DETAILED ACTION
Status of Claims
In the response dated December 30, 2025, Applicant amended claims 1, 11, and 19. Claims 2, 12, and 20 were canceled, and claims 5 and 15 were previously canceled. Claims 1, 3, 4, 6-11, 13, 14, and 16-19 are pending in the current application.
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on December 30, 2025 has been entered.
Response to Arguments
Applicant's arguments with respect to the rejection under 35 U.S.C. 101 have been fully considered but they are not persuasive. Applicant asserts that the newly amended recitations of training data and OCR are directed to patent eligible subject matter. Examiner respectfully disagrees. The claims recite conventional computer-implemented models without specific improvements to the technology itself. Additionally, applying machine learning to validating and qualifying credentials does not transform the abstract idea into a patent-eligible invention. Simply applying generic machine learning techniques to credential validation, without improving the underlying technology, is insufficient for patent eligibility. Applicant asserts that “extracting information from the credential issued to the clinician” cannot be performed in the human mind or performed by a human. Examiner respectfully disagrees. Claims can recite a mental process even if they are claimed as being performed on a computer if the abstract idea could be performed by humans without a computer (see MPEP 2106.04(a)(2)(III)(C)). In this case, the steps encompass a person reviewing healthcare credentials for validity to qualify the healthcare professional for home healthcare. Applicant asserts that the claims do not recite a mental process because the limitations 1) are not recited at a high level of generality and 2) improve an existing technological process as the claims requires complex processing and therefore impose meaningful limits on the claim. Examiner respectfully disagrees. As a whole, the additional elements recite storing data into memory. The processor, memory, computing devices, application programming interface, and computer-implemented models in the steps are recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using a generic computer component. Accordingly, this additional element does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Lastly, Applicant asserts that the claims amount to more than an abstract idea because the recited structural elements are required to execute limitations. Examiner respectfully disagrees. As stated above, a claim can recite a mental process even if they are claimed as being performed by a computer and the processor, memory, computing devices, application programming interface, and computer-implemented models in the steps are recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using a generic computer component. The rejection is maintained.
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1, 3, 4, 6-11, 13, 14, and 16-19 are rejected under 35 U.S.C. 101 because the claims are not directed to patent eligible subject matter.
Claims 1, 3, 4, 6-11, 13, 14, and 16-19 do fall within at least one of the four categories of patent eligible subject matter because the claims recite a machine (i.e., non-transitory computer-readable medium and system) and process (i.e., a method).
Although claims 1, 3, 4, 6-11, 13, 14, and 16-19 fall under at least one of the four statutory categories, it should be determined whether the claim wholly embraces a judicially recognized exception, which includes laws of nature, physical phenomena, and abstract ideas, or is it a particular practical application of a judicial exception (See MPEP 2106 I and II).
Claims 1, 3, 4, 6-11, 13, 14, and 16-19 are directed to a judicial exception (i.e., a law of nature, natural phenomenon, or abstract idea) without significantly more.
Part I: Step 2A, Prong One: Identify the Abstract Idea
Under step 2A, Prong One of the Alice framework, the claims are analyzed to determine if the claims are directed to a judicial exception. MPEP §2106.04(a). The determination consists of a) identifying the specific limitations in the claim that recite an abstract idea; and b) determining whether the identified limitations fall within at least one of the three subject matter groupings of abstract ideas (i.e., mathematical concepts, mental processes, and certain methods of organizing human activity).
The identified limitations of independent claim 11 (representative of independent claims 1 and 19) recite:
a memory storing instructions; and
a processor communicatively coupled to the memory, wherein, when the instructions are executed by the processor, the instructions cause the processor to:
receive, from a computing device of a clinician, an image of a credential issued to the clinician, wherein the credential pertains to healthcare;
train, using training data comprising one or more images of one or more credentials with labeled expiration dates, one or more computer-implemented models executed by an artificial intelligence engine to use object character recognition (OCR) to identify one or more information from the one or more images of the one or more credentials;
input the image of the credential into the one or more computer- implemented models that are trained to use OCR to identify and extract information from the image of the credential, extracting information from the image of the credential, wherein the information comprises an expiration date of the credential;
store the image of the credential and the expiration date of the credential in a data store;
validating the credential issued to the clinician by communicating with an application programming interface of an issuing agency that issued the credential to the clinician
receive, from the computing device of the clinician, a selection to join a home health agency; and
transmit, to a computing device of the home health agency, a notification pertaining to the credential provided by the clinician, wherein the notification indicates whether the credential is active based on the expiration date
The identified limitations, using their broadest reasonable interpretation, cover performance of the limitations in the mind but for the recitation of generic computer components. That is, other than reciting a processor, memory, computing devices, application programming interface, computer-implemented models, and data store, nothing in the claim elements precludes the steps from being performed practically in the mind. For example, the steps encompass a person reviewing healthcare credentials for validity to qualify the healthcare professional for home healthcare. The claims cover observation, evaluation, judgement and opinion and fall within the Mental Processes groupings of abstract ideas. Thus, the claimed invention recites a judicial exception.
Part I: Step 2A, prong two: additional elements that integrate the judicial exception into a practical application
Under step 2A, Prong Two of the Alice framework, the claims are analyzed to determine whether the claims recite additional elements that integrate the judicial exception into a practical application. In particular, the claims are evaluated to determine if there are additional elements or a combination of elements that apply, rely on, or use the judicial exception in a manner that imposes a meaningful limit on the judicial exception, such that the claims are more than a drafting effort designed to monopolize the judicial exception.
As a whole, the additional elements recite storing data into memory. The processor, memory, computing devices, application programming interface, computer-implemented models, and data store in the steps are recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using a generic computer component. The claims recite conventional computer-implemented models without specific improvements to the technology itself. Additionally, applying machine learning to validating and qualifying credentials does not transform the abstract idea into a patent-eligible invention. Simply applying generic machine learning techniques to credential validation, without improving the underlying technology, is insufficient for patent eligibility. Accordingly, this additional element does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. The claim is directed to an abstract idea.
Dependent claims 3, 4, 6-10, 13, 14, and 16-18, when analyzed as a whole are held to be patent ineligible under 35 U.S.C. 101 because the additional recited limitations fail to establish that the claims are not directed to an abstract idea:
Claims 3 and 13 The computer-implemented method of claim 1, wherein extracting the information further comprises: inputting the image of the credential into a machine learning model trained to extract the expiration date from the image of the credential.
Claims 4 and 14 The computer-implemented method of claim 1, further comprising: receiving, from the computing device of the clinician, a second image of a second credential issued to the clinician, wherein the second credential pertains to healthcare; extracting second information from the second image of the second credential, wherein the second information comprises an expiration date of the second credential; storing the second image of the second credential and the expiration date of the second credential in the database; and transmitting, to the home health agency, a second notification pertaining to the second credential provided by the clinician, wherein the second notification indicates whether the second credential is active based on the expiration date of the second credential.
Claims 6 and 16 The computer-implemented method of claim 1, further comprising: determining the expiration date of the credential is going to expire within a certain period of time; and transmitting a notification to the computing device of the clinician, wherein the notification instructs the clinician to provide an updated credential before the certain period of time elapses.
Claims 7 and 17 The computer-implemented method of claim 6, further comprising: receiving, from the computing device of the clinician, the updated credential having a new expiration date; and transmitting, to the computing device of the home health agency, a notification pertaining to the updated credential having the new expiration date.
Claims 8 and 18 The computer-implemented method of claim 1, further comprising: determining, based on the expiration date, that the credential expired; and preventing the clinician from being considered for staffing to a patient referral.
Claim 9 The computer-implemented method of claim 1, further comprising: receiving, from the computing device of the clinician, an indication of a type of the credential; determining whether a requirement for the type of the credential is satisfied, wherein the requirement comprises a background check of the clinician, a drug screen of the clinician, or both; and responsive to determining that the requirement is not satisfied, preventing the clinician from being considered for staffing to a patient referral.
Claim 10. The computer-implemented method of claim 1, wherein the notification comprises the image of the credential.
Since these claims are directed to an abstract idea, the Office must determine whether the remaining limitations “do significantly more” than describe the abstract idea.
Part II. Determine whether any Element, or Combination, Amounts to“Significantly More” than the Abstract Idea itself
Under Part II, the steps of the claims, when considered individually and as an ordered combination, do not improve another technology or technical field, do not improve the functioning of the computer itself, and are not enough to qualify as "significantly more". For example, the steps require no more than a conventional computer to perform generic computer functions. As stated above in Prong Two, the processor, memory, computing devices, application programming interface, computer-implemented models, and data store in the steps are recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using a generic computer component. Therefore, based on the two-part Mayo analysis, there are no meaningful limitations in the claim that transform the exception into a patent eligible application such that the claim amounts to significantly more than the exception itself. Claims 1, 3, 4, 6-11, 13, 14, and 16-19, when considered individually and as an ordered combination, are rejected as ineligible subject matter under 35 U.S.C. 101.
Dependent claims 3, 4, 6-10, 13, 14, and 16-18 when analyzed as a whole are held to be patent ineligible under 35 U.S.C. 101 because the additional claims do no recite significantly more than an abstract idea.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Haddad et al. (US 2017/0223001 A1), Electronic credentials management
Geller et al. (US 8,620,676 B2), Electronic credentials verification and management system
The aforementioned prior art references generally describe electronic credential management for healthcare providers. However, the references do not teach or suggest extracting expiration date of the credential using OCR, joining a home healthcare agency based on the recognition, and transmitting a notification indicating the credential is active as recited in claims 1, 11, and 19. Additionally, the references do not teach or suggest machine learning models as recited in claims 3, 13, and 20.
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/CHINYERE MPAMUGO/Primary Examiner, Art Unit 3685