DETAILED ACTION
This communication is in response to the amendment filed 3/16/26 in which claims 21, 26, 27, 29, 30, 38 were amended, and claims 25 and 34 were canceled. Claims 21-24, 26-33, and 35-42 are pending.
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Response to Arguments
Applicant argues:
Zhang discloses a system for automated compliance checking. The explicit purpose of Zhang's system is to extract structured rules from existing regulatory documents to "formalize them in a computer-processable rule representation" (Zhang, Abstract). The output of Zhang's analysis is a set of extracted rules or a determination of compliance. The process described in Zhang ends there; it does not teach or suggest a subsequent step or a separate engine for taking that analysis and using it to recommend new textual prose for a living document.
The present invention teaches a two-stage process performed by two distinct engines. First, an analysis engine determines the impact of triggers. Second, a policy knowledge engine (PKE) takes the "output of said analysis engine" and performs the novel function "to recommend changes to section text content". The functionality of the PKE is described in paragraphs 235-40 240 and 242 of the Specification.
The prior art combination, including Zhang, provides no teaching or motivation for this second step. A person of ordinary skill, in seeking to automate compliance checking as taught by Zhang, would have no reason to build an additional engine whose purpose is to suggest prose updates to a human designer.
The other references do not cure this deficiency. Newman, Frankland, Dick, and Kobayashi do not teach or suggest a PKE that acts on the output of an analysis engine to recommend changes to the text content of a living document. The proposed combination would result in a system that merely identifies a regulatory change (per Frankland) and perhaps extracts the rule (per Zhang), but it would not teach or suggest the critical step of generating a recommendation for new text content for a designer to implement in a living document such as a website policy.
In view of the foregoing amendments and remarks, the pending claims are deemed to be allowable. Their favorable reconsideration and allowance is respectfully requested.
Applicant’s arguments with respect to claim 21 have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. Examiner respectfully directs Applicant’s attention to the rejection below for more details on Newman is remapped in combination with a new reference to Larson to teach the alleged deficiency.
Claim Rejections - 35 USC § 103
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
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.
The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
1. Determining the scope and contents of the prior art.
2. Ascertaining the differences between the prior art and the claims at issue.
3. Resolving the level of ordinary skill in the pertinent art.
4. Considering objective evidence present in the application indicating obviousness or non-obviousness.
Claims 21-28 and 30-37 are rejected under 35 U.S.C. 103 as being unpatentable over Newman (US 2006/0282396 A1; published Dec. 14, 2006) in view of Dick (US 2013/0246291 A1; published Sep. 19, 2013), Frankland (US 2017/0083346 A1; published Mar. 23, 2017), Zhang, Jiansong, and Nora M. El-Gohary. "Semantic NLP-based information extraction from construction regulatory documents for automated compliance checking." Journal of computing in civil engineering 30.2 (2016): 04015014 (“Zhang”), Larson (US 2018/0189517 A1; published Jul 5, 2018), and Kobayashi (US 2001/0027463 A1; published Oct. 4, 2001).
Regarding claim 21, Newman discloses [a] website building system (WBS) hosting multiple websites used by designers to create websites, said WBS comprising:
at least one processor; and (¶ 18)
a living document generator (LDG) running on said at least one processor to generate a living document (see ¶ 25 (Upon completion of the questionnaire, a document reflecting appropriate language in response to the user’s answers may then be downloaded for the automatic fabrication of a custom-made document with parameters tailored to the facts and circumstances, and intent, of the user(s), and which is also jurisdiction specific.)) for a designer using said WBS to build at least one website (this limitation recites an intended use of the claimed living document generator. An intended use does not differentiate a claimed invention from the prior art. See MPEP 2114(II)).
Newman does not particularly disclose said living document stating at least one policy for said at least one website1, and having at least one tag having metadata (but see Dick Abstract (teaching a compliance computer that creates compliance documents referencing one or more rules with which an entity must comply and/or a jurisdiction and topic related to rules with which the company must comply), ¶ 34 (describing how once the compliance document search module identifies one or more key terms or phrases in the initial compliance documents, the compliance document tagging module operates to create tags or metadata (“at least one tag”) identifying the rules, jurisdictions, topics, and/or key terms or phrases in the initial compliance documents); the compliance document tagging module may also create tags or metadata identifying the section or sections of the initial compliance documents that reference the rules, jurisdictions, topics, and/or key terms or phrases)).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Newman to incorporate the teachings of Dick to use tags and metadata in the contract document being generated to reference relevant jurisdictions, topics, and/or specific rules, at least because doing so would assist an entity in complying with rules promulgated by regulatory authorities. See Dick ¶ 4.
Newman further discloses wherein a version of said living document is displayed to an end-user of said at least one website according to said metadata, (¶ 9 (“As may be ascertained, there exist yet many opportunities for innovative methods and systems to fully exploit the Internet venue in offering and vending services and products, and especially those of an interactive nature where products with attendant services may be purchased and/or actually constructed and then stored by way of a web site for later retrieval and use. To this end there has not been provided an automated way of composing contracts, agreements, wills and other legal documents by way of e-commerce, such as by a user in virtually any geographic location being provided a menu as a starting point for document construction, and in which such documents of a legal nature may be tailored to be jurisdictional specific or for use in specified factual contexts.”), ¶ 19 (“Further, the system includes an interactive question and user response means of which a user is confronted with and prompted to respond to determine and display an appropriate incomplete construct or template reflecting jurisdiction specific language as appropriate, and optionally, a modeller means for storing descriptions for a formal contract model, or for storing a preformatted or partially constructed model (a “construct” or “template”), and a tool means for enabling the contract or agreement to be formatted and displayed as desired, or optionally according to the preformatted model. The modeller means may make layout models for documents, such as a contract or agreement, available through the repository and a tool which enables a document to be formatted according to the layout model displayed, all of which are made available to users of the e-commerce repository.”)).
Although Newman teaches that the annotation feature accessible by a user contemplating a particular document displays a summary of the local law applicable to the nature of the document and the facts and circumstances of the user, Newman does not expressly disclose said LDG comprising: a monitoring engine running on said at least one processor to monitor internal and external data sources to said WBS to identify potential triggers for updates to said living document (but see Frankland ¶ 38 (“The system operates at four layers, as illustrated in FIG. 1: (1) a change management layer 11 that includes one or more change agents that “cruise the Web” and identify and bring to the user's attention relevant regulatory and non-regulatory changes found on the Web that may affect a user's business…”)).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Newman to incorporate the teachings of Frankland to identify and bring to the user’s attention relevant regulatory and non-regulatory changes found on the Web that may affect a user’s business, at least because doing so would enable cost-effective monitoring of changes instead of maintaining an internal database as current. See Frankland ¶ 28.
Newman does not expressly disclose an analysis engine running on said at least one processor to determine an impact of said potential triggers on said living document by utilizing at least one of: a rule engine, a natural language processing (NLP) engine, or a machine learning (ML) engine to correlate said potential triggers with at least said metadata of said at least one tag (but see Zhang pg. 5 Rule-Based Approach (“Our approach is rule-based. There are two main types of approaches taken in NLP: rule-based approach, and machine learning (ML)-based approach. Rule-based NLP uses manually-coded rules for text processing. These rules are iteratively-constructed and refined to improve the accuracy of text processing. ML-based NLP uses ML algorithms for training text processing models based on the text features of a given training text (Tierney 2012). Rule-based NLP tends to show better text processing performance (in terms of precision and recall), but requires more human effort. We are taking a rule-based approach, because of its expected higher performance. We are using IE rules that rely on pattern matching to identify the part(s) of text to extract based on recognized text patterns. Our approach relies on, both, the semantic and syntactic features of the text in defining these patterns. We capture the syntactic features (e.g. part of speech (POS) tags) of the text using various NLP techniques, including tokenization, sentence splitting, morphological analysis, POS tagging, and phrase structure analysis. We capture the semantic features (concepts and relations) of the text based on an ontology that represents the domain knowledge.”); Zhang pg. 28 (“Fourth, and most importantly, this study is the first in the AEC domain that addresses automated IE using a semantically-deep NLP approach. It offers baseline semantic IE methods/algorithms for extracting information from textual construction documents. Future research could use these methods/algorithms as a benchmark and build on this work by adapting the developed algorithms to extract information from other types of documents (e.g. contract documents) or for different purposes (e.g. contract analysis)…. The impact of applying this work in the AEC domain could be far-reaching. First, this work brings automated construction regulatory compliance checking one step closer to reality. Automated regulatory compliance checking would reduce the time, cost, and error of the checking process. This could speed up the regulatory process, enhance cost and time project efficiency, and lead to less violation of regulations. Second, the application of this work could be extended to support automated information extraction and analysis for many other applications and purposes, such as analysis of contract documents for the detection of inconsistencies, analysis of project documents and records for supporting claim analysis, analysis of daily site reports for supporting progress monitoring and project control, etc.”)).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Newman to incorporate the teachings of Zhang to use rule-based NLP to extract compliance requirements from legal codes and use it to automate regulatory compliance checking of a document (e.g., a contract), at least because doing so would reduce the time, cost, and error of the checking process.
Although Newman teaches an annotation feature which displays a summary of the local law applicable to the nature of the document and the facts and circumstances of the user, and which is updated as required to reflect changes in the law, see ¶ 26, Newman does not expressly disclose a policy knowledge engine running on said at least one processor to recommend changes to section text content of said living document based on the output of said analysis engine; (but see Larson ¶ 5 (“Embodiments are directed to intelligence and analysis driven security and compliance suggestions. A security and compliance module associated with a hosted service may be configured to analyze a tenant's environment, such as numbers and types of users, employed service components, processed and stored documents, and data. Based on the analysis, the security and compliance module may suggest a policy or a configuration change to be implemented based on the analysis, which may be presented to the tenant through a dashboard. The suggested policy or configuration may encompass regulatory, legal, industrial, internal compliance, external compliance, and other security and compliance rules or standards employed to protect the tenant, for example. The suggested policy or configuration may be presented along with the analysis results and a prompt to confirm implementation of the suggested policy or configuration. Upon receiving a confirmation of the implementation of the suggested policy or configuration, an option may be presented to customize the suggested policy or configuration by modifying the settings suggested based on analysis results.”)).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Newman to incorporate the teachings of Larson to analyze the document and provide suggested policy or configuration changes to be implemented based on the analysis, at least because doing so would enable protecting the user by ensuring compliance with regulatory, legal, industrial, and other security and compliance rules or standards.
Newman further discloses a notification engine running on said at least one processor to notify said designer of said updates (¶ 27 (User alerts are also contemplated by the invention to alert a user, such as by email, to recent changes in a legal environment in a specific jurisdiction.)).
Newman does not expressly disclose to notify said designer of said updates, recommend said changes and to provide timeline and urgency levels for delivery (but see Kobayashi ¶ 50 (teaching a document information describing the contents of task information, determining a process deadline for a task indicated by the document information and corresponding to a given keyword, plan information, and so on); the keyword is a given word included in document information, e.g., a word that explicitly or implicitly indicates a process deadline for the involved task); the word that explicitly indicates the process deadline is a word or phrase that describes a specific deadline such as “by” or “before the end of the week”; the word that implicitly specifies the process deadline is a word or phrase that abstractly represents a deadline such as “urgent” or “rush”), ¶ 75, fig. 5 (further teaches displaying task information to a user, the task information including the remaining term for the task and an icon indicating whether the task is overdue and indicated with the appropriate font to indicate severity)).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Newman to incorporate the teachings of Kobayashi to provide a deadline and an indication of whether the updates are overdue, at least because doing so would enable more efficient conveyance of task information to end users. See Kobayashi ¶ 10.
Newman does not expressly disclose a workflow engine running on said at least one processor to implement both designer and system generated updates to said living document accordingly (but see Dick ¶ 26 (“The present invention also optionally provides an annotation feature accessible by a user contemplating a particular document which displays a summary of the local law applicable to the nature of the document and the facts and circumstances of the user, and which is updated as required to reflect changes in the law. This feature, which may be made available, for example, in a drop down menu when a user is contemplating a document specific to a certain jurisdiction, is particularly useful as a consultation database by those contemplating a relocation to other jurisdictions, or perhaps for those doing business in various jurisdictions or have entered into some form of a contract or agreement in one or more jurisdictions.”)).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Newman to incorporate the teachings of Dick to use tags and metadata in the contract document being generated to reference relevant jurisdictions, topics, and/or specific rules, at least because doing so would assist an entity in complying with rules promulgated by regulatory authorities. See Dick ¶ 4.
Claim 30 is a method claim corresponding to claim 21 and is similarly rejected.
Regarding claim 22, Newman, in view of Dick, Frankland, Zhang, Larson, and Kobayashi, discloses the invention of claim 21 as discussed above. Newman does not expressly disclose wherein said at least one tag is one of tags list type of section, geography to which it relates, type of law, type of document, its associated legal code, and/or its legal source. However, Dick teaches a compliance computer that creates compliance documents referencing one or more rules with which an entity must comply and/or a jurisdiction and topic related to rules with which the company must comply. Dick Abstract. Once the compliance document search module identifies one or more key terms or phrases in the initial compliance documents, the compliance document tagging module operates to create tags or metadata identifying the rules, jurisdictions, topics, and/or key terms or phrases in the initial compliance documents. Dick ¶ 34. The compliance document tagging module may also create tags or metadata identifying the section or sections of the initial compliance documents that reference the rules, jurisdictions, topics, and/or key terms or phrases. Dick ¶ 34.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Newman to incorporate the teachings of Dick to use tags and metadata in the contract document being generated to reference relevant jurisdictions, topics, and/or specific rules, at least because doing so would assist an entity in complying with rules promulgated by regulatory authorities. See Dick ¶ 4.
Claim 31 is a method claim corresponding to claim 22 and is similarly rejected.
Regarding claim 23, Newman, in view of Dick, Frankland, Zhang, Larson, and Kobayashi, discloses the invention of claim 21 as discussed above. Newman does not expressly disclose wherein said LDG comprises a tagger to associate said at least one tag to said at least one section. However, Dick teaches a compliance computer that creates compliance documents referencing one or more rules with which an entity must comply and/or a jurisdiction and topic related to rules with which the company must comply. Dick Abstract. Once the compliance document search module identifies one or more key terms or phrases in the initial compliance documents, the compliance document tagging module operates to create tags or metadata identifying the rules, jurisdictions, topics, and/or key terms or phrases in the initial compliance documents. Dick ¶ 34. The compliance document tagging module may also create tags or metadata identifying the section or sections of the initial compliance documents that reference the rules, jurisdictions, topics, and/or key terms or phrases. Dick ¶ 34.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Newman to incorporate the teachings of Dick to use tags and metadata in the contract document being generated to reference relevant jurisdictions, topics, and/or specific rules, at least because doing so would assist an entity in complying with rules promulgated by regulatory authorities. See Dick ¶ 4.
Claim 32 is a method claim corresponding to claim 23 and is similarly rejected.
Regarding claim 24, Newman, in view of Dick, Frankland, Zhang, Larson, and Kobayashi, discloses the invention of claim 21 as discussed above. Although Newman teaches a database to store the documents, Newman does not expressly disclose and comprising at least one database running on said at least one processor to store said living document said at least one tag. However, Dick teaches a compliance computer that creates compliance documents referencing one or more rules with which an entity must comply and/or a jurisdiction and topic related to rules with which the company must comply. Dick Abstract. Once the compliance document search module identifies one or more key terms or phrases in the initial compliance documents, the compliance document tagging module operates to create tags or metadata identifying the rules, jurisdictions, topics, and/or key terms or phrases in the initial compliance documents. Dick ¶ 34. The compliance document tagging module may also create tags or metadata identifying the section or sections of the initial compliance documents that reference the rules, jurisdictions, topics, and/or key terms or phrases. Dick ¶ 34. An incorporate module then operates to compile the tags or metadata into a separate computer object. Dick ¶ 34.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Newman to incorporate the teachings of Dick to use tags and metadata in the contract document being generated to reference relevant jurisdictions, topics, and/or specific rules, at least because doing so would assist an entity in complying with rules promulgated by regulatory authorities. See Dick ¶ 4.
Claim 33 is a method claim corresponding to claim 24 and is similarly rejected.
Regarding claim 26, Newman, in view of Dick, Frankland, Zhang, Larson, and Kobayashi, discloses the invention of claim 21 as discussed above. Newman does not expressly disclose wherein said policy knowledge engine updates said at least one tag according to said changes to section text content. However, Dick further teaches that after the incorporation module has complied the tags or metadata, a review module presents tags or metadata to the compliance officer who can edit the existing tags or metadata. Dick ¶ 34. Newman further teaches that the compliance document update module propagates the changes made to a particular section of the compliance documents to other sections of the compliance documents. Dick ¶ 51. For example, the compliance officer may use the notification to update a rule in a particular section of the compliance manual. Dick ¶ 51.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Newman to incorporate the teachings of Dick to update the compliance document in response to changes to a particular section of the compliance document, at least because doing so would keep the document current with rules and regulations.
Claim 35 is a method claim corresponding to claim 26 and is similarly rejected.
Regarding claim 27, Newman, in view of Dick, Frankland, Zhang, Larson, and Kobayashi, discloses the invention of claim 21 as discussed above. Newman further discloses wherein said analysis engine (because the analysis engine is a part of the LDG, it is also interpreted as software executed by the processor) analyzes internal data sources of said WBS and at least one of: external online and offline data sources to determine WBS information and business operational information relevant to said living document (see ¶ 21 (A contract for the sale of goods tailored to comport to a state’s specific form of Uniform Commercial Code provisions is contemplated.)).
Claim 36 is a method claim corresponding to claim 27 and is similarly rejected.
Regarding claim 28, Newman, in view of Dick, Frankland, Zhang, Larson, and Kobayashi, discloses the invention of claim 27 as discussed above. Newman further discloses wherein said at least one of: external online and offline data sources comprise at least one of: law and regulation online and offline repositories (see ¶ 21 (A contract for the sale of goods tailored to comport to a state’s specific form of Uniform Commercial Code provisions is contemplated.)).
Claim 37 is a method claim corresponding to claim 28 and is similarly rejected.
Regarding claim 39, Newman, in view of Dick, Frankland, Zhang, Larson, and Kobayashi, discloses the invention of claim 27 as discussed above. Newman does not disclose wherein said business operational data comprises at least one of: revenue levels, product portfolio, staffing levels and other data. However, Frankland teaches a system that (1) provides one or more databases that contain information on operations and requirements concerning an activity or area of business; (2) monitors and evaluates the relevance of information on regulatory and non-regulatory changes that affect operations of the business and/or information management requirements; (3) converts the relevant changes into changes in work/task lists, data entry forms, reports, data processing, analysis and presentation (by printing, electronic display, network distribution and/or physical distribution) of data processing and analysis results to selected recipients. Frankland ¶ 35.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Newman to incorporate the teachings of Frankland to monitor the business or information management requirements of an organization, at least because doing so would enable responding to regulatory changes affecting business operations.
Claim 40 is a method claim corresponding to claim 39 and is similarly rejected.
Regarding claim 41, Newman, in view of Dick, Frankland, Zhang, Larson, and Kobayashi, discloses the invention of claim 21 as discussed above. Although Newman teaches that the annotation feature displays a summary of the local law applicable to the nature of the document and facts and circumstances of the user, see ¶ 26, Newman does not expressly disclose wherein said internal data comprises at least one of: WBS designer information, website components of websites built by said designer and other designers of said WBS, business information related to websites and operational information of said websites (but see Koren ¶ 324 (“Machine learner/AI 424 may use artificial intelligence/machine learning) to provide an evolving and continuously improving interaction with site designer 62 based on the above mentioned crowd-sourced information. Such collected information reflects the actual use of system 100, the actual priorities set by site designer 62, and the actual use of preferences (as related to content, presentation, aesthetics or other aspects of the system) by the user community.”)).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Newman to incorporate the teachings of Koren to generate a site based on the integration and analysis of information from multiple sources including information entered by the user, information pre-specified within the system and information retrieved from external sources, etc., at least because doing so would “allow for the rapid generation and maintenance of websites while minimizing or eliminating the required manual editing although it may allow some editing where necessary via a (possibly adapted) visual editor.” Koren ¶ 96.
Claim 42 is directed to a method corresponding to claim 41 and, therefore, is similarly rejected.
Claims 29 and 38 are rejected under 35 U.S.C. 103 as being unpatentable over Newman, Dick, Frankland, Zhang, Larson, and Kobayashi as applied to claims 27 and 36 above, and further in view of Miller (US 2014/0025608 A1; published Jan. 23, 2014).
Regarding claim 29, Newman, in view of Dick, Frankland, Zhang, Larson, and Kobayashi, discloses the invention of claim 27 as discussed above. Although Newman teaches annotating documents with jurisdiction specific information, Newman does not particularly disclose wherein said policy knowledge engine comprises a machine learning engine (because the machine learning engine is a part of the analysis engine which is in turn a part of the LDG, it is also interpreted as software executed by the processor) to generate said section text content according to said analysis. However, Miller teaches the probabilistic prediction of customary legal documents and optional clauses using a combination of expert provided rules, user input and supervised machine learning. Miller ¶ 27.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Newman to incorporate the teachings of Miller to generate document clauses based on the jurisdiction specific information using machine learning, at least because doing so would alert the parties to the possible applicability of important legal documents and clauses that are not commonly used and thus might otherwise by overlooked. See Miller ¶ 27.
Claim 38 is a method claim corresponding to claim 29 and is similarly rejected.
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.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to SHAHID KHAN whose telephone number is (571)270-0419. The examiner can normally be reached M-F, 9-5 est.
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/SHAHID K KHAN/Primary Examiner, Art Unit 2146
1 The limitation “for said website” recites an intended use of the claimed policy. However, “[T]he patentability of apparatus or composition claims depends on the claimed structure, not on the use or purpose of that structure.” Catalina Mktg. Int’l, Inc. v. Coolsavings.com, Inc., 289 F.3d 801, 809 (Fed. Cir. 2002).
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