aid of pen, paper, and a calculator, so this is a mental evaluation, an abstract idea. Claims 15 and 20 fail to provide any additional limitations that confer eligibility at Step 2A, Prong 2 and Step 2. Claims 15 and 20 are ineligible. Claim 19 wherein the second controllability score exceeds the first controllability score. The determination that one score exceeds another score is practically performable in the mind or with the aid of pen, paper, and a calculator, so this is a mental evaluation, an abstract idea. Should it be found otherwise, this is a description of the data that merely limits the abstract idea to a particular technological environment. Claim 19 fails to provide any additional limitations that confer eligibility at Step 2A, Prong 2 and Step 2. Claim 19 is ineligible. Claim Rejections - 35 USC § 103 The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. Claims 1-20: Morton and Kukk Claim(s) 1-20 are rejected under 35 U.S.C. 103 as being unpatentable over US 20190314117 A1 to Morton et al. (Morton) in view of US 2023/0325558 A1 to Kukk et al. (Kukk). Claim 1 Regarding claim 1, Morton Teaches: A method comprising: receiving, by one or more processors, a digital model of a dentition, the digital model comprising at least one tooth comprising a plurality of tooth faces; (Morton Abstract “Orthodontic systems and related methods are disclosed for designing and providing improved or more effective tooth moving systems for eliciting a desired tooth movement and/or repositioning teeth into a desired arrangement. Methods and orthodontic systems of the invention include tooth attachments having improved or optimized parameters selected or modified for more optimal and/or effective application of forces for a desired/selected orthodontic movement.” – An orthodontic method. [0168] “The data processing aspects of the invention can be implemented in digital electronic circuitry, or in computer hardware, firmware, software, or in combinations of them. Data processing apparatus of the invention can be implemented in a computer program product tangibly embodied in a machine-readable storage device for execution by a programmable processor; and data processing method steps of the invention can be performed by a programmable processor executing a program of instructions to perform functions of the invention by operating on input data and generating output. The data processing aspects of the invention can be implemented advantageously in one or more computer programs that are executable on a programmable system including at least one programmable processor coupled to receive data and instructions from and to transmit data and instructions to a data storage system, at least one input device, and at least one output device.” – Processor and memory are used to conduct the computations. [0008] “The method includes receiving a digital model of the patient's tooth.” [0064] “FIG. 2C illustrates an attachment optimization process, according to an embodiment of the present invention. The process includes providing or creating a treatment or force application simulation environment. A simulation environment can include, e.g., computer modeling systems, biomechanical systems or apparatus, and the like. One or more aligner shapes or candidate attachment designs can be selected for testing or force modeling. As noted above, a desired tooth movement, as well as a force system required or desired for eliciting the desired tooth movement can be identified. Using the simulation environment, a candidate attachment shape(s) can be analyzed or modeled for determination of an actual force system resulting from use of the candidate attachment. One or more modifications can optionally be made to a candidate attachment, and force modeling can be further analyzed as described.” [0067] “The result of the determination is a desired force system to be applied to the tooth. An initial attachment geometry can be assumed and described by a group of parameters. The force system produced by this initial geometry may then be determined by computer modeling or measured directly. The force system may be defined with respect to a reference point, such as an axis of the tooth or any dental characteristic. The tooth morphology and surface orientation may be taken into account when determining the attachment design. The surface of the tooth may have an orientation such that when a generic attachment shape is bonded to the surface of the tooth, the force is not correctly directed.” – The computer models the environment, including the dentition. This includes the faces of the teeth of the dentition.) determining, by the one or more processors, a factor of engagement for each of the plurality of tooth faces based on a degree of normality of each tooth face with respect to a direction of a movement for the at least one tooth; determining, by the one or more processors, an addressable area of the at least one tooth based on the factors of engagement of the plurality of tooth faces, wherein the addressable area comprises at least one of the plurality of tooth faces, wherein the factor of engagement for each tooth face in the at least one of the plurality of tooth faces satisfies a threshold; (Morton [0067] “The surface of the tooth may have an orientation such that when a generic attachment shape is bonded to the surface of the tooth, the force is not correctly directed. The surface orientation(s) of the parametric attachment is then altered to compensate for the tooth surface orientation and the force is redirected in a more favorable direction. Location of the attachment on the tooth may be altered as well to determine the position which produces the optimal force system. Orientation such as rotation around an axis or linear movement may be altered as well to optimize the force system. Each parameter of consequence in determining the force system produced by the attachment may then be incremented within clinically relevant values and the optimal design identified.” [0121] “Furthermore, in yet still another aspect, attachment design and/or placement may be determined based on the location of the maximum amount of surface area available perpendicular to the desired direction of the tooth movement. Further, if the force on any given tooth in the treatment plan is at or below a predefined level, the attachment(s) may be added to the tooth or appliance to supplement the desired surface area or increase the friction coefficient of the tooth, thereby improving the force profile of the aligner on the tooth.” – Based on the relative angle of movement v. the normal to a tooth surface, the system determines potential locations for the attachments. If the engagement is deemed insufficient (does not meet a threshold), it is modified until the engagement is sufficient (threshold is met). This can also be applied to the ranges of force and angle rotation limits that are applied, which themselves are thresholds. Also See [0063]-[0067], [0071]-[0074], [0119]-[0129], and [0160]-[0170] – These paragraphs describe the various factors accounted for including tooth morphology, attachment location, attachment orientation, and probability of engagement between the teeth and the aligner. The movement direction is defined which establishes the direction of the applied force, as well as the level of force and its properties that reposition teeth from initial positions to target positions. Optimized rotation and angle of clipping plane are also described.). identifying, by the one or more processors, an area of engagement of the at least one tooth, wherein the area of engagement comprises at least a portion of the addressable area, the portion comprising at least one tooth face accessible by a dental appliance to apply a force to the at least one tooth to effectuate the movement; (Morton [0066] “In one embodiment, an attachment may be identified as having a force or torque value falling outside the identified range, and generating an optimized attachment can include modifying one or more parameter values of the attachment so as to bring the force or torque value of the attachment within the identified range. In another embodiment, a method may include identification of an attachment with a force/torque falling within the desired range, followed by modification of parameter value(s) accomplished such that the force/torque of the modified or optimized attachment fall within a different portion of the desired range. For example, an attachment may be identified as having force/torque values in a lower portion of a desired range, with modifications selected to optimized the attachment so as to provide force/torque values higher within the desired range. See, e.g., FIG. 2D, Shape F compared to Shape F′ and F″.” [0067] “Location of the attachment on the tooth may be altered as well to determine the position which produces the optimal force system. Orientation such as rotation around an axis or linear movement may be altered as well to optimize the force system. Each parameter of consequence in determining the force system produced by the attachment may then be incremented within clinically relevant values and the optimal design identified.” [0121] “Furthermore, in yet still another aspect, attachment design and/or placement may be determined based on the location of the maximum amount of surface area available perpendicular to the desired direction of the tooth movement. Further, if the force on any given tooth in the treatment plan is at or below a predefined level, the attachment(s) may be added to the tooth or appliance to supplement the desired surface area or increase the friction coefficient of the tooth, thereby improving the force profile of the aligner on the tooth.” [0123] “Moreover, in further regard to the discussion herein regarding attachment design and customization, angulation or the attachment as well as the surface configuration of the attachments may be selected or provided to improve upon the movement vector to optimize its application to the desired tooth while minimizing the amount of undesirable or unwanted force vectors, e.g., that may be counteracting upon the movement vector. Additionally, in one aspect, a plurality of attachments, e.g., a series of abutting attachments may be provided to alter the force direction or generate the movement vector which is carried over for a predetermined time period, such that, the series of abutting attachments may be configured to function as slow motion cams where the dental appliance then functions as a follower.” – The system searches for the best location on the surface of the tooth for attachment engagement in order to optimize the application to the desired tooth for the treatment plan.) outputting, by the one or more processors, a [design adjustment] for the at least one tooth based on the area of engagement , (Morton [0007] “ Methods and orthodontic systems of the invention include tooth attachments having improved or optimized parameters selected or modified for more optimal and/or effective application of forces for a desired/selected orthodontic movement. Attachments of the present invention can be customized to a particular patient (e.g., patient-customized), a particular movement, and/or a sub-group or sub-set of patients, and configured to engage an orthodontic tooth positioning appliance worn by a patient, where engagement between the attachment and orthodontic appliance results in application of a repositioning force or series/system of forces to the tooth having the attachment and will generally elicit a tooth movement.” – The determinations are used to customize the designs/adjustments for the patient.) generating, by the one or more processors, an inner surface geometry of a digital model of a dental appliance based on the [design adjustment] . (Morton [0007] “ Methods and orthodontic systems of the invention include tooth attachments having improved or optimized parameters selected or modified for more optimal and/or effective application of forces for a desired/selected orthodontic movement. Attachments of the present invention can be customized to a particular patient (e.g., patient-customized), a particular movement, and/or a sub-group or sub-set of patients, and configured to engage an orthodontic tooth positioning appliance worn by a patient, where engagement between the attachment and orthodontic appliance results in application of a repositioning force or series/system of forces to the tooth having the attachment and will generally elicit a tooth movement.” – The determinations are used to customize the designs/adjustments for the patient.). Morton teaches an inference engine 456 to process input data and a set of rules 452a-452n in a rule base of rules to define a production system which, when applied to the input data, produces a set of output conclusions that specify the adjustments to the aligner in the relevant region of the tooth. Morton does not appear to explicitly teach, but Morton in view of Kukk teaches: outputting, by the one or more processors, a controllability score for the at least one tooth based on the area of engagement, wherein the controllability score indicates an ability to control a movement of the at least one tooth; and controllability score to increase the area of engagement between the dental appliance and the at least one tooth. (Kukk [0074]-[0075] “The retentiveness of an aligner may be estimated based on the shape and orientation of one or more teeth in the patient's dentition. In any of these methods and apparatuses, the retentiveness may be estimated based on the angle of the side (e.g., the buccal and/or lingual side) of all or some of the teeth relative to the long axis of the tooth (e.g., an axis extending normal to the occlusal surface of the tooth). FIG. 2A shows a side view of a tooth 200 to illustrate how a shape and orientation of the tooth 200 can be used to determine a retention value or score of the tooth 200. The estimation may be based on a 3D model of the tooth 200 in predetermined orientation. For example, the tooth 200 may be oriented in accordance with a position/orientation of the tooth at initiation of a particular stage of the treatment plan. A reference vector 202 that is parallel to a long axis of the tooth 200 is determined. In addition, surface normal vectors, e.g., 204, distributed across a surface of the tooth 200 and that are normal to the surface of the tooth 200 are determined. For example, each surface normal vector, e.g., 204, may be associated with a polygon of a surface mesh of the 3D model. Angles, e.g., 206, between the reference vector 202 and each of the surface normal vectors, e.g., 204, are then calculated. These angles, e.g., 206, are associated with a degree in which portions of the tooth surface can provide a retention force for an aligner. For example, surface portions associated with angles, e.g., 206, greater than 90 degrees can contribute a positive retention force for an aligner. Surface portions associated with angles greater than 90 degrees, such as the surface associated with surface normal vector 204 in FIG. 2, may be referred to as an undercut surface portion. A retention value or score of the tooth 200 may be estimated based on the number of angles, e.g., 206, that are greater than 90 degrees. In some cases, this calculation includes calculating a cosine of each of the angle(s), e.g., 206, based on vectors that are normal 204 to the surface of identified polygons. The angles of each of the identified polygons may be measured and added together to provide a weighting based on surface area. The retention value/score of the tooth 200 may be based on this sum. In some cases, the retention value/score may be based on a range. For example, the tooth 200 may be estimated to have a low retention value/score if the area of retention surfaces is above a first threshold, a medium retention value/score if the area of retention surfaces is above a second threshold greater than the first threshold, and a high retention value/score if the area of retention surfaces is above a third threshold greater than the second threshold. Retention scores may be estimated for individual teeth and/or for groups of the teeth (or all of the teeth). In some examples, retention values/scores for various zones of a dentition may be calculated based on the retention values/scores of the teeth. FIG. 2B illustrates an example dentition showing retention scores for different zones of the dentition (e.g., as shown in a user interface). In this example, retention values/scores are provided for three zones: Zone 1, Zone 2, and Zone 3. Zone 1 includes the lower left 8 tooth (LL8), the lower left 7 tooth (LL7), and the lower left 6 tooth (LL6), which correspond to the three last posterior teeth of the left side of the lower dentition. Zone 2 includes all the teeth of Zone 1 and also the lower left 5 tooth (LL5), which correspond to the four last posterior teeth of the left side of the lower dentition. Zone 3 includes all the teeth of Zone 2 and also the lower left 4 tooth (LL4), which correspond to the five last posterior teeth of the left side of the lower dentition. In this case, the retention values of each of the Zones 1-3 corresponds to an average retention value of the teeth of each zone. For example, Zone 1 has a retention value/score of R3, Zone 2 has a retention value/score of R4, and Zone 3 has a retention value/score of R5. A predicted lack of retention of an aligner can be determined based on a comparing retention values/scores of the zones to threshold values. In this example, a lack of retentive forces in the lower left quadrant of the dentition may be detected if R3 of Zone 1 is less than a first threshold value T3, R4 of Zone 2 is less than a second threshold value T4, or R5 of Zone 3 is less than a third threshold value T5. Similar calculations may be performed for other regions of the dentition (e.g., lower right quadrant). These calculations may then be used to determine a retentiveness of the aligner. For example, if it is determined that a left or right quadrant of a dentition lacks retentive forces, the user may be informed that the aligner is predicted to lack retentiveness. If a lack of retentiveness is determined, one or more retention-enhancing attachment locations for increasing the retention forces may be determined. For example, if one of Zones 1-3 has a low retention value/score, one or more attachments may be recommended on one or more teeth within Zones 1-3. In some cases, the recommendation is based on the retention value/score of a particular tooth. For example, if tooth LL7 has a low retention value (e.g., lower than a threshold value), an attachment may be recommended for the tooth LL7. In some examples, a shape, size and/or specific location on a tooth of one or more retention-enhancing attachments is recommended.” – This describes retention value/score systems based on available engagement area on the tooth at angles relative to the forces applied for generating better corrections with improved controllability.) It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claims to modify Morton’s aligner development by Kukk’s orthodontic considerations, as the person of ordinary skill in the art would be motivated to by Morton’s express aim to precisely control the moments applied to the teeth (e.g., angles and surface areas for engagement) to improve controlled treatment and clinical results with precise applied forces customized to a particular patient, to look to Kukk whose methods improve adaptability of the orthodontic suite of Morton, better customizing the treatment to make it more suitable for people. (Morton [0005]-[0006] “Current tooth attachments used for rotation have the same shape and position for all patients and teeth undergoing movement with a rotation component. Due to the individual morphology of teeth and composite movements, the performance of such attachments may not be optimal for all patients. Accordingly, improved techniques and orthodontic systems are needed for designing and providing more effective tooth movement forces to the teeth during orthodontic treatment using tooth attachments, and reducing unwanted tooth movements.” [0053] “As further described herein, tooth attachments can be designed, oriented, and/or located on a patient's tooth to precisely control the moments produced on a patient's tooth as the appliance is worn by the patient. Customized design and use in orthodontic treatment as described herein can advantageously improve effectiveness of treatment and clinical results by more precisely applying force vectors of necessary magnitude and direction for desired movement. Orthodontic systems of the present invention including appliances and tooth attachments as described further provide an efficient force distribution mechanism that can more effectively reduce unwanted force and moment.”; Kukk [0006] “The methods and apparatuses described herein may be used to improve detection of aligners that are at risk of improper fitting, as well as identifying and implementing adjustments to aligner designs to prevent improper fitting.” [0008] “The methods and apparatuses described herein provide specific improvement over currently described systems in which the fit of one or more (and particularly a series) of dental appliances is determined only after fabrication of the appliance, or by trial-and-error. These methods and apparatuses may instead provide a dynamic method and apparatus (e.g., user interface) that may allow a user to quickly modify, in an iterative manner, specific subsets of features that may cause discrepancies and therefore poor fit. For example, a poor fit may result in a variety of different features (e.g., a mis-match of tooth shape, tooth position, and/or gingival line, a missing extracted tooth, or a present erupted tooth). By allowing the user to separately view and adjust these features in a user interface the overall design process may be vastly streamlined.”) Claim 2 Regarding claim 2, Morton in view of Kukk teaches the features of claim 1 and further teach: further comprising selecting the movement for a treatment plan configured to move the at least one tooth from an initial position to a final position based on the controllability score. (Kukk [0074]-[0075] “The retentiveness of an aligner may be estimated based on the shape and orientation of one or more teeth in the patient's dentition. In any of these methods and apparatuses, the retentiveness may be estimated based on the angle of the side (e.g., the buccal and/or lingual side) of all or some of the teeth relative to the long axis of the tooth (e.g., an axis extending normal to the occlusal surface of the tooth). FIG. 2A shows a side view of a tooth 200 to illustrate how a shape and orientation of the tooth 200 can be used to determine a retention value or score of the tooth 200. The estimation may be based on a 3D model of the tooth 200 in predetermined orientation. For example, the tooth 200 may be oriented in accordance with a position/orientation of the tooth at initiation of a particular stage of the treatment plan. A reference vector 202 that is parallel to a long axis of the tooth 200 is determined. In addition, surface normal vectors, e.g., 204, distributed across a surface of the tooth 200 and that are normal to the surface of the tooth 200 are determined. For example, each surface normal vector, e.g., 204, may be associated with a polygon of a surface mesh of the 3D model. Angles, e.g., 206, between the reference vector 202 and each of the surface normal vectors, e.g., 204, are then calculated. These angles, e.g., 206, are associated with a degree in which portions of the tooth surface can provide a retention force for an aligner. For example, surface portions associated with angles, e.g., 206, greater than 90 degrees can contribute a positive retention force for an aligner. Surface portions associated with angles greater than 90 degrees, such as the surface associated with surface normal vector 204 in FIG. 2, may be referred to as an undercut surface portion. A retention value or score of the tooth 200 may be estimated based on the number of angles, e.g., 206, that are greater than 90 degrees. In some cases, this calculation includes calculating a cosine of each of the angle(s), e.g., 206, based on vectors that are normal 204 to the surface of identified polygons. The angles of each of the identified polygons may be measured and added together to provide a weighting based on surface area. The retention value/score of the tooth 200 may be based on this sum. In some cases, the retention value/score may be based on a range. For example, the tooth 200 may be estimated to have a low retention value/score if the area of retention surfaces is above a first threshold, a medium retention value/score if the area of retention surfaces is above a second threshold greater than the first threshold, and a high retention value/score if the area of retention surfaces is above a third threshold greater than the second threshold. Retention scores may be estimated for individual teeth and/or for groups of the teeth (or all of the teeth). In some examples, retention values/scores for various zones of a dentition may be calculated based on the retention values/scores of the teeth. FIG. 2B illustrates an example dentition showing retention scores for different zones of the dentition (e.g., as shown in a user interface). In this example, retention values/scores are provided for three zones: Zone 1, Zone 2, and Zone 3. Zone 1 includes the lower left 8 tooth (LL8), the lower left 7 tooth (LL7), and the lower left 6 tooth (LL6), which correspond to the three last posterior teeth of the left side of the lower dentition. Zone 2 includes all the teeth of Zone 1 and also the lower left 5 tooth (LL5), which correspond to the four last posterior teeth of the left side of the lower dentition. Zone 3 includes all the teeth of Zone 2 and also the lower left 4 tooth (LL4), which correspond to the five last posterior teeth of the left side of the lower dentition. In this case, the retention values of each of the Zones 1-3 corresponds to an average retention value of the teeth of each zone. For example, Zone 1 has a retention value/score of R3, Zone 2 has a retention value/score of R4, and Zone 3 has a retention value/score of R5. A predicted lack of retention of an aligner can be determined based on a comparing retention values/scores of the zones to threshold values. In this example, a lack of retentive forces in the lower left quadrant of the dentition may be detected if R3 of Zone 1 is less than a first threshold value T3, R4 of Zone 2 is less than a second threshold value T4, or R5 of Zone 3 is less than a third threshold value T5. Similar calculations may be performed for other regions of the dentition (e.g., lower right quadrant). These calculations may then be used to determine a retentiveness of the aligner. For example, if it is determined that a left or right quadrant of a dentition lacks retentive forces, the user may be informed that the aligner is predicted to lack retentiveness. If a lack of retentiveness is determined, one or more retention-enhancing attachment locations for increasing the retention forces may be determined. For example, if one of Zones 1-3 has a low retention value/score, one or more attachments may be recommended on one or more teeth within Zones 1-3. In some cases, the recommendation is based on the retention value/score of a particular tooth. For example, if tooth LL7 has a low retention value (e.g., lower than a threshold value), an attachment may be recommended for the tooth LL7. In some examples, a shape, size and/or specific location on a tooth of one or more retention-enhancing attachments is recommended.” – This describes retention value/score systems based on available engagement area on the tooth at angles relative to the forces applied for generating better corrections with improved controllability. - - Also, Kukk teaches these features as shown above in [0074]-[0075].) Claim 3 Regarding claim 3, Morton in view of Kukk teaches the features of claim 1 and further teaches: wherein determining the factor of engagement for each of the plurality of tooth faces comprises: determining, by the one or more processors, a face normalized unit vector for each of the plurality of tooth faces; determining, by the one or more processors, a movement normalized unit vector for each of the plurality of tooth faces; and determining, by the one or more processors, a relative angle between the face normalized unit vector and the movement normalized unit vector for each tooth face. (Morton [0005] “Appliances, in general, apply force and/or torque on a tooth crown to move teeth, with the applied force typically normal with respect to the surface of a tooth or attachment positioned on the tooth. ” [0007]-[0013] “Methods and orthodontic systems of the invention include tooth attachments having improved or optimized parameters selected or modified for more optimal and/or effective application of forces for a desired/selected orthodontic movement. […] A desired force system for eliciting the selected tooth movement is determined. A patient-customized attachment is then designed. The attachment is configured to engage an orthodontic appliance when worn by a patient and apply a repositioning force to a tooth corresponding to the selected force system. The attachment includes one or more parameters having values selected based on the digital model, the selected force system, and one or more patient-specific characteristics, thereby providing improved application of the selected force system to the patient's tooth. […] The method includes determining a desired force system to be applied to the patient's tooth so as to elicit the selected tooth movement. A first attachment is selected from a group of non-custom attachments. A first force system that is applied to a tooth having the first attachment and engaged with an orthodontic appliance is modeled. An optimized attachment is then generated by modifying one or more parameter values of the first attachment such that a second force system applied to the tooth having the optimized attachment and engaged with an orthodontic appliance worn by the patient more closely corresponds to the desired force system than the first force system. […] The attachment includes one or more parameters having values modified or selected based on the selected force system and one or more patient-specific characteristics. […] A movement optimized or patient-customized attachment is designed. The attachment is configured to engage an orthodontic appliance when worn by a patient and apply a repositioning force to the tooth. The attachment includes one or more parameter values modified based on the determined force or torque values such that the applied repositioning force substantially matches the desired force system. […] The method includes identifying a range of force or torque values corresponding to a desired force system to be applied to a tooth so as to elicit a selected tooth movement. A first force or torque value applied to a tooth is modeled when a first attachment disposed on the tooth is engaged with an orthodontic appliance. The first attachment has parameters affecting the force or torque applied to the tooth during engagement. The first force or torque value is identified as being within the range of values. An optimized attachment is then generated by modifying one or more parameter values of the first attachment such that a second force or torque is applied to a tooth having the optimized attachment and engaged with an orthodontic positioning appliance. The second force or torque value is higher or lower in the range of values compared to the first force system and selected to optimize force/torque application to a tooth during orthodontic treatment. […] The method includes identifying an initial position of an attachment on a tooth at a location on a digital model of the patient's dentition. Attachment parameters are computed based on the initial position of the attachment and a geometry of the tooth. Each attachment parameter is associated with a predetermined range of values corresponding to optimal force or optimal torque for the selected movement of the tooth. In the event that at least one value of the computed parameters is not within the predetermined range of values, at least one of the attachment parameters and the position of the attachment on the tooth is modified such that all of the attachment parameters are within the predetermined range of values.” – The torque values for different positions of engagement of attachments is determined and modified to satisfy ranges of values of parameters. [0071] “The disclosed invention determines the parameter of the attachment to vary to compensate for the variation in angle between the long axis and the direction of the surface of the tooth onto which the attachment is bonded.” [0139] “The method includes identifying an initial position of an attachment on a tooth at a location on a digital model of the patient's dentition. Attachment parameters are computed based on the initial position of the attachment and a geometry of the tooth. Each attachment parameter is associated with a predetermined range of values corresponding to optimal force or optimal torque for the selected movement of the tooth. In the event that at least one value of the computed parameters is not within the predetermined range of values, at least one of the attachment parameters and the position of the attachment on the tooth is modified such that all of the attachment parameters are within the predetermined range of values.” – An angle between a normal to the tooth face and the direction of force/motion is determined as part of the treatment plan.) Claim 4 Regarding claim 4, Morton in view of Kukk teaches the features of claim 1 and further teaches: wherein the addressable area is an actual addressable area, and determining the actual addressable area comprises: determining, by the one or more processors, a total addressable area, wherein the total addressable area comprises a first subset of the plurality of tooth faces of the at least one tooth, wherein the factors of engagement of the first subset of the plurality of tooth faces satisfy the threshold; (Morton [0007]-[0013] “Methods and orthodontic systems of the invention include tooth attachments having improved or optimized parameters selected or modified for more optimal and/or effective application of forces for a desired/selected orthodontic movement. […] A desired force system for eliciting the selected tooth movement is determined. A patient-customized attachment is then designed. The attachment is configured to engage an orthodontic appliance when worn by a patient and apply a repositioning force to a tooth corresponding to the selected force system. The attachment includes one or more parameters having values selected based on the digital model, the selected force system, and one or more patient-specific characteristics, thereby providing improved application of the selected force system to the patient's tooth. […] The method includes determining a desired force system to be applied to the patient's tooth so as to elicit the selected tooth movement. A first attachment is selected from a group of non-custom attachments. A first force system that is applied to a tooth having the first attachment and engaged with an orthodontic appliance is modeled. An optimized attachment is then generated by modifying one or more parameter values of the first attachment such that a second force system applied to the tooth having the optimized attachment and engaged with an orthodontic appliance worn by the patient more closely corresponds to the desired force system than the first force system. […] The attachment includes one or more parameters having values modified or selected based on the selected force system and one or more patient-specific characteristics. […] A movement optimized or patient-customized attachment is designed. The attachment is configured to engage an orthodontic appliance when worn by a patient and apply a repositioning force to the tooth. The attachment includes one or more parameter values modified based on the determined force or torque values such that the applied repositioning force substantially matches the desired force system. […] The method includes identifying a range of force or torque values corresponding to a desired force system to be applied to a tooth so as to elicit a selected tooth movement. A first force or torque value applied to a tooth is modeled when a first attachment disposed on the tooth is engaged with an orthodontic appliance. The first attachment has parameters affecting the force or torque applied to the tooth during engagement. The first force or torque value is identified as being within the range of values. An optimized attachment is then generated by modifying one or more parameter values of the first attachment such that a second force or torque is applied to a tooth having the optimized attachment and engaged with an orthodontic positioning appliance. The second force or torque value is higher or lower in the range of values compared to the first force system and selected to optimize force/torque application to a tooth during orthodontic treatment. […] The method includes identifying an initial position of an attachment on a tooth at a location on a digital model of the patient's dentition. Attachment parameters are computed based on the initial position of the attachment and a geometry of the tooth. Each attachment parameter is associated with a predetermined range of values corresponding to optimal force or optimal torque for the selected movement of the tooth. In the event that at least one value of the computed parameters is not within the predetermined range of values, at least one of the attachment parameters and the position of the attachment on the tooth is modified such that all of the attachment parameters are within the predetermined range of values.” – The torque values for different positions of engagement of attachments is determined and modified to satisfy ranges of values of parameters.) identifying, by the one or more processors, an obstruction that prevents at least one of the plurality of tooth faces of the first subset from being able to receive the force; and (Morton [0067] “ The tooth morphology and surface orientation may be taken into account when determining the attachment design. The surface of the tooth may have an orientation such that when a generic attachment shape is bonded to the surface of the tooth, the force is not correctly directed. The surface orientation(s) of the parametric attachment is then altered to compensate for the tooth surface orientation and the force is redirected in a more favorable direction.” [0080] “The initial digital data set, which may include both raw data from scanning operations and data representing surface models derived from the raw data, is processed to segment the tissue constituents from each other (step 120). In particular, in this step, data structures that digitally represent individual tooth crowns are produced. Advantageously, digital models of entire teeth are produced, including measured or extrapolated hidden surfaces and root structures as well as surrounding bone and soft tissue.” – Blocked surfaces are determined. The nature and position of the attachment can be varied to compensate for it.) determining, by the one or more processors, the actual addressable area, wherein the actual addressable area comprises the at least one tooth face, wherein the at least one tooth face is capable of receive the force despite the obstruction. (Morton [0067] “ The tooth morphology and surface orientation may be taken into account when determining the attachment design. The surface of the tooth may have an orientation such that when a generic attachment shape is bonded to the surface of the tooth, the force is not correctly directed. The surface orientation(s) of the parametric attachment is then altered to compensate for the tooth surface orientation and the force is redirected in a more favorable direction.” [0080] “The initial digital data set, which may include both raw data from scanning operations and data representing surface models derived from the raw data, is processed to segment the tissue constituents from each other (step 120). In particular, in this step, data structures that digitally represent individual tooth crowns are produced. Advantageously, digital models of entire teeth are produced, including measured or extrapolated hidden surfaces and root structures as well as surrounding bone and soft tissue.” [0106] “The teeth movement can be guided in part using a root-based sequencing system. In one embodiment, the movement is constrained by a surface area constraint, while in another embodiment, the movement is constrained by a volume constraint.” [0117] “In one aspect, based on the force behavior determined from the material properties and the amount of surface area perpendicular to the composite vector resulting from the movement vector for the particular treatment stage, additional surface area may be added to the tooth by employing an attachment that can be selected and further customized for the desired movement. In this manner, in one aspect, the cross section and/or orientation of the surface area may be determined for a particular tooth, and the attachment(s) can be incorporated on one or more teeth to enhance or improve upon the necessary surface area to cooperate or engage with the dental appliance to effect the desired movement vector or the predetermined level of force upon the tooth in the accurate direction for the treatment stage.” – Blocked surfaces are determined. The nature and position of the attachment can be varied to compensate for it. This includes compensating for surface area constraints. - - Also, Kukk teaches these features as shown above in [0074]-[0075]) Claim 5 Regarding claim 5, Morton in view of Kukk teaches the features of claim 1 and further teaches: wherein outputting the controllability score comprises: determining, by the one or more processors, an available force vector for the at least one tooth face within the area of engagement; determining, by the one or more processors, an available moment vector for the at least one tooth face within the area of engagement; and (Morton [0063] “As noted above, appliances or aligners accomplish tooth movement by applying a series or system of forces (force system) comprised of forces, the moment of a force, and the moment of a couple to a tooth to elicit a biological response of the periodontal tissues and bone structures which surround the tooth. Different force systems result in different types of tooth movement: tipping, translation, root movement, etc. In some cases, the aligner alone cannot deliver the force system required to accomplish a desired tooth movement. An amount of material or structure, commonly referred to in the orthodontic arena as an attachment, can be bonded to the tooth to aid the aligner in delivering the appropriate force system to the tooth. The state-of-the-art in attachments is fixed geometric shapes which are indicated for use when a specific tooth movement is desired. However, the selection of an attachment paired with the aligner to improve movement has historically been determined from clinical observation alone and has demonstrated in some instances limited clinical success and lack of precise clinical control of the force system deliverer to the tooth. Methods and systems according to the present invention advantageously consider and account for various factors which can have a significant effect on imparting a precise force system to a tooth, including biomechanical principles, tooth morphology, attachment location, attachment orientation, and probability of engagement between the aligner. The present invention uses these inputs to determine the optimal design of the attachment to be used with the aligner for the specific movement of a specific tooth, and accommodate specific attachment characteristics determined for a specific tooth and specific desired movement. Thus, the current attachments and orthodontic systems provide optimized as well as customized individualized attachment design for a specific tooth and a specific movement.” [0123] “ Additionally, in one aspect, a plurality of attachments, e.g., a series of abutting attachments may be provided to alter the force direction or generate the movement vector which is carried over for a predetermined time period” [0129] “Additionally, the force direction for the tooth movement, as well as counter forces for addressing unwanted or unintended forces are determined. Thereafter, based on the determined components associated with the movement vector which is associated with the tooth movement from the initial position to the target position, the cavity geometry of the dental appliance such as the aligner is modified (step 2150).” [0132] “FIG. 19 illustrates that an object may be moved by applying a force along any direction tangential to the object's rotational trajectory. Specifically, a force (a, b, c or d) applied to an object 2300 can rotate the object in a circle by a torque of the cross product of an arm (r) and the amount of force (F) applied to the object, r×F. A pair of equal and opposite forces may create a torque that has a zero resultant force (e.g., forces a and c, or forces b and d). Three parameters together generate a torque: 1) a force vector, 2) a point where the force is applied, and 3) a point at which the torque is measured. The point where the force is applied and the point at which the torque is measured determine the arm vector. When rotating a tooth, the torque is calculated with respect to a center of resistance of the tooth.” – Torques with moment vectors and forces with force vectors are calculated. - - Also, Kukk teaches these features as shown above in [0074]-[0075]) summing, by the one or more processors, the available force vectors and the available moment vectors. (Morton [0058] “Previously existing attachment technology does not provide for customizing attachments to an individual patient or the specific tooth movement desired, or optimizing or precisely controlling the forces (e.g., collection or system of forces) applied to a patient's tooth to elicit a desired movement of the tooth.” [0063] “As noted above, appliances or aligners accomplish tooth movement by applying a series or system of forces (force system) comprised of forces, the moment of a force, and the moment of a couple to a tooth to elicit a biological response of the periodontal tissues and bone structures which surround the tooth. Different force systems result in different types of tooth movement: tipping, translation, root movement, etc. In some cases, the aligner alone cannot deliver the force system required to accomplish a desired tooth movement. An amount of material or structure, commonly referred to in the orthodontic arena as an attachment, can be bonded to the tooth to aid the aligner in delivering the appropriate force system to the tooth. […] Methods and systems according to the present invention advantageously consider and account for various factors which can have a significant effect on imparting a precise force system to a tooth, including biomechanical principles, tooth morphology, attachment location, attachment orientation, and probability of engagement between the aligner.” [0123] “ Additionally, in one aspect, a plurality of attachments, e.g., a series of abutting attachments may be provided to alter the force direction or generate the movement vector which is carried over for a predetermined time period” [0129] “Additionally, the force direction for the tooth movement, as well as counter forces for addressing unwanted or unintended forces are determined. Thereafter, based on the determined components associated with the movement vector which is associated with the tooth movement from the initial position to the target position, the cavity geometry of the dental appliance such as the aligner is modified (step 2150).” [0132] “FIG. 19 illustrates that an object may be moved by applying a force along any direction tangential to the object's rotational trajectory. Specifically, a force (a, b, c or d) applied to an object 2300 can rotate the object in a circle by a torque of the cross product of an arm (r) and the amount of force (F) applied to the object, r×F. A pair of equal and opposite forces may create a torque that has a zero resultant force (e.g., forces a and c, or forces b and d). Three parameters together generate a torque: 1) a force vector, 2) a point where the force is applied, and 3) a point at which the torque is measured. The point where the force is applied and the point at which the torque is measured determine the arm vector. When rotating a tooth, the torque is calculated with respect to a center of resistance of the tooth.” See also FIGs. 20, 27, and 29 (shown below) – Torques with moment vectors and forces with force vectors are calculated, some by summing to determine from component force elements a composite force and composite torque/moment applied to each of the teeth.) PNG media_image1.png 580 577 media_image1.png Greyscale PNG media_image2.png 569 566 media_image2.png Greyscale PNG media_image3.png 398 539 media_image3.png Greyscale Claim 6 Regarding claim 6, Morton in view of Kukk teaches the features of claim 1 and further teaches: receiving, by the one or more processors, a model dental appliance; adjusting, by the one or more processors, the area of engagement by modifying a geometry of the model dental appliance; and determining, by the one or more processors, a second controllability score for the at least one tooth based on the adjusted area of engagement, wherein the second controllability score is greater than the first controllability score. (Morton [0087] “ If the motions are orthodontically acceptable and the teeth have reached an acceptable position, the current aligner shape is compared to the previously calculated aligner shapes. If the current shape is the best solution so far (step 250), it is saved as the best candidate so far (step 260). If not, it is saved in an optional step as a possible intermediate result (step 252). If the current aligner shape is the best candidate so far, the process determines whether it is good enough to be accepted (step 270). If it is, the process exits. Otherwise, the process continues and calculates another candidate shape (step 240) for analysis.” -Morton tries different configurations and compares them. As indicated, the most perfect situation is that the position of CO has 0.5 mm to 1 mm displacement away from the position of CR. Similarly, the metrics for Cass II and Class III occlusion relationship of Angle’s Classification can have orthodontic treatment, which can make the patient’s first molars be gradually moved (controllability) and rotated to meet the Class I occlusion relationship of Angle’s Classification. Morton in view of Kukk compares these controllability scores to determine an optimal aligner configuration. - - Also, Kukk teaches these features as shown above in [0074]-[0075]) Claim 7 Regarding claim 7, Morton in view of Kukk teaches the features of claim 1 and further teaches: receiving, by the one or more processors, the digital model of the dentition, the digital model comprising a plurality of teeth; identifying, by the one or more processors, the area of engagement for each of the plurality of teeth; and determining, by the one or more processors, a dentition controllability score based on the area of engagement for each of the plurality of teeth. (Morton [0087] “FIG. 10B illustrates a process 200 implementing the appliance-calculation step (FIG. 6A, step 170) for polymeric shell aligners of the kind described in above-mentioned U.S. Pat. No. 5,975,893. Inputs to the process include an initial aligner shape 202, various control parameters 204, and a desired end configuration for the teeth at the end of the current treatment path segment 206. Other inputs include digital models of the teeth in position in the jaw, models of the jaw tissue, attachment placement and configuration, and specifications of an initial aligner shape and of the aligner material. Using the input data, the process creates a finite element model of the aligner, attachments, teeth and tissue, with the aligner in place on the teeth (step 210). […] If the motions are orthodontically acceptable and the teeth have reached an acceptable position, the current aligner shape is compared to the previously calculated aligner shapes. If the current shape is the best solution so far (step 250), it is saved as the best candidate so far (step 260). If not, it is saved in an optional step as a possible intermediate result (step 252). If the current aligner shape is the best candidate so far, the process determines whether it is good enough to be accepted (step 270). If it is, the process exits. Otherwise, the process continues and calculates another candidate shape (step 240) for analysis.” -Morton tries different configurations and compares them on a model of the teeth. Kukk [0074]-[0075] “The retentiveness of an aligner may be estimated based on the shape and orientation of one or more teeth in the patient's dentition. In any of these methods and apparatuses, the retentiveness may be estimated based on the angle of the side (e.g., the buccal and/or lingual side) of all or some of the teeth relative to the long axis of the tooth (e.g., an axis extending normal to the occlusal surface of the tooth). FIG. 2A shows a side view of a tooth 200 to illustrate how a shape and orientation of the tooth 200 can be used to determine a retention value or score of the tooth 200. The estimation may be based on a 3D model of the tooth 200 in predetermined orientation. For example, the tooth 200 may be oriented in accordance with a position/orientation of the tooth at initiation of a particular stage of the treatment plan. A reference vector 202 that is parallel to a long axis of the tooth 200 is determined. In addition, surface normal vectors, e.g., 204, distributed across a surface of the tooth 200 and that are normal to the surface of the tooth 200 are determined. For example, each surface normal vector, e.g., 204, may be associated with a polygon of a surface mesh of the 3D model. Angles, e.g., 206, between the reference vector 202 and each of the surface normal vectors, e.g., 204, are then calculated. These angles, e.g., 206, are associated with a degree in which portions of the tooth surface can provide a retention force for an aligner. For example, surface portions associated with angles, e.g., 206, greater than 90 degrees can contribute a positive retention force for an aligner. Surface portions associated with angles greater than 90 degrees, such as the surface associated with surface normal vector 204 in FIG. 2, may be referred to as an undercut surface portion. A retention value or score of the tooth 200 may be estimated based on the number of angles, e.g., 206, that are greater than 90 degrees. In some cases, this calculation includes calculating a cosine of each of the angle(s), e.g., 206, based on vectors that are normal 204 to the surface of identified polygons. The angles of each of the identified polygons may be measured and added together to provide a weighting based on surface area. The retention value/score of the tooth 200 may be based on this sum. In some cases, the retention value/score may be based on a range. For example, the tooth 200 may be estimated to have a low retention value/score if the area of retention surfaces is above a first threshold, a medium retention value/score if the area of retention surfaces is above a second threshold greater than the first threshold, and a high retention value/score if the area of retention surfaces is above a third threshold greater than the second threshold. Retention scores may be estimated for individual teeth and/or for groups of the teeth (or all of the teeth). In some examples, retention values/scores for various zones of a dentition may be calculated based on the retention values/scores of the teeth. FIG. 2B illustrates an example dentition showing retention scores for different zones of the dentition (e.g., as shown in a user interface). In this example, retention values/scores are provided for three zones: Zone 1, Zone 2, and Zone 3. Zone 1 includes the lower left 8 tooth (LL8), the lower left 7 tooth (LL7), and the lower left 6 tooth (LL6), which correspond to the three last posterior teeth of the left side of the lower dentition. Zone 2 includes all the teeth of Zone 1 and also the lower left 5 tooth (LL5), which correspond to the four last posterior teeth of the left side of the lower dentition. Zone 3 includes all the teeth of Zone 2 and also the lower left 4 tooth (LL4), which correspond to the five last posterior teeth of the left side of the lower dentition. In this case, the retention values of each of the Zones 1-3 corresponds to an average retention value of the teeth of each zone. For example, Zone 1 has a retention value/score of R3, Zone 2 has a retention value/score of R4, and Zone 3 has a retention value/score of R5. A predicted lack of retention of an aligner can be determined based on a comparing retention values/scores of the zones to threshold values. In this example, a lack of retentive forces in the lower left quadrant of the dentition may be detected if R3 of Zone 1 is less than a first threshold value T3, R4 of Zone 2 is less than a second threshold value T4, or R5 of Zone 3 is less than a third threshold value T5. Similar calculations may be performed for other regions of the dentition (e.g., lower right quadrant). These calculations may then be used to determine a retentiveness of the aligner. For example, if it is determined that a left or right quadrant of a dentition lacks retentive forces, the user may be informed that the aligner is predicted to lack retentiveness. If a lack of retentiveness is determined, one or more retention-enhancing attachment locations for increasing the retention forces may be determined. For example, if one of Zones 1-3 has a low retention value/score, one or more attachments may be recommended on one or more teeth within Zones 1-3. In some cases, the recommendation is based on the retention value/score of a particular tooth. For example, if tooth LL7 has a low retention value (e.g., lower than a threshold value), an attachment may be recommended for the tooth LL7. In some examples, a shape, size and/or specific location on a tooth of one or more retention-enhancing attachments is recommended.” – Kukk uses retention value/score systems based on available engagement area on the tooth at angles relative to the forces applied for generating devices with better corrections with improved controllability.) Claim 8 Regarding claim 8, Morton in view of Kukk teaches the features of claim 1 and further teaches: receiving, by the one or more processors, the digital model of the dentition, the digital model comprising a plurality of teeth; determining, by the one or more processors, a movement for at least one tooth of the plurality of teeth; outputting, by the one or more processors, a first controllability score based on the movement of the at least one tooth; determining, by the one or more processors, an alternative movement for the at least one tooth; outputting, by the one or more processors, a second controllability score based on the alternative movement for the at least one tooth. (Morton [0087] “ If the motions are orthodontically acceptable and the teeth have reached an acceptable position, the current aligner shape is compared to the previously calculated aligner shapes. If the current shape is the best solution so far (step 250), it is saved as the best candidate so far (step 260). If not, it is saved in an optional step as a possible intermediate result (step 252). If the current aligner shape is the best candidate so far, the process determines whether it is good enough to be accepted (step 270). If it is, the process exits. Otherwise, the process continues and calculates another candidate shape (step 240) for analysis.” -Morton tries different configurations and compares them. Kukk [0074]-[0075] “The retentiveness of an aligner may be estimated based on the shape and orientation of one or more teeth in the patient's dentition. In any of these methods and apparatuses, the retentiveness may be estimated based on the angle of the side (e.g., the buccal and/or lingual side) of all or some of the teeth relative to the long axis of the tooth (e.g., an axis extending normal to the occlusal surface of the tooth). FIG. 2A shows a side view of a tooth 200 to illustrate how a shape and orientation of the tooth 200 can be used to determine a retention value or score of the tooth 200. The estimation may be based on a 3D model of the tooth 200 in predetermined orientation. For example, the tooth 200 may be oriented in accordance with a position/orientation of the tooth at initiation of a particular stage of the treatment plan. A reference vector 202 that is parallel to a long axis of the tooth 200 is determined. In addition, surface normal vectors, e.g., 204, distributed across a surface of the tooth 200 and that are normal to the surface of the tooth 200 are determined. For example, each surface normal vector, e.g., 204, may be associated with a polygon of a surface mesh of the 3D model. Angles, e.g., 206, between the reference vector 202 and each of the surface normal vectors, e.g., 204, are then calculated. These angles, e.g., 206, are associated with a degree in which portions of the tooth surface can provide a retention force for an aligner. For example, surface portions associated with angles, e.g., 206, greater than 90 degrees can contribute a positive retention force for an aligner. Surface portions associated with angles greater than 90 degrees, such as the surface associated with surface normal vector 204 in FIG. 2, may be referred to as an undercut surface portion. A retention value or score of the tooth 200 may be estimated based on the number of angles, e.g., 206, that are greater than 90 degrees. In some cases, this calculation includes calculating a cosine of each of the angle(s), e.g., 206, based on vectors that are normal 204 to the surface of identified polygons. The angles of each of the identified polygons may be measured and added together to provide a weighting based on surface area. The retention value/score of the tooth 200 may be based on this sum. In some cases, the retention value/score may be based on a range. For example, the tooth 200 may be estimated to have a low retention value/score if the area of retention surfaces is above a first threshold, a medium retention value/score if the area of retention surfaces is above a second threshold greater than the first threshold, and a high retention value/score if the area of retention surfaces is above a third threshold greater than the second threshold. Retention scores may be estimated for individual teeth and/or for groups of the teeth (or all of the teeth). In some examples, retention values/scores for various zones of a dentition may be calculated based on the retention values/scores of the teeth. FIG. 2B illustrates an example dentition showing retention scores for different zones of the dentition (e.g., as shown in a user interface). In this example, retention values/scores are provided for three zones: Zone 1, Zone 2, and Zone 3. Zone 1 includes the lower left 8 tooth (LL8), the lower left 7 tooth (LL7), and the lower left 6 tooth (LL6), which correspond to the three last posterior teeth of the left side of the lower dentition. Zone 2 includes all the teeth of Zone 1 and also the lower left 5 tooth (LL5), which correspond to the four last posterior teeth of the left side of the lower dentition. Zone 3 includes all the teeth of Zone 2 and also the lower left 4 tooth (LL4), which correspond to the five last posterior teeth of the left side of the lower dentition. In this case, the retention values of each of the Zones 1-3 corresponds to an average retention value of the teeth of each zone. For example, Zone 1 has a retention value/score of R3, Zone 2 has a retention value/score of R4, and Zone 3 has a retention value/score of R5. A predicted lack of retention of an aligner can be determined based on a comparing retention values/scores of the zones to threshold values. In this example, a lack of retentive forces in the lower left quadrant of the dentition may be detected if R3 of Zone 1 is less than a first threshold value T3, R4 of Zone 2 is less than a second threshold value T4, or R5 of Zone 3 is less than a third threshold value T5. Similar calculations may be performed for other regions of the dentition (e.g., lower right quadrant). These calculations may then be used to determine a retentiveness of the aligner. For example, if it is determined that a left or right quadrant of a dentition lacks retentive forces, the user may be informed that the aligner is predicted to lack retentiveness. If a lack of retentiveness is determined, one or more retention-enhancing attachment locations for increasing the retention forces may be determined. For example, if one of Zones 1-3 has a low retention value/score, one or more attachments may be recommended on one or more teeth within Zones 1-3. In some cases, the recommendation is based on the retention value/score of a particular tooth. For example, if tooth LL7 has a low retention value (e.g., lower than a threshold value), an attachment may be recommended for the tooth LL7. In some examples, a shape, size and/or specific location on a tooth of one or more retention-enhancing attachments is recommended.” – Kukk uses retention value/score systems based on available engagement area on the tooth at angles relative to the forces applied for generating devices with better corrections with improved controllability. Multiple scores for different configurations are determined, even for each tooth or group of teeth and compared.) Claim 9 Regarding claim 9, Morton in view of Kukk teaches the features of claim 8 and further teaches: comparing, by the one or more processors, the first controllability score and the second controllability score; and generating, by the one or more processors, a step of the treatment plan based on the comparison of the first controllability score and the second controllability score. (Morton [0087] “ If the motions are orthodontically acceptable and the teeth have reached an acceptable position, the current aligner shape is compared to the previously calculated aligner shapes. If the current shape is the best solution so far (step 250), it is saved as the best candidate so far (step 260). If not, it is saved in an optional step as a possible intermediate result (step 252). If the current aligner shape is the best candidate so far, the process determines whether it is good enough to be accepted (step 270). If it is, the process exits. Otherwise, the process continues and calculates another candidate shape (step 240) for analysis.” -Morton tries different configurations and compares them. Kukk [0074]-[0075] “The retentiveness of an aligner may be estimated based on the shape and orientation of one or more teeth in the patient's dentition. In any of these methods and apparatuses, the retentiveness may be estimated based on the angle of the side (e.g., the buccal and/or lingual side) of all or some of the teeth relative to the long axis of the tooth (e.g., an axis extending normal to the occlusal surface of the tooth). FIG. 2A shows a side view of a tooth 200 to illustrate how a shape and orientation of the tooth 200 can be used to determine a retention value or score of the tooth 200. The estimation may be based on a 3D model of the tooth 200 in predetermined orientation. For example, the tooth 200 may be oriented in accordance with a position/orientation of the tooth at initiation of a particular stage of the treatment plan. A reference vector 202 that is parallel to a long axis of the tooth 200 is determined. In addition, surface normal vectors, e.g., 204, distributed across a surface of the tooth 200 and that are normal to the surface of the tooth 200 are determined. For example, each surface normal vector, e.g., 204, may be associated with a polygon of a surface mesh of the 3D model. Angles, e.g., 206, between the reference vector 202 and each of the surface normal vectors, e.g., 204, are then calculated. These angles, e.g., 206, are associated with a degree in which portions of the tooth surface can provide a retention force for an aligner. For example, surface portions associated with angles, e.g., 206, greater than 90 degrees can contribute a positive retention force for an aligner. Surface portions associated with angles greater than 90 degrees, such as the surface associated with surface normal vector 204 in FIG. 2, may be referred to as an undercut surface portion. A retention value or score of the tooth 200 may be estimated based on the number of angles, e.g., 206, that are greater than 90 degrees. In some cases, this calculation includes calculating a cosine of each of the angle(s), e.g., 206, based on vectors that are normal 204 to the surface of identified polygons. The angles of each of the identified polygons may be measured and added together to provide a weighting based on surface area. The retention value/score of the tooth 200 may be based on this sum. In some cases, the retention value/score may be based on a range. For example, the tooth 200 may be estimated to have a low retention value/score if the area of retention surfaces is above a first threshold, a medium retention value/score if the area of retention surfaces is above a second threshold greater than the first threshold, and a high retention value/score if the area of retention surfaces is above a third threshold greater than the second threshold. Retention scores may be estimated for individual teeth and/or for groups of the teeth (or all of the teeth). In some examples, retention values/scores for various zones of a dentition may be calculated based on the retention values/scores of the teeth. FIG. 2B illustrates an example dentition showing retention scores for different zones of the dentition (e.g., as shown in a user interface). In this example, retention values/scores are provided for three zones: Zone 1, Zone 2, and Zone 3. Zone 1 includes the lower left 8 tooth (LL8), the lower left 7 tooth (LL7), and the lower left 6 tooth (LL6), which correspond to the three last posterior teeth of the left side of the lower dentition. Zone 2 includes all the teeth of Zone 1 and also the lower left 5 tooth (LL5), which correspond to the four last posterior teeth of the left side of the lower dentition. Zone 3 includes all the teeth of Zone 2 and also the lower left 4 tooth (LL4), which correspond to the five last posterior teeth of the left side of the lower dentition. In this case, the retention values of each of the Zones 1-3 corresponds to an average retention value of the teeth of each zone. For example, Zone 1 has a retention value/score of R3, Zone 2 has a retention value/score of R4, and Zone 3 has a retention value/score of R5. A predicted lack of retention of an aligner can be determined based on a comparing retention values/scores of the zones to threshold values. In this example, a lack of retentive forces in the lower left quadrant of the dentition may be detected if R3 of Zone 1 is less than a first threshold value T3, R4 of Zone 2 is less than a second threshold value T4, or R5 of Zone 3 is less than a third threshold value T5. Similar calculations may be performed for other regions of the dentition (e.g., lower right quadrant). These calculations may then be used to determine a retentiveness of the aligner. For example, if it is determined that a left or right quadrant of a dentition lacks retentive forces, the user may be informed that the aligner is predicted to lack retentiveness. If a lack of retentiveness is determined, one or more retention-enhancing attachment locations for increasing the retention forces may be determined. For example, if one of Zones 1-3 has a low retention value/score, one or more attachments may be recommended on one or more teeth within Zones 1-3. In some cases, the recommendation is based on the retention value/score of a particular tooth. For example, if tooth LL7 has a low retention value (e.g., lower than a threshold value), an attachment may be recommended for the tooth LL7. In some examples, a shape, size and/or specific location on a tooth of one or more retention-enhancing attachments is recommended.” – Kukk uses retention value/score systems based on available engagement area on the tooth at angles relative to the forces applied for generating devices with better corrections with improved controllability. Multiple scores for different configurations are determined, even for each tooth or group of teeth and compared.) Claim 10 Regarding claim 10, Morton in view of Kukk teaches: determining, by the one or more processors, a plurality of movements for the at least one tooth based on the treatment plan, wherein each of the plurality of movements corresponds with a step of the treatment plan; determining, by the one or more processors, a treatment plan controllability score based on the plurality of movements for the at least one tooth. (Morton [0087] “FIG. 10B illustrates a process 200 implementing the appliance-calculation step (FIG. 6A, step 170) for polymeric shell aligners of the kind described in above-mentioned U.S. Pat. No. 5,975,893. Inputs to the process include an initial aligner shape 202, various control parameters 204, and a desired end configuration for the teeth at the end of the current treatment path segment 206. […] If the motions are orthodontically acceptable and the teeth have reached an acceptable position, the current aligner shape is compared to the previously calculated aligner shapes. If the current shape is the best solution so far (step 250), it is saved as the best candidate so far (step 260). If not, it is saved in an optional step as a possible intermediate result (step 252). If the current aligner shape is the best candidate so far, the process determines whether it is good enough to be accepted (step 270). If it is, the process exits. Otherwise, the process continues and calculates another candidate shape (step 240) for analysis.” -Morton tries different configurations for different treatment plans and compares them to determine an optimal treatment plan. Kukk [0074]-[0075] “The retentiveness of an aligner may be estimated based on the shape and orientation of one or more teeth in the patient's dentition. In any of these methods and apparatuses, the retentiveness may be estimated based on the angle of the side (e.g., the buccal and/or lingual side) of all or some of the teeth relative to the long axis of the tooth (e.g., an axis extending normal to the occlusal surface of the tooth). FIG. 2A shows a side view of a tooth 200 to illustrate how a shape and orientation of the tooth 200 can be used to determine a retention value or score of the tooth 200. The estimation may be based on a 3D model of the tooth 200 in predetermined orientation. For example, the tooth 200 may be oriented in accordance with a position/orientation of the tooth at initiation of a particular stage of the treatment plan. A reference vector 202 that is parallel to a long axis of the tooth 200 is determined. In addition, surface normal vectors, e.g., 204, distributed across a surface of the tooth 200 and that are normal to the surface of the tooth 200 are determined. For example, each surface normal vector, e.g., 204, may be associated with a polygon of a surface mesh of the 3D model. Angles, e.g., 206, between the reference vector 202 and each of the surface normal vectors, e.g., 204, are then calculated. These angles, e.g., 206, are associated with a degree in which portions of the tooth surface can provide a retention force for an aligner. For example, surface portions associated with angles, e.g., 206, greater than 90 degrees can contribute a positive retention force for an aligner. Surface portions associated with angles greater than 90 degrees, such as the surface associated with surface normal vector 204 in FIG. 2, may be referred to as an undercut surface portion. A retention value or score of the tooth 200 may be estimated based on the number of angles, e.g., 206, that are greater than 90 degrees. In some cases, this calculation includes calculating a cosine of each of the angle(s), e.g., 206, based on vectors that are normal 204 to the surface of identified polygons. The angles of each of the identified polygons may be measured and added together to provide a weighting based on surface area. The retention value/score of the tooth 200 may be based on this sum. In some cases, the retention value/score may be based on a range. For example, the tooth 200 may be estimated to have a low retention value/score if the area of retention surfaces is above a first threshold, a medium retention value/score if the area of retention surfaces is above a second threshold greater than the first threshold, and a high retention value/score if the area of retention surfaces is above a third threshold greater than the second threshold. Retention scores may be estimated for individual teeth and/or for groups of the teeth (or all of the teeth). In some examples, retention values/scores for various zones of a dentition may be calculated based on the retention values/scores of the teeth. FIG. 2B illustrates an example dentition showing retention scores for different zones of the dentition (e.g., as shown in a user interface). In this example, retention values/scores are provided for three zones: Zone 1, Zone 2, and Zone 3. Zone 1 includes the lower left 8 tooth (LL8), the lower left 7 tooth (LL7), and the lower left 6 tooth (LL6), which correspond to the three last posterior teeth of the left side of the lower dentition. Zone 2 includes all the teeth of Zone 1 and also the lower left 5 tooth (LL5), which correspond to the four last posterior teeth of the left side of the lower dentition. Zone 3 includes all the teeth of Zone 2 and also the lower left 4 tooth (LL4), which correspond to the five last posterior teeth of the left side of the lower dentition. In this case, the retention values of each of the Zones 1-3 corresponds to an average retention value of the teeth of each zone. For example, Zone 1 has a retention value/score of R3, Zone 2 has a retention value/score of R4, and Zone 3 has a retention value/score of R5. A predicted lack of retention of an aligner can be determined based on a comparing retention values/scores of the zones to threshold values. In this example, a lack of retentive forces in the lower left quadrant of the dentition may be detected if R3 of Zone 1 is less than a first threshold value T3, R4 of Zone 2 is less than a second threshold value T4, or R5 of Zone 3 is less than a third threshold value T5. Similar calculations may be performed for other regions of the dentition (e.g., lower right quadrant). These calculations may then be used to determine a retentiveness of the aligner. For example, if it is determined that a left or right quadrant of a dentition lacks retentive forces, the user may be informed that the aligner is predicted to lack retentiveness. If a lack of retentiveness is determined, one or more retention-enhancing attachment locations for increasing the retention forces may be determined. For example, if one of Zones 1-3 has a low retention value/score, one or more attachments may be recommended on one or more teeth within Zones 1-3. In some cases, the recommendation is based on the retention value/score of a particular tooth. For example, if tooth LL7 has a low retention value (e.g., lower than a threshold value), an attachment may be recommended for the tooth LL7. In some examples, a shape, size and/or specific location on a tooth of one or more retention-enhancing attachments is recommended.” – Kukk uses retention value/score systems based on available engagement area on the tooth at angles relative to the forces applied for generating devices with better corrections with improved controllability. Claim 11 Regarding claim 11, Morton in view of Kukk teaches the features of claim 1 and further teaches: further comprising determining a pushing force configured to move the at least one tooth from a first position to a second position. (Morton Abstract “Attachments of the present invention can be customized to a particular patient (e.g., patient-customized), a particular movement, and/or a sub-group or sub-set of patients, and configured to engage an orthodontic tooth positioning appliance worn by a patient, where engagement between the attachment and orthodontic appliance results in application of a repositioning force or series/system of forces to the tooth having the attachment and will generally elicit a tooth movement.” – A force pushes a tooth from one position to another.) Claims 12 and 16 Regarding claim 16 (and claim 12), Morton teaches: A system comprising: one or more processors; and a memory coupled with the one or more processors, wherein the memory stores instructions that, when executed by the one or more processors, cause the one or more processors to: (Morton [0168] “The data processing aspects of the invention can be implemented in digital electronic circuitry, or in computer hardware, firmware, software, or in combinations of them. Data processing apparatus of the invention can be implemented in a computer program product tangibly embodied in a machine-readable storage device for execution by a programmable processor; and data processing method steps of the invention can be performed by a programmable processor executing a program of instructions to perform functions of the invention by operating on input data and generating output. The data processing aspects of the invention can be implemented advantageously in one or more computer programs that are executable on a programmable system including at least one programmable processor coupled to receive data and instructions from and to transmit data and instructions to a data storage system, at least one input device, and at least one output device.” – Processor and memory are used to conduct the computations.) identify an area of engagement of at least one tooth represented in a digital model of a dentition for applying a first force to move the at least one tooth according to a first movement as part of a treatment plan or a second force to move the at least one tooth according to a second movement as part of the treatment plan, wherein the treatment plan is configured to move the at least one tooth from an initial position to a final position, (Morton [0053]-[0055] “Customized design and use in orthodontic treatment as described herein can advantageously improve effectiveness of treatment and clinical results by more precisely applying force vectors of necessary magnitude and direction for desired movement. Orthodontic systems of the present invention including appliances and tooth attachments as described further provide an efficient force distribution mechanism that can more effectively reduce unwanted force and moment. A tooth attachment for delivering a movement force or system of forces is further illustrated with reference to FIG. 1B. The attachment is coupled to a surface of the tooth on the tooth crown and can couple with or engage a dental appliance or aligner as illustrated in FIG. 1A when the appliance is worn by the patient. When worn by the patient, the appliance engages the tooth crown and attachment, with interaction/contact between an activator, e.g., one or more surfaces or portions of the internal cavity of the appliance, and corresponding surfaces/portions of the tooth attachment and/or tooth crown to apply a system of forces for eliciting tooth movement. Various tooth movements can be accomplished, as further noted below. As set forth in the prior applications, an appliance can be designed and/or provided as part of a set or plurality of appliances and treatment can be administered according to a treatment plan. In such an embodiment, each appliance may be configured so that one or more tooth-receiving cavities has a geometry corresponding to an intermediate or final tooth arrangement intended for the appliance.” – Morton sets one or more treatments plans that deal with engagement of an aligner with one or more teeth to effectuate one or more tooth movements.) and wherein the area of engagement comprises a portion of the at least one tooth that is capable of engaging with a dental aligner to be manufactured to apply the first force or the second force to the at least one tooth via the area of engagement to move the at least one tooth; (Morton [0055] “Appliance geometries can be further designed or modified (e.g., modified to accommodate or operate in conjunction with tooth attachments) so as to apply a desired force or system of forces to the patient's teeth and elicit a desired tooth movement and gradually reposition teeth to an intended arrangement. The patient's teeth are progressively repositioned from their initial tooth arrangement to a final tooth arrangement by placing a series of incremental position adjustment appliances over the patient's teeth.” [0069] “Parameters which define attachments and may have their values incremented to determine the combinations which produce the desired force system include surface area, surface orientation, location on the tooth, size (length, depth, height), prominence defined as the distance an attachment is out of the tooth surface.” [0117] “In one aspect, based on the force behavior determined from the material properties and the amount of surface area perpendicular to the composite vector resulting from the movement vector for the particular treatment stage, additional surface area may be added to the tooth by employing an attachment that can be selected and further customized for the desired movement. In this manner, in one aspect, the cross section and/or orientation of the surface area may be determined for a particular tooth, and the attachment(s) can be incorporated on one or more teeth to enhance or improve upon the necessary surface area to cooperate or engage with the dental appliance to effect the desired movement vector or the predetermined level of force upon the tooth in the accurate direction for the treatment stage.” [0152] “Collisions and constraints are checked (step 2745). The attachment should not collide with other objects, such as other teeth or attachments, a ridge, a virtual filler, etc. In addition, the constraint thresholds should be satisfied, such as the distance to the gingival curve, the distance to the interproximial zone or region (IP zone or IPR), the distance to the incisal edge, etc.” [0106] “Various tooth root imaging and/or modeling (e.g., statistical root modeling) may be utilized. The teeth movement can be guided in part using a root-based sequencing system. In one embodiment, the movement is constrained by a surface area constraint” – Morton determines various forces to be applied to specified areas of the tooth by attachment engagement of a custom aligner for one or more teeth and for one or more variations of treatment plans.) determine [first and second designs] based on the area of engagement, the first force associated with the first movement, and the second force associated with the second movementand select the first movement for the treatment plan based on [orthodontic acceptability] . (Morton [0087] “FIG. 10B illustrates a process 200 implementing the appliance-calculation step (FIG. 6A, step 170) for polymeric shell aligners of the kind described in above-mentioned U.S. Pat. No. 5,975,893. Inputs to the process include an initial aligner shape 202, various control parameters 204, and a desired end configuration for the teeth at the end of the current treatment path segment 206. […] If the motions are orthodontically acceptable and the teeth have reached an acceptable position, the current aligner shape is compared to the previously calculated aligner shapes. If the current shape is the best solution so far (step 250), it is saved as the best candidate so far (step 260). If not, it is saved in an optional step as a possible intermediate result (step 252). If the current aligner shape is the best candidate so far, the process determines whether it is good enough to be accepted (step 270). If it is, the process exits. Otherwise, the process continues and calculates another candidate shape (step 240) for analysis.” - Morton tries different configurations for different treatment plans and compares them to determine an optimal treatment plan.) Morton teaches modifying treatment plans to meet orthodontic acceptability (see prior paragraph) but does not appear to explicitly teach, but Morton in view of Kukk teaches: determine a first controllability score for the first movement and a second controllability score for the second movement based on the area of engagement, the first force associated with the first movement, and the second force associated with the second movement, wherein the first controllability score indicates an ability to achieve the first movement and the second controllability score indicates an ability to achieve the second movement; select the first movement for the treatment plan based on the first controllability score and the second controllability score; and generate an inner surface geometry of a digital model of a dental appliance based on the first movement to increase the area of engagement between the dental appliance and the at least one tooth. (Kukk [0074]-[0075] “The retentiveness of an aligner may be estimated based on the shape and orientation of one or more teeth in the patient's dentition. In any of these methods and apparatuses, the retentiveness may be estimated based on the angle of the side (e.g., the buccal and/or lingual side) of all or some of the teeth relative to the long axis of the tooth (e.g., an axis extending normal to the occlusal surface of the tooth). FIG. 2A shows a side view of a tooth 200 to illustrate how a shape and orientation of the tooth 200 can be used to determine a retention value or score of the tooth 200. The estimation may be based on a 3D model of the tooth 200 in predetermined orientation. For example, the tooth 200 may be oriented in accordance with a position/orientation of the tooth at initiation of a particular stage of the treatment plan. A reference vector 202 that is parallel to a long axis of the tooth 200 is determined. In addition, surface normal vectors, e.g., 204, distributed across a surface of the tooth 200 and that are normal to the surface of the tooth 200 are determined. For example, each surface normal vector, e.g., 204, may be associated with a polygon of a surface mesh of the 3D model. Angles, e.g., 206, between the reference vector 202 and each of the surface normal vectors, e.g., 204, are then calculated. These angles, e.g., 206, are associated with a degree in which portions of the tooth surface can provide a retention force for an aligner. For example, surface portions associated with angles, e.g., 206, greater than 90 degrees can contribute a positive retention force for an aligner. Surface portions associated with angles greater than 90 degrees, such as the surface associated with surface normal vector 204 in FIG. 2, may be referred to as an undercut surface portion. A retention value or score of the tooth 200 may be estimated based on the number of angles, e.g., 206, that are greater than 90 degrees. In some cases, this calculation includes calculating a cosine of each of the angle(s), e.g., 206, based on vectors that are normal 204 to the surface of identified polygons. The angles of each of the identified polygons may be measured and added together to provide a weighting based on surface area. The retention value/score of the tooth 200 may be based on this sum. In some cases, the retention value/score may be based on a range. For example, the tooth 200 may be estimated to have a low retention value/score if the area of retention surfaces is above a first threshold, a medium retention value/score if the area of retention surfaces is above a second threshold greater than the first threshold, and a high retention value/score if the area of retention surfaces is above a third threshold greater than the second threshold. Retention scores may be estimated for individual teeth and/or for groups of the teeth (or all of the teeth). In some examples, retention values/scores for various zones of a dentition may be calculated based on the retention values/scores of the teeth. FIG. 2B illustrates an example dentition showing retention scores for different zones of the dentition (e.g., as shown in a user interface). In this example, retention values/scores are provided for three zones: Zone 1, Zone 2, and Zone 3. Zone 1 includes the lower left 8 tooth (LL8), the lower left 7 tooth (LL7), and the lower left 6 tooth (LL6), which correspond to the three last posterior teeth of the left side of the lower dentition. Zone 2 includes all the teeth of Zone 1 and also the lower left 5 tooth (LL5), which correspond to the four last posterior teeth of the left side of the lower dentition. Zone 3 includes all the teeth of Zone 2 and also the lower left 4 tooth (LL4), which correspond to the five last posterior teeth of the left side of the lower dentition. In this case, the retention values of each of the Zones 1-3 corresponds to an average retention value of the teeth of each zone. For example, Zone 1 has a retention value/score of R3, Zone 2 has a retention value/score of R4, and Zone 3 has a retention value/score of R5. A predicted lack of retention of an aligner can be determined based on a comparing retention values/scores of the zones to threshold values. In this example, a lack of retentive forces in the lower left quadrant of the dentition may be detected if R3 of Zone 1 is less than a first threshold value T3, R4 of Zone 2 is less than a second threshold value T4, or R5 of Zone 3 is less than a third threshold value T5. Similar calculations may be performed for other regions of the dentition (e.g., lower right quadrant). These calculations may then be used to determine a retentiveness of the aligner. For example, if it is determined that a left or right quadrant of a dentition lacks retentive forces, the user may be informed that the aligner is predicted to lack retentiveness. If a lack of retentiveness is determined, one or more retention-enhancing attachment locations for increasing the retention forces may be determined. For example, if one of Zones 1-3 has a low retention value/score, one or more attachments may be recommended on one or more teeth within Zones 1-3. In some cases, the recommendation is based on the retention value/score of a particular tooth. For example, if tooth LL7 has a low retention value (e.g., lower than a threshold value), an attachment may be recommended for the tooth LL7. In some examples, a shape, size and/or specific location on a tooth of one or more retention-enhancing attachments is recommended.” – This describes retention value/score systems based on available engagement area on the tooth at angles relative to the forces applied for generating better corrections with improved controllability.) It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claims to modify Morton’s aligner development by Kukk’s orthodontic considerations, as the person of ordinary skill in the art would be motivated to by Morton’s express aim to precisely control the moments applied to the teeth (e.g., angles and surface areas for engagement) to improve controlled treatment and clinical results with precise applied forces customized to a particular patient, to look to Kukk whose methods improve adaptability of the orthodontic suite of Morton, better customizing the treatment to make it more suitable for people. (Morton [0005]-[0006] “Current tooth attachments used for rotation have the same shape and position for all patients and teeth undergoing movement with a rotation component. Due to the individual morphology of teeth and composite movements, the performance of such attachments may not be optimal for all patients. Accordingly, improved techniques and orthodontic systems are needed for designing and providing more effective tooth movement forces to the teeth during orthodontic treatment using tooth attachments, and reducing unwanted tooth movements.” [0053] “As further described herein, tooth attachments can be designed, oriented, and/or located on a patient's tooth to precisely control the moments produced on a patient's tooth as the appliance is worn by the patient. Customized design and use in orthodontic treatment as described herein can advantageously improve effectiveness of treatment and clinical results by more precisely applying force vectors of necessary magnitude and direction for desired movement. Orthodontic systems of the present invention including appliances and tooth attachments as described further provide an efficient force distribution mechanism that can more effectively reduce unwanted force and moment.”; Kukk [0006] “The methods and apparatuses described herein may be used to improve detection of aligners that are at risk of improper fitting, as well as identifying and implementing adjustments to aligner designs to prevent improper fitting.” [0008] “The methods and apparatuses described herein provide specific improvement over currently described systems in which the fit of one or more (and particularly a series) of dental appliances is determined only after fabrication of the appliance, or by trial-and-error. These methods and apparatuses may instead provide a dynamic method and apparatus (e.g., user interface) that may allow a user to quickly modify, in an iterative manner, specific subsets of features that may cause discrepancies and therefore poor fit. For example, a poor fit may result in a variety of different features (e.g., a mis-match of tooth shape, tooth position, and/or gingival line, a missing extracted tooth, or a present erupted tooth). By allowing the user to separately view and adjust these features in a user interface the overall design process may be vastly streamlined.”) Regarding claim 12, claim 12 recites the operations conducted by the system of claim 16 and is rejected for at least the same reasons. Claims 13 and 17 Regarding claim 17 (and 13), Morton in view of Kukk teaches the features of claim 16 (and claim 12) and further teaches: wherein the first movement is selected for the treatment plan based on the first controllability score exceeding the second controllability score. (Morton [0087] “ If the motions are orthodontically acceptable and the teeth have reached an acceptable position, the current aligner shape is compared to the previously calculated aligner shapes. If the current shape is the best solution so far (step 250), it is saved as the best candidate so far (step 260). If not, it is saved in an optional step as a possible intermediate result (step 252). If the current aligner shape is the best candidate so far, the process determines whether it is good enough to be accepted (step 270). If it is, the process exits. Otherwise, the process continues and calculates another candidate shape (step 240) for analysis.” -Morton tries different configurations and compares them. Kukk [0074]-[0075] “The retentiveness of an aligner may be estimated based on the shape and orientation of one or more teeth in the patient's dentition. In any of these methods and apparatuses, the retentiveness may be estimated based on the angle of the side (e.g., the buccal and/or lingual side) of all or some of the teeth relative to the long axis of the tooth (e.g., an axis extending normal to the occlusal surface of the tooth). FIG. 2A shows a side view of a tooth 200 to illustrate how a shape and orientation of the tooth 200 can be used to determine a retention value or score of the tooth 200. The estimation may be based on a 3D model of the tooth 200 in predetermined orientation. For example, the tooth 200 may be oriented in accordance with a position/orientation of the tooth at initiation of a particular stage of the treatment plan. A reference vector 202 that is parallel to a long axis of the tooth 200 is determined. In addition, surface normal vectors, e.g., 204, distributed across a surface of the tooth 200 and that are normal to the surface of the tooth 200 are determined. For example, each surface normal vector, e.g., 204, may be associated with a polygon of a surface mesh of the 3D model. Angles, e.g., 206, between the reference vector 202 and each of the surface normal vectors, e.g., 204, are then calculated. These angles, e.g., 206, are associated with a degree in which portions of the tooth surface can provide a retention force for an aligner. For example, surface portions associated with angles, e.g., 206, greater than 90 degrees can contribute a positive retention force for an aligner. Surface portions associated with angles greater than 90 degrees, such as the surface associated with surface normal vector 204 in FIG. 2, may be referred to as an undercut surface portion. A retention value or score of the tooth 200 may be estimated based on the number of angles, e.g., 206, that are greater than 90 degrees. In some cases, this calculation includes calculating a cosine of each of the angle(s), e.g., 206, based on vectors that are normal 204 to the surface of identified polygons. The angles of each of the identified polygons may be measured and added together to provide a weighting based on surface area. The retention value/score of the tooth 200 may be based on this sum. In some cases, the retention value/score may be based on a range. For example, the tooth 200 may be estimated to have a low retention value/score if the area of retention surfaces is above a first threshold, a medium retention value/score if the area of retention surfaces is above a second threshold greater than the first threshold, and a high retention value/score if the area of retention surfaces is above a third threshold greater than the second threshold. Retention scores may be estimated for individual teeth and/or for groups of the teeth (or all of the teeth). In some examples, retention values/scores for various zones of a dentition may be calculated based on the retention values/scores of the teeth. FIG. 2B illustrates an example dentition showing retention scores for different zones of the dentition (e.g., as shown in a user interface). In this example, retention values/scores are provided for three zones: Zone 1, Zone 2, and Zone 3. Zone 1 includes the lower left 8 tooth (LL8), the lower left 7 tooth (LL7), and the lower left 6 tooth (LL6), which correspond to the three last posterior teeth of the left side of the lower dentition. Zone 2 includes all the teeth of Zone 1 and also the lower left 5 tooth (LL5), which correspond to the four last posterior teeth of the left side of the lower dentition. Zone 3 includes all the teeth of Zone 2 and also the lower left 4 tooth (LL4), which correspond to the five last posterior teeth of the left side of the lower dentition. In this case, the retention values of each of the Zones 1-3 corresponds to an average retention value of the teeth of each zone. For example, Zone 1 has a retention value/score of R3, Zone 2 has a retention value/score of R4, and Zone 3 has a retention value/score of R5. A predicted lack of retention of an aligner can be determined based on a comparing retention values/scores of the zones to threshold values. In this example, a lack of retentive forces in the lower left quadrant of the dentition may be detected if R3 of Zone 1 is less than a first threshold value T3, R4 of Zone 2 is less than a second threshold value T4, or R5 of Zone 3 is less than a third threshold value T5. Similar calculations may be performed for other regions of the dentition (e.g., lower right quadrant). These calculations may then be used to determine a retentiveness of the aligner. For example, if it is determined that a left or right quadrant of a dentition lacks retentive forces, the user may be informed that the aligner is predicted to lack retentiveness. If a lack of retentiveness is determined, one or more retention-enhancing attachment locations for increasing the retention forces may be determined. For example, if one of Zones 1-3 has a low retention value/score, one or more attachments may be recommended on one or more teeth within Zones 1-3. In some cases, the recommendation is based on the retention value/score of a particular tooth. For example, if tooth LL7 has a low retention value (e.g., lower than a threshold value), an attachment may be recommended for the tooth LL7. In some examples, a shape, size and/or specific location on a tooth of one or more retention-enhancing attachments is recommended.” – Kukk uses retention value/score systems based on available engagement area on the tooth at angles relative to the forces applied for generating devices with better corrections with improved controllability. Multiple scores for different configurations are determined, even for each tooth or group of teeth and compared, with the option of selecting configurations with better scores.) Regarding claim 13, claim 13 recites the operations conducted by the system of claim 17 and is rejected for at least the same reasons. Claims 14 and 18 Regarding claim 18 (and 14), Morton in view of Kukk teaches the features of claim 16 (and claim 12) and further teaches: wherein the memory further stores instructions that, when executed by the one or more processors, cause the one or more processors to: (Morton [0168] “The data processing aspects of the invention can be implemented in digital electronic circuitry, or in computer hardware, firmware, software, or in combinations of them. Data processing apparatus of the invention can be implemented in a computer program product tangibly embodied in a machine-readable storage device for execution by a programmable processor; and data processing method steps of the invention can be performed by a programmable processor executing a program of instructions to perform functions of the invention by operating on input data and generating output. The data processing aspects of the invention can be implemented advantageously in one or more computer programs that are executable on a programmable system including at least one programmable processor coupled to receive data and instructions from and to transmit data and instructions to a data storage system, at least one input device, and at least one output device.” – Processor and memory are used to conduct the computations.) determine a third controllability score for a third movement subsequent to the first movement; and determine a fourth controllability score for a fourth movement subsequent to the second movement; wherein the first movement is selected for the treatment plan based on a summation of the first controllability score and the third controllability score exceeding a summation of the second controllability score and the fourth controllability score. (Morton [0082] “The tooth paths are segmented. The segments are calculated so that each tooth's motion within a segment stays within threshold limits of linear and rotational translation. In this way, the end points of each path segment can constitute a clinically viable repositioning, and the aggregate of segment end points constitute a clinically viable sequence of tooth positions, so that moving from one point to the next in the sequence does not result in a collision of teeth.” – Each movement can be segmented into multiple. So, a fifth movement could be specified that is composed of the first movement and the third movement subsequent to the first. Similarly, a sixth movement could be specified that is composed of the second movement and the fourth movement subsequent to the second movement. Kukk [0074]-[0075] “The retentiveness of an aligner may be estimated based on the shape and orientation of one or more teeth in the patient's dentition. In any of these methods and apparatuses, the retentiveness may be estimated based on the angle of the side (e.g., the buccal and/or lingual side) of all or some of the teeth relative to the long axis of the tooth (e.g., an axis extending normal to the occlusal surface of the tooth). FIG. 2A shows a side view of a tooth 200 to illustrate how a shape and orientation of the tooth 200 can be used to determine a retention value or score of the tooth 200. The estimation may be based on a 3D model of the tooth 200 in predetermined orientation. For example, the tooth 200 may be oriented in accordance with a position/orientation of the tooth at initiation of a particular stage of the treatment plan. A reference vector 202 that is parallel to a long axis of the tooth 200 is determined. In addition, surface normal vectors, e.g., 204, distributed across a surface of the tooth 200 and that are normal to the surface of the tooth 200 are determined. For example, each surface normal vector, e.g., 204, may be associated with a polygon of a surface mesh of the 3D model. Angles, e.g., 206, between the reference vector 202 and each of the surface normal vectors, e.g., 204, are then calculated. These angles, e.g., 206, are associated with a degree in which portions of the tooth surface can provide a retention force for an aligner. For example, surface portions associated with angles, e.g., 206, greater than 90 degrees can contribute a positive retention force for an aligner. Surface portions associated with angles greater than 90 degrees, such as the surface associated with surface normal vector 204 in FIG. 2, may be referred to as an undercut surface portion. A retention value or score of the tooth 200 may be estimated based on the number of angles, e.g., 206, that are greater than 90 degrees. In some cases, this calculation includes calculating a cosine of each of the angle(s), e.g., 206, based on vectors that are normal 204 to the surface of identified polygons. The angles of each of the identified polygons may be measured and added together to provide a weighting based on surface area. The retention value/score of the tooth 200 may be based on this sum. In some cases, the retention value/score may be based on a range. For example, the tooth 200 may be estimated to have a low retention value/score if the area of retention surfaces is above a first threshold, a medium retention value/score if the area of retention surfaces is above a second threshold greater than the first threshold, and a high retention value/score if the area of retention surfaces is above a third threshold greater than the second threshold. Retention scores may be estimated for individual teeth and/or for groups of the teeth (or all of the teeth). In some examples, retention values/scores for various zones of a dentition may be calculated based on the retention values/scores of the teeth. FIG. 2B illustrates an example dentition showing retention scores for different zones of the dentition (e.g., as shown in a user interface). In this example, retention values/scores are provided for three zones: Zone 1, Zone 2, and Zone 3. Zone 1 includes the lower left 8 tooth (LL8), the lower left 7 tooth (LL7), and the lower left 6 tooth (LL6), which correspond to the three last posterior teeth of the left side of the lower dentition. Zone 2 includes all the teeth of Zone 1 and also the lower left 5 tooth (LL5), which correspond to the four last posterior teeth of the left side of the lower dentition. Zone 3 includes all the teeth of Zone 2 and also the lower left 4 tooth (LL4), which correspond to the five last posterior teeth of the left side of the lower dentition. In this case, the retention values of each of the Zones 1-3 corresponds to an average retention value of the teeth of each zone. For example, Zone 1 has a retention value/score of R3, Zone 2 has a retention value/score of R4, and Zone 3 has a retention value/score of R5. A predicted lack of retention of an aligner can be determined based on a comparing retention values/scores of the zones to threshold values. In this example, a lack of retentive forces in the lower left quadrant of the dentition may be detected if R3 of Zone 1 is less than a first threshold value T3, R4 of Zone 2 is less than a second threshold value T4, or R5 of Zone 3 is less than a third threshold value T5. Similar calculations may be performed for other regions of the dentition (e.g., lower right quadrant). These calculations may then be used to determine a retentiveness of the aligner. For example, if it is determined that a left or right quadrant of a dentition lacks retentive forces, the user may be informed that the aligner is predicted to lack retentiveness. If a lack of retentiveness is determined, one or more retention-enhancing attachment locations for increasing the retention forces may be determined. For example, if one of Zones 1-3 has a low retention value/score, one or more attachments may be recommended on one or more teeth within Zones 1-3. In some cases, the recommendation is based on the retention value/score of a particular tooth. For example, if tooth LL7 has a low retention value (e.g., lower than a threshold value), an attachment may be recommended for the tooth LL7. In some examples, a shape, size and/or specific location on a tooth of one or more retention-enhancing attachments is recommended.” – This describes retention value/score systems based on available engagement area on the tooth at angles relative to the forces applied for generating better corrections with improved controllability. These can be done at every stage of the process and for any subset of teeth in each stage, as taught by the combination of Morton and Kukk.) Regarding claim 14, claim 14 recites the operations conducted by the system of claim 18 and is rejected for at least the same reasons. Claims 15 and 20 Regarding claim 20 (and 15), Morton in view of Kukk teaches the features of claim 16 (and 12), and further teaches: wherein the at least one tooth is a first tooth, and wherein the first movement is selected for the treatment plan based on a controllability score of a movement selected to be applied to a second tooth represented in the digital model of the dentition. (Morton [0063] “As noted above, appliances or aligners accomplish tooth movement by applying a series or system of forces (force system) comprised of forces, the moment of a force, and the moment of a couple to a tooth to elicit a biological response of the periodontal tissues and bone structures which surround the tooth. Different force systems result in different types of tooth movement: tipping, translation, root movement, etc. In some cases, the aligner alone cannot deliver the force system required to accomplish a desired tooth movement. An amount of material or structure, commonly referred to in the orthodontic arena as an attachment, can be bonded to the tooth to aid the aligner in delivering the appropriate force system to the tooth. The state-of-the-art in attachments is fixed geometric shapes which are indicated for use when a specific tooth movement is desired. However, the selection of an attachment paired with the aligner to improve movement has historically been determined from clinical observation alone and has demonstrated in some instances limited clinical success and lack of precise clinical control of the force system deliverer to the tooth. Methods and systems according to the present invention advantageously consider and account for various factors which can have a significant effect on imparting a precise force system to a tooth, including biomechanical principles, tooth morphology, attachment location, attachment orientation, and probability of engagement between the aligner. The present invention uses these inputs to determine the optimal design of the attachment to be used with the aligner for the specific movement of a specific tooth, and accommodate specific attachment characteristics determined for a specific tooth and specific desired movement. Thus, the current attachments and orthodontic systems provide optimized as well as customized individualized attachment design for a specific tooth and a specific movement.” [0123] “ Additionally, in one aspect, a plurality of attachments, e.g., a series of abutting attachments may be provided to alter the force direction or generate the movement vector which is carried over for a predetermined time period” [0129] “Additionally, the force direction for the tooth movement, as well as counter forces for addressing unwanted or unintended forces are determined. Thereafter, based on the determined components associated with the movement vector which is associated with the tooth movement from the initial position to the target position, the cavity geometry of the dental appliance such as the aligner is modified (step 2150).” [0132] “FIG. 19 illustrates that an object may be moved by applying a force along any direction tangential to the object's rotational trajectory. Specifically, a force (a, b, c or d) applied to an object 2300 can rotate the object in a circle by a torque of the cross product of an arm (r) and the amount of force (F) applied to the object, r×F. A pair of equal and opposite forces may create a torque that has a zero resultant force (e.g., forces a and c, or forces b and d). Three parameters together generate a torque: 1) a force vector, 2) a point where the force is applied, and 3) a point at which the torque is measured. The point where the force is applied and the point at which the torque is measured determine the arm vector. When rotating a tooth, the torque is calculated with respect to a center of resistance of the tooth.” – Composite forces from the aligner on a specific tooth general come from direct contact with a tooth and indirect contact with other teeth. This is reflected in the design of the aligner. Kukk [0074]-[0075] “The retentiveness of an aligner may be estimated based on the shape and orientation of one or more teeth in the patient's dentition. In any of these methods and apparatuses, the retentiveness may be estimated based on the angle of the side (e.g., the buccal and/or lingual side) of all or some of the teeth relative to the long axis of the tooth (e.g., an axis extending normal to the occlusal surface of the tooth). FIG. 2A shows a side view of a tooth 200 to illustrate how a shape and orientation of the tooth 200 can be used to determine a retention value or score of the tooth 200. The estimation may be based on a 3D model of the tooth 200 in predetermined orientation. For example, the tooth 200 may be oriented in accordance with a position/orientation of the tooth at initiation of a particular stage of the treatment plan. A reference vector 202 that is parallel to a long axis of the tooth 200 is determined. In addition, surface normal vectors, e.g., 204, distributed across a surface of the tooth 200 and that are normal to the surface of the tooth 200 are determined. For example, each surface normal vector, e.g., 204, may be associated with a polygon of a surface mesh of the 3D model. Angles, e.g., 206, between the reference vector 202 and each of the surface normal vectors, e.g., 204, are then calculated. These angles, e.g., 206, are associated with a degree in which portions of the tooth surface can provide a retention force for an aligner. For example, surface portions associated with angles, e.g., 206, greater than 90 degrees can contribute a positive retention force for an aligner. Surface portions associated with angles greater than 90 degrees, such as the surface associated with surface normal vector 204 in FIG. 2, may be referred to as an undercut surface portion. A retention value or score of the tooth 200 may be estimated based on the number of angles, e.g., 206, that are greater than 90 degrees. In some cases, this calculation includes calculating a cosine of each of the angle(s), e.g., 206, based on vectors that are normal 204 to the surface of identified polygons. The angles of each of the identified polygons may be measured and added together to provide a weighting based on surface area. The retention value/score of the tooth 200 may be based on this sum. In some cases, the retention value/score may be based on a range. For example, the tooth 200 may be estimated to have a low retention value/score if the area of retention surfaces is above a first threshold, a medium retention value/score if the area of retention surfaces is above a second threshold greater than the first threshold, and a high retention value/score if the area of retention surfaces is above a third threshold greater than the second threshold. Retention scores may be estimated for individual teeth and/or for groups of the teeth (or all of the teeth). In some examples, retention values/scores for various zones of a dentition may be calculated based on the retention values/scores of the teeth. FIG. 2B illustrates an example dentition showing retention scores for different zones of the dentition (e.g., as shown in a user interface). In this example, retention values/scores are provided for three zones: Zone 1, Zone 2, and Zone 3. Zone 1 includes the lower left 8 tooth (LL8), the lower left 7 tooth (LL7), and the lower left 6 tooth (LL6), which correspond to the three last posterior teeth of the left side of the lower dentition. Zone 2 includes all the teeth of Zone 1 and also the lower left 5 tooth (LL5), which correspond to the four last posterior teeth of the left side of the lower dentition. Zone 3 includes all the teeth of Zone 2 and also the lower left 4 tooth (LL4), which correspond to the five last posterior teeth of the left side of the lower dentition. In this case, the retention values of each of the Zones 1-3 corresponds to an average retention value of the teeth of each zone. For example, Zone 1 has a retention value/score of R3, Zone 2 has a retention value/score of R4, and Zone 3 has a retention value/score of R5. A predicted lack of retention of an aligner can be determined based on a comparing retention values/scores of the zones to threshold values. In this example, a lack of retentive forces in the lower left quadrant of the dentition may be detected if R3 of Zone 1 is less than a first threshold value T3, R4 of Zone 2 is less than a second threshold value T4, or R5 of Zone 3 is less than a third threshold value T5. Similar calculations may be performed for other regions of the dentition (e.g., lower right quadrant). These calculations may then be used to determine a retentiveness of the aligner. For example, if it is determined that a left or right quadrant of a dentition lacks retentive forces, the user may be informed that the aligner is predicted to lack retentiveness. If a lack of retentiveness is determined, one or more retention-enhancing attachment locations for increasing the retention forces may be determined. For example, if one of Zones 1-3 has a low retention value/score, one or more attachments may be recommended on one or more teeth within Zones 1-3. In some cases, the recommendation is based on the retention value/score of a particular tooth. For example, if tooth LL7 has a low retention value (e.g., lower than a threshold value), an attachment may be recommended for the tooth LL7. In some examples, a shape, size and/or specific location on a tooth of one or more retention-enhancing attachments is recommended.” – This describes retention value/score systems based on available engagement area on the tooth at angles relative to the forces applied for generating better corrections with improved controllability, and these can be applied to single teeth or multiple teeth and accounting for multiple teeth.) Regarding claim 15, claim 15 recites the operations conducted by the system of claim 20 and is rejected for at least the same reasons. Claim 19 Regarding claim 19, Morton in view of Kukk teaches the feature of claim 18 and further teaches: wherein the second controllability score exceeds the first controllability score. (Morton [0087] “If the motions are orthodontically acceptable and the teeth have reached an acceptable position, the current aligner shape is compared to the previously calculated aligner shapes. If the current shape is the best solution so far (step 250), it is saved as the best candidate so far (step 260). If not, it is saved in an optional step as a possible intermediate result (step 252). If the current aligner shape is the best candidate so far, the process determines whether it is good enough to be accepted (step 270). If it is, the process exits. Otherwise, the process continues and calculates another candidate shape (step 240) for analysis.” – Morton compares the models for orthodontic acceptability. Kukk [0074]-[0075] “The retentiveness of an aligner may be estimated based on the shape and orientation of one or more teeth in the patient's dentition. In any of these methods and apparatuses, the retentiveness may be estimated based on the angle of the side (e.g., the buccal and/or lingual side) of all or some of the teeth relative to the long axis of the tooth (e.g., an axis extending normal to the occlusal surface of the tooth). FIG. 2A shows a side view of a tooth 200 to illustrate how a shape and orientation of the tooth 200 can be used to determine a retention value or score of the tooth 200. The estimation may be based on a 3D model of the tooth 200 in predetermined orientation. For example, the tooth 200 may be oriented in accordance with a position/orientation of the tooth at initiation of a particular stage of the treatment plan. A reference vector 202 that is parallel to a long axis of the tooth 200 is determined. In addition, surface normal vectors, e.g., 204, distributed across a surface of the tooth 200 and that are normal to the surface of the tooth 200 are determined. For example, each surface normal vector, e.g., 204, may be associated with a polygon of a surface mesh of the 3D model. Angles, e.g., 206, between the reference vector 202 and each of the surface normal vectors, e.g., 204, are then calculated. These angles, e.g., 206, are associated with a degree in which portions of the tooth surface can provide a retention force for an aligner. For example, surface portions associated with angles, e.g., 206, greater than 90 degrees can contribute a positive retention force for an aligner. Surface portions associated with angles greater than 90 degrees, such as the surface associated with surface normal vector 204 in FIG. 2, may be referred to as an undercut surface portion. A retention value or score of the tooth 200 may be estimated based on the number of angles, e.g., 206, that are greater than 90 degrees. In some cases, this calculation includes calculating a cosine of each of the angle(s), e.g., 206, based on vectors that are normal 204 to the surface of identified polygons. The angles of each of the identified polygons may be measured and added together to provide a weighting based on surface area. The retention value/score of the tooth 200 may be based on this sum. In some cases, the retention value/score may be based on a range. For example, the tooth 200 may be estimated to have a low retention value/score if the area of retention surfaces is above a first threshold, a medium retention value/score if the area of retention surfaces is above a second threshold greater than the first threshold, and a high retention value/score if the area of retention surfaces is above a third threshold greater than the second threshold. Retention scores may be estimated for individual teeth and/or for groups of the teeth (or all of the teeth). In some examples, retention values/scores for various zones of a dentition may be calculated based on the retention values/scores of the teeth. FIG. 2B illustrates an example dentition showing retention scores for different zones of the dentition (e.g., as shown in a user interface). In this example, retention values/scores are provided for three zones: Zone 1, Zone 2, and Zone 3. Zone 1 includes the lower left 8 tooth (LL8), the lower left 7 tooth (LL7), and the lower left 6 tooth (LL6), which correspond to the three last posterior teeth of the left side of the lower dentition. Zone 2 includes all the teeth of Zone 1 and also the lower left 5 tooth (LL5), which correspond to the four last posterior teeth of the left side of the lower dentition. Zone 3 includes all the teeth of Zone 2 and also the lower left 4 tooth (LL4), which correspond to the five last posterior teeth of the left side of the lower dentition. In this case, the retention values of each of the Zones 1-3 corresponds to an average retention value of the teeth of each zone. For example, Zone 1 has a retention value/score of R3, Zone 2 has a retention value/score of R4, and Zone 3 has a retention value/score of R5. A predicted lack of retention of an aligner can be determined based on a comparing retention values/scores of the zones to threshold values. In this example, a lack of retentive forces in the lower left quadrant of the dentition may be detected if R3 of Zone 1 is less than a first threshold value T3, R4 of Zone 2 is less than a second threshold value T4, or R5 of Zone 3 is less than a third threshold value T5. Similar calculations may be performed for other regions of the dentition (e.g., lower right quadrant). These calculations may then be used to determine a retentiveness of the aligner. For example, if it is determined that a left or right quadrant of a dentition lacks retentive forces, the user may be informed that the aligner is predicted to lack retentiveness. If a lack of retentiveness is determined, one or more retention-enhancing attachment locations for increasing the retention forces may be determined. For example, if one of Zones 1-3 has a low retention value/score, one or more attachments may be recommended on one or more teeth within Zones 1-3. In some cases, the recommendation is based on the retention value/score of a particular tooth. For example, if tooth LL7 has a low retention value (e.g., lower than a threshold value), an attachment may be recommended for the tooth LL7. In some examples, a shape, size and/or specific location on a tooth of one or more retention-enhancing attachments is recommended.” – This describes retention value/score systems based on available engagement area on the tooth at angles relative to the forces applied for generating better corrections with improved controllability. Kukk teaches the comparison of these various scores in determining the best course of action for adjustment, even providing different grades based on the relative scores.) Conclusion 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. The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. (From Current Action) US 2022/0313391 A1 to Moray (Teaches determining controllability scores based on available engagement area) US 2021/0361387 A1 to Salah et al. (Teaches determining controllability scores based on available engagement area) US 2018/0235437 A1 to Ozerov et al. (Teaches determining controllability scores based on available engagement area) US 2009/0191503 A1 to Matov et al. (Teaches determining controllability scores based on available engagement area) (From Prior Action) US 2019/0175303 A1 to Akopov et al. (Teaches determining and scoring multiple treatment plans) US 2016/0095668 A1 to Kuo et al. (Teaches determining and scoring multiple treatment plans based on reference points on teeth) US 20080182220 A1 to Chisthi et al. (Teaches orthodontic modeling, emphasizing tooth surfaces) US 2020/0000551 A1 to Li et al. (Teaches quantifying simulated outcomes of different orthodontic treatment plans) WO 2021/030284 A1 to Phan et al. (Teaches determining features of the treatment plan based on engageable surface area) WO 2000/019928 A1 to Chisthi et al. (Teaches using averages of normal to teeth surfaces to determine metrics) NPL: “Predicting patient experience of Invisalign treatment: An analysis using artificial neural network” by Xu et al. (Teaches using neural nets to determine likelihood of successful aligner outcome) NPL: “Predictability of rotational tooth movement with orthodontic aligners comparing software-based and achieved data: A systematic review and meta-analysis of observational studies” by Koletsi et al. (Teaches prediction of rotational tooth movement) NPL: “Forces and moments generated by removable thermoplastic aligners: Incisor torque, premolar derotation, and molar distalization” by Simon et al. (Teaches some physics of aligner orthodontia) NPL: “Prioritized Commitment-Based Clinical Assessment: A New Method for Assessment of Orthodontic Treatment Outcomes” by Safavi et al. (Teaches proposed modified metrics for scoring orthodontia) Any inquiry concerning this communication or earlier communications from the examiner should be directed to JAY MICHAEL WHITE whose telephone number is (571)272-7073. The examiner can normally be reached Mon-Fri 11:00-7:00 EST. 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, Ryan Pitaro can be reached at (571) 272-4071. 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. /J.M.W./Examiner, Art Unit 2188 /MICHAEL EDWARD COCCHI/Primary Examiner, Art Unit 2188
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Prosecution Timeline

Aug 05, 2022
Application Filed
Dec 18, 2025
Non-Final Rejection mailed — §101, §103
Jun 17, 2026
Response Filed
Aug 12, 2026
Final Rejection mailed — §101, §103 (current)

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