DETAILED ACTION
Response received on March 18, 2026 has been acknowledged. Claims 1, 8, and 15 have been amended. Therefore, Claims 1-20 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 .
Status of Claims
This Final action is in response to the application filed on 10/31/2022 and in response to Applicant’s Arguments/Remarks filed on 3/18/2026. Claims 1-20 are pending.
Priority
Application 17/977,796 was filed on 10/31/2022 and claims benefits to a provisional application no. 63/273,776, filed October 29, 2021.
Applicant’s Reply
Applicant's response of March 18, 2026 has been entered. The examiner will address applicant’s remarks at the end of this office action. The examiner acknowledges the amendments made to Claim 1, 8, and 15.
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
Claims 1-7 are directed to a method (process), claim 8-14 are directed to a system and device (machine/apparatus), and claims 15-20 are directed to a non-transitory computer-readable medium (manufacture/machine). Thus, these claims fall within one of the four statutory categories of invention. (Step 1: Yes)
For step 2A, the Examiner has identified independent method Claim 1 as the claim that represents the claimed invention for analysis and is similar to independent claim 8 and 15. Claim 1, as exemplary is recited below, isolating the abstract idea from the additional elements, wherein the abstract idea is set in bold:
A dynamically updatable method for hybrid onboarding of disparate compliance systems through centralized federated compliance management using repository- specific policy mapping definitions, comprising: importing, by a federated compliance management system operating in a cloud computing environment, a repository-specific retention policy from a source information system communicatively connected to the federated compliance management system over a network, the source information system on premises of an enterprise and operating in an enterprise computing environment; converting, by the federated compliance management system using a policy mapping definition, the repository-specific retention policy into a federated retention policy, the policy mapping definition containing: attribute mappings for federated attributes common across a plurality of on-prem information systems of disparate types; and repository-specific attributes that are specific to the source information system, the converting including: receiving a change in one of the repository-specific attributes; and updating the policy mapping definition responsive to the change, wherein the updating results in the change specific to the source information system being dynamically incorporated in the federated retention policy; storing the federated retention policy in the cloud computing environment, creating a target information system policy using the federated retention policy thus dynamically updated; pushing the target information system policy to a target information systems, wherein the target information and the source information system have different types of repositories.
The above bolded limitations recite the abstract idea of importing a repository-specific retention policy and converting using a policy mapping definition, the repository-specific retention policy into a federated retention policy. These recited limitations under its broadest reasonable interpretation, covers certain methods of organizing human activity (commercial interactions include agreements in the form of contracts, advertising, marketing or sales activities or behaviors, and business relations) but for the recitation of generic computer components. For example, for the federated compliance management system and its associated computer components, this claim encompasses importing, mapping, and dynamically updating retention policies across disparate information systems, which is a business-related transaction involving an organization’s facilitation of regulatory compliance services that could otherwise be managed manually by compliance personnel. If a claim limitation, under its broadest reasonable interpretation, covers legal and commercial interactions between parties, but for the recitation of generic computer components, then it falls within the “certain methods of organizing human activity” grouping of abstract ideas. The mere nominal recitation of a disparate compliance systems, federated compliance management system operating in a cloud computing environment, a source information system communicatively connected to the federated compliance management system over a network, cloud computing environment, on-prem information systems of disparate types, and an enterprise computing environment do not take the claim out of the methods of organizing human interactions grouping. Thus, claims 1, 8, and 15 recite an abstract idea. (Step 2A- Prong 1: YES. The claims recite an abstract idea).
This judicial exception is not integrated into a practical application (2nd prong of eligibility test for step 2A). Claim 1 recites the additional elements of a “disparate compliance systems”, “federated compliance management system operating in a cloud computing environment”, “a source information system communicatively connected to the federated compliance management system over a network”, “cloud computing environment”, “on-prem information systems of disparate types”, “a target information system”, and “an enterprise computing environment”. Claim 8 recites similar additional elements of Claim 1 with the addition of “a processor” and “a non-transitory computer-readable medium”. Claim 11 recites similar additional elements of Claim 1 with the addition of “a computer program”, “a processor”, and “a non-transitory computer-readable medium”. These additional elements are all considered nothing more than generic computing devices to perform generic communicating functions such as storing data and instructions, transmitting and receiving data between computers. The computing devices are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function of communicating data between users) such that they amount no more than mere instructions to apply the exception using a generic computer component. Accordingly, these additional elements (combination of computer and the use ledgers) do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea and are recited at a high level of generality when considered both individually and as a whole. Thus, Claims 1, 8, and 15 are directed to an abstract idea without an integration into a practical application. (Step 2A-Prong 2: NO: the additional claimed elements are not integrated into a practical application).
For step 2B, the claim(s) do not include additional elements that are sufficient to amount to significantly more than the judicial exception because they do not amount to more than simply instructing one to practice the abstract idea by using generic computer components to carry out the steps that define the abstract idea, as discussed above. This does not render the claims as being eligible. See MPEP 2106.05(f). The additional elements of using “disparate compliance systems”, “federated compliance management system operating in a cloud computing environment”, “a source information system communicatively connected to the federated compliance management system over a network”, “cloud computing environment”, “on-prem information systems of disparate types”, “a target information system”, and “an enterprise computing environment” when considered both individually and as an ordered combination did not add significantly more to the abstract idea because they were simply applying the abstract idea using generic computer components. In addition, the claims recite additional element which are considered nothing more than a general link to technology because there is no recitation of specifics of how this additional element is being used. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept (See MPEP 2106.05(f)). Accordingly, these additional elements, do not change the outcome of the analysis, and claims 1, 8, and 15 are not patent eligible. (Step 2B: NO. The claims do not provide significantly more).
Claims 2, 4-5, 9, 11-12, 16, and 18-19, recite limitations that further define the abstract idea noted in the independent claims to include determining whether the repository-specific retention policy of the source information system is up for migration to a target information system, a payload for a call to the target information system, and wherein the policy mapping definition is provisioned to the source information system from a master mapping definition. The dependent claims 2, 4-5, 9, 11-12, 16, and 18-19, do not include any additional elements and therefore are considered patent ineligible for the reasons given above.
Claims 3, 10, and 17, recite limitations that further define the abstract idea noted in the independent claims to include a user to select for importation a repository-specific retention policy from all the repository-specific retention policies. In addition, they recite the additional element of an “a user interface”. These additional elements are recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using a generic component. Even, in combination, this additional element does not integrate the abstract idea into a practical application and does not amount to significantly more than the abstract idea itself. The claims are ineligible.
Claims 6-7, 13-14, and 20, recite limitations that further define the abstract idea noted in the independent claims to include the master mapping definition comprises a template field for which a value is prepopulated from a template when the policy mapping definition is provisioned by the federated compliance management system and wherein the source information system is multi- phased. The dependent claims 6-7, 13-14, and 20, do not include any additional elements and therefore are considered patent ineligible for the reasons given above.
Response to arguments
Applicant's arguments filed March 18, 2026 have been fully considered but they are not persuasive.
The comments regarding the 35 USC 101 rejection are noted. On page 9 of Applicant’s response, applicant asserts that the Examiner misconstrued or misunderstood Applicant's Previous Arguments by taking a passage out of the entire paragraph. For clarity, the facts of the claimed invention are not identical to facts of DDR Holdings. Rather, the point is that, just like the invention at issue in DDR Holdings, the invention as claimed is fundamentally rooted in computer technology. Also, just like the invention at issue in DDR Holdings, the claimed invention is used in the computing environment. The Examiner respectfully disagrees, and acknowledges that the comparison to DDR Holdings was raised by Applicant, however, the claims are not analogous because they do not address a problem unique to computer networks or provide a specific technological solution as in DDR Holdings, but instead recite the use of generic computing components to implement the abstract idea of data processing and policy management. Thus, merely asserting that the invention is “rooted in computer technology” or operates within a computing environment is insufficient to overcome the 101 rejection where the claimed advance does not improve computer functionality itself. Applicant further argues that as submitted in the Previous Arguments, taking a computer system repository attribute from one computer system and mapping it to the same retentional policy as a different computer system repository attribute from a second system, is a problem that, by definition, only arises in the context of computer systems. Examiner respectfully disagrees because while the problem may arise in a computer environment, the claimed solution (retrieving attributes, comparing them, and mapping them to corresponding policies) constitutes an abstract idea of information processing that can be performed conceptually and does not reflect a technological improvement to computer systems themselves. Simply because the context involves computer systems does not render the claim eligible, as the focus remains on organizing and translating information between systems using generic computing functionality rather than solving a technical problem in computer technology.
Applicant further argues that is, by the very nature of the invention and based on historical case laws, the solution described and claimed in the instant Application is indeed for solving a problem necessarily rooted in computer technology, just like the invention at issue in DDR Holdings. Examiner respectfully disagrees because merely asserting that the claimed invention is “by its nature” rooted in computer technology does not make it so under 101, where the claim is directed to abstract data mapping and policy alignment performed using generic computing components. Unlike DDR Holdings, which addressed a problem unique to computer networks with a specific technological solution, the present claims do not improve the functioning of the computer or network itself but instead use known technology to implement an abstract business idea. Additionally, and to the extent Applicant alleges a technical improvement, the claims do not recite sufficient specific limitations to reflect such an improvement. Applicant further argues that the claimed invention solves this technical problem by converting a repository-specific retention policy imported from a source information system into a policy mapping definition and using the policy mapping definition to create a target information system policy for a target information system so that one information system attribute can be mapped to another information system dynamically, even if their repositories are of different types. Examiner respectfully disagrees because the claimed steps of importing policies, converting them into mapping definitions, and generating corresponding policies for another system merely reflect abstract data manipulation and rule application, which constitute a business improvement in managing compliance information across systems, rather than an improvement to computer functionality itself. The claims do not recite any specific technical mechanism for resolving differences between repository types, but instead state a desired results achieved through generic computing components, and therefore do not provide a technological solution sufficient to overcome the 101 rejection.
Applicant further argues that by solving a technical problem that specifically arising in the realm of networked, distributed, disparate information systems and repositories, the claimed invention is necessarily rooted in computer technology. This is exactly the reason that the claims in DDR Holdings were found to be eligible for patent, as submitted in the Previous Arguments. Further, the invention operates in the same way as the invention at issue in DDR Holdings, namely, entirely in a computing environment, no brick and mortar involved. Examiner respectfully disagrees because merely framing the problem as arising in distributed or disparate information systems does not render the claims “necessarily rooted in computer technology” where the recited solution is still limited to abstract data mapping, policy translation, and information exchange using generic computing components. Unlike DDR Holdings, which addressed a problem in unique to computer networks with a specific technical solution, the present claims do not improve network functionality or system architecture, but instead implement a business or compliance objective in a computing environment, and operating entirely on a computer without brick-and-mortar elements does not lead to eligibility under 101. Applicant further argues that in the instant case, the claims represent a non-abstract improvement in the functionality of an existing technological process - a specific type of data migration in an enterprise computing environment, migrating compliance policies from one information system to another information system and that prior to the invention, this kind of dynamic mapping of disparate attributes across repositories of different types cannot be performed via existing data migration processes. Thus, like the claims at issue in Koninklijke, the claims of the instant Application represent a non- abstract improvement in the functionality of an existing technological process and, therefore, are eligible for patent under 35 U.S.C. § 101. Examiner respectfully disagrees because the claimed improvement to data migration merely involves converting, mapping, and updating policy information across systems, which constitutes abstract data processing and does not reflect an improvement to the functioning of the computer or network itself. While Applicant asserts that prior systems could not perform such dynamic mapping, the claims do not recite any specific technological mechanisms or architectural change that enables this capability, but instead describe a desired results achieved through generic computing components, and thus do not provide a non-abstract improvement under 101. The amendments do not meaningfully transform the abstract idea into a patent-eligible application. For the reasons mentioned above, the argument to the contrary is not persuasive. Thus, the rejections of Claims 1-20 under 35 USC 101 are maintained.
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
extension fee 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 date of this final
action.
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/A.W.H./ Examiner, Art Unit 3626
/JESSICA LEMIEUX/ Supervisory Patent Examiner, Art Unit 3626
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