DETAILED ACTION
Notice of Pre-AIA or AIA Status
1. The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
2, The amendment filed on 03/27/2026 has been received and fully considered.
3. Claims 1-20 are presented for examination.
Response to Arguments
4. Applicant's arguments filed 03/27/2026 have been fully considered but they are not persuasive. The rejection under 35 USC 112 has been withdrawn. Regarding applicant’s assertions that: “Under step 2A, Prong One: Applicant respectfully submits that the claims are not directed to mental process but instead are directed toward patent eligible subject matter. And under Step 2A Prong Two: Applicant's position is that the independent claims are integrated into a practical application under Step 2A, Prong Two because, as a whole, they provide a specific improvement to computer-aided design (CAD) technology for sheet metal part design”; and that: This is a concrete improvement to CAD technology and its user interaction model: it changes how the CAD system operates to produce correct sheet metal feature topology with substantially less user effort and fewer opportunities for user error, rather than merely implementing an abstract idea on a generic computer. Accordingly, even if any portion of the claim is characterized as reciting an abstract idea, the claim as a whole integrates any such concept into a practical application by improving a technical field (CAD sheet metal design) and by producing a specific, tangible design output used by CAD/manufacturing workflows. Applicant therefore respectfully submits that Step 2A, Prong Two is satisfied. Step 2B: Applicant respectfully submits that the claims, when considered as a whole, recite additional elements that amount to significantly more than a judicial exception”, the Examiner respectfully disagrees and asserts that the claims, as currently constructed, are clearly directed to an abstract. The Examiner further notes that the claims do not recite anything that is sufficient to amount to significantly more than the abstract idea or integrate the recited abstract to a practical application. It is further noted by the examiner that merely adding a programmable computer to perform generic computer functions does not automatically overcome an eligibility rejection. Alice, 573 U.S. at 223-24. Furthermore, the use of a general-purpose computer to apply an otherwise ineligible algorithm does not qualify as a particular machine. See Ultramerciallnc. v. Hulu, LLC, 772F.3d 709, 716-17 (Fed. Cir. 20l4); In re TLI Commc 'ns LLC v. AV Automotive, LLC, 823 F.3d 607, 613 (Fed. Cir. 2016) (mere recitation of concrete or tangible components is not an inventive concept); Eon Corp. IP Holdings LLC v. AT&T Mobility LLC, 785; and that to transform an abstract idea, law of nature or natural phenomenon into "a patent-eligible application", the claim must recite more than simply the judicial exception "while adding the words 'apply it.'" Mayo, 132 S. Ct. at 1294, 101 USPQ2d at 1965. Therefore, the claims are abstract, as currently presented, contrary to applicant’s assertions.
Claim Rejections - 35 USC § 101
5. 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.
5.1 Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Step 2A- Prong One
The claim(s) recite(s) a computer-implemented method for designing a sheet metal part, comprising: The step of: “automatically generating a digital representation of a sheet metal part by: “constructing a first face adjacency graph comprising graph vertices and graph edges, wherein a graph vertex of the first face adjacency graph corresponds to a flange of the shell or a group of flanges user-constrained to be interconnected, wherein a graph edge of the first face adjacency graph connects two graph vertices if the flanges of the shell corresponding to the two graph vertices share an edge, a shared edge being either a candidate miter if the flanges of the shell corresponding to the two graph vertices are coplanar or a candidate bend otherwise”; “marking a candidate miter as a connected feature if the candidate miter is represented in the first spanning tree or bounds only one flange, a candidate miter bounding only one flange corresponding to an unnecessary cut in the sheet metal part that can be removed”; “constructing a second face adjacency graph comprising graph vertices and graph edges, wherein a graph vertex of the second face adjacency graph corresponds to a flange of the shell or a group of flanges linked via shared edges marked as connected features, wherein a graph edge of the second face adjacency graph connects two graph vertices if corresponding flanges of the shell share a candidate bend”; under the broadest reasonable interpretation, these steps fall under a mental process or otherwise could be performed using a pen and paper; and the steps of “computing a first spanning tree for the first face adjacency graph; “computing a second spanning tree for the second face adjacency graph”; under the broadest reasonable interpretation fall under a mathematical concept/relationship. Likewise, the further limitations of: “wherein: the sheet metal part includes flanges, bend features corresponding to the graph edges of the second spanning tree, junction features corresponding to the graph edges of the second face adjacency graph absent in the second spanning tree, connected features, and miter features corresponding to unmarked candidate miters”, and the sheet metal part hence includes flanges, bend features corresponding to candidate bends represented in the second spanning tree, junction features corresponding to candidate bends which do not correspond to bend features, connected features, and miter features corresponding to candidate miters which do not correspond to connected features”; under the broadest reasonable interpretation fall under a mental process. Therefore, the claims are directed to an abstract idea, by use of generic computer components and thus are clearly directed to an abstract idea, as constructed.
Step 2A Prong Two
This judicial exception is not integrated into a practical application because the additional limitation such as: “computer system”, “computer-processable instructions”, “a computer” (claims 19-20), either alone or in combination, all serve to gather and process data and do not add anything more significantly to the judicial exception, but are mere instructions to apply the exception using a generic computer component that are well known, routine, and conventional activities (see specification at page 4) previously known in the industries. Merely adding a programmable computer to perform generic computer functions does not automatically overcome an eligibility rejection. Alice, 573 U.S. at 223-24. Furthermore, the use of a general-purpose computer to apply an otherwise ineligible algorithm does not qualify as a particular machine. See Ultramerciallnc. v. Hulu, LLC, 772F.3d 709, 716-17 (Fed. Cir. 20l4); In re TLI Commc 'ns LLC v. AV Automotive, LLC, 823 F.3d 607, 613 (Fed. Cir. 2016) (mere recitation of concrete or tangible components is not an inventive concept); Eon Corp. IP Holdings LLC v. AT&T Mobility LLC, 785; the step of: “receiving zero, one, two or more feature changes of the sheet metal part via the graphical user interface”; and “receiving user acceptance of the displayed sheet metal part”, under the broadest reasonable interpretation, reasonable fall under data gathering and processing activities that are pre-solution activities” and the further step of: “automatically displaying the sheet metal part in the graphical user interface”, and “updating the displayed part correspondingly” could amount to post-solution activities that are also well-known, routine and conventional activities and are not sufficient to amount to significantly more than the judicial exception (See further MPEP 2106.05(d)(i-iv)-f); thus are not patent eligible under 35 USC 101.
Step 2B
The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, as previously discussed above with reference to the integration of abstract idea into a practical application, the additional elements of: “computer system”, “computer-processable instructions”, “a computer”, either alone or in combination, all serve to gather and process data and do not add anything more significantly to the judicial exception, but are mere instructions to apply the exception using a generic computer component that are well known, routine, and conventional activities (see specification at page 4) previously known in the industries. Merely adding a programmable computer to perform generic computer functions does not automatically overcome an eligibility rejection. Alice, 573 U.S. at 223-24. Furthermore, the use of a general-purpose computer to apply an otherwise ineligible algorithm does not qualify as a particular machine. See Ultramerciallnc. v. Hulu, LLC, 772F.3d 709, 716-17 (Fed. Cir. 20l4); In re TLI Commc 'ns LLC v. AV Automotive, LLC, 823 F.3d 607, 613 (Fed. Cir. 2016) (mere recitation of concrete or tangible components is not an inventive concept); Eon Corp. IP Holdings LLC v. AT&T Mobility LLC, 785; the step of: “receiving zero, one, two or more feature changes of the sheet metal part via the graphical user interface”; and “receiving user acceptance of the displayed sheet metal part”, under the broadest reasonable interpretation, reasonable fall under data gathering and processing activities that are pre-solution activities” and the further step of: “automatically displaying the sheet metal part in the graphical user interface”, and “updating the displayed part correspondingly” could amount to post-solution activities that are also well-known, routine and conventional activities and are not sufficient to amount to significantly more than the judicial exception (See further MPEP 2106.05(d)(i-iv)-f); thus are not patent eligible under 35 USC 101. Therefore, using computer components amount to no more than mere instructions to perform the abstract, and thus are not sufficient to amount to significantly more than the recited abstract, as constructed.
5.2 Dependent claims 2-18 merely include limitations pertaining to: (claim 2), “wherein said step of receiving zero, one, two or more feature changes of the part and updating the displayed part includes zero, one, two or more iterations of: ”receiving via the graphical user interface a change of a junction feature to a bend feature, a bend feature to a junction feature, a miter feature to a connected feature, or a connected feature to a miter feature, wherein the change defines a new user constraint” (data gathering and processing); “automatically generating a new sheet metal part by computing new first and second spanning trees subject to the new user constraint and user constraints of previous iterations; and automatically updating in the graphical user interface the displayed part to the new part” (mathematical concept and/or otherwise a mental process);. (claims 3 and 11); “automatically verifying whether the new sheet metal part is unfoldable” (mental process); (claims 4 and 16); “receiving a user selection of an edge weight function from a list of multiple edge weight functions, wherein: each of the first face adjacency graph and the second adjacency graph and the second face adjacency graph is a weighted face adjacency graph, each graph edge includes a weight defined by the selected edge weight function, and the computation of the spanning trees targets minimal edge weight sum” (data gathering and processing); (claim 5); “wherein: the first and second spanning trees subject to the user constraints are based on new face adjacency graphs, and a graph vertex corresponds to a group of flanges linked via shared edges which are constrained to be bend features, constrained to be connected features and/or marked as connected features” (mental process); (claim 6) “wherein: the new spanning trees subject to the user constraints are based on new face adjacency graphs, and a new face adjacency graph does not comprise a graph edge for a shared edge which is constrained to be a junction feature or constrained to be a miter feature” (mental process); (claims 7 and 10); “automatically indicating in the graphical user interface two or more features of the new sheet metal part subject to incompatible user constraints” (mental process), (claim 8), “wherein: the new first and second spanning trees subject to the user constraints are based on new face adjacency graphs, and a new face adjacency graph does not comprise a graph edge for a shared edge which is constrained to be a junction feature or constrained to be a miter feature” (a mental process);. (claim 9); “wherein receiving a feature change of the sheet metal part in the graphical user interface is performed via cursor selection at or near the displayed feature of the sheet metal part, the sursor selection being the cursor selection of the displayed feature or cursor selection of a callout or widget associated with the displayed feature” (data gathering and processing or otherwise a mental process); (claim 12); “wherein: in the graphical user interface both the sheet metal part and a corresponding preform are displayed, wherein the preform is an unfolded version of the sheet metal part, and a change of a bend feature to a junction feature or a change of a connected feature to a miter feature can be indicated at or near a corresponding displayed feature of the preform” (WURC post-solution activities); (claim 13) “wherein: each of first adjacency graph and the second adjacency graph is a weighted face adjacency graph, each graph edge comprises a weight defined by a strictly monotone function of a length of a corresponding shared edge, and the computation of the spanning trees targets minimal or maximal edge weight sum” (mental process); (claim 14); “wherein a weight of a graph edge is defined by a strictly decreasing linear function of a shared edge length and minimal edge weight sum is targeted” (mathematical concept or otherwise a mental process), (claims 15 and 17); “wherein a spanning tree for each of first adjacency graph and the second adjacency graph is computed via Kruskal's spanning tree algorithm or Prim's spanning tree algorithm” (mathematical concept); (claim 18) “wherein the step of obtaining the shell comprises the steps of: obtaining a solid comprising faces, wherein: a face includes zero, one or more contours, and a face includes zero, one or more lines with endpoints on edges of the face; and automatically generating the sheet metal shell from the solid, by converting a face to a flange, extruding a hole in a flange for each contour, and introducing a candidate miter in a flange for each line” (data gathering and processing or otherwise a mental process);. all of which further amount to further data gathering and processing, mathematical concept and/or mental process similar to that already recited by the independent claims and already addressed above and thus are further not patent eligible under 35 USC 101.
5.3 Claims 19 rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter. The claims recite a computer system (claim 19); however, the claim is directed to or can be interpreted as a program/software per se and therefore are not statutory.
Conclusion
6. The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
6.1 Joshi et al. (USPG_PUB No. 2013/0127848) teaches a system and methods for generating 3D surface patches from unconstrained 3D curves.
7. Claims 1-20 are rejected and THIS ACTION IS MADE FINAL. 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.
8. Any inquiry concerning this communication or earlier communications from the examiner should be directed to ANDRE PIERRE-LOUIS whose telephone number is (571)272-8636. The examiner can normally be reached M-F 9:00 AM-5:00 PM.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, EMERSON C PUENTE can be reached at 571-272-3652. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/ANDRE PIERRE LOUIS/Primary Patent Examiner, Art Unit 2187 June 13, 2026