DETAILED ACTION
Response received on July 01, 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 Non-Final action is in response to the application filed on 10/31/2022 and in response to Applicant’s Arguments/Remarks filed on 7/01/2026. 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 July 01, 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.
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 July 01, 2026 has been entered.
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 having an on-prem format 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 imported from the source system over the network from the on-prem format into a federated retention policy in a standard format internal to the federated compliance management system, 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 system 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 July 01, 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 specifically disagrees with these statements previously made by the Examiner and notes that Applicant did not merely assert that the invention is "rooted in computer technology" or "operates within a computing environment." Rather, Applicant particularly submitted in the Previous Reply, and also cited portions of the specification in support for the argument that "taking a computer system repository attribute from one computer system (e.g., a source information system on premises of an enterprise and operating in an enterprise computing environment) and mapping it to the same retentional policy as a different computer system repository attribute from a second system (e.g., a target information system of a different type), is a problem that, by definition, only arises in the context of computer systems (e.g., on-prem information systems of disparate types). Examiner respectfully disagrees because the claimed repository specific attributes, policy mapping definitions, and federated retention policies merely define the information being processed, not an improvement to the underlying computer technology. Examiner notes that while the claim is implemented in the context of disparate computer systems, it uses generic cloud and networked computing components to automate the management and translation of retention policies, rather than reciting a specific technological improvement to computer functionality or network operation as required under DDR Holdings. Applicant further argues that the claims of the instant Application do not recite "the use of generic computing components to implement the abstract idea of data processing and policy management" as the Examiner alleged. No record evidence shows, and the Examiner has not cited any reference or technical documentation that shows, using generic computing components can actually perform the ordered combination of limitations exactly as recited in the claims. Examiner respectfully disagrees because the 101 rejection does not require evidence that generic computing components perform each claimed limitations. Instead, the claim is evaluated as a whole, and the recited cloud computing environment, network, and information systems merely serve as generic computer components used to automate the abstract idea of policy management and data processing without providing a technological improvement to computer functionality or another technology.
Applicant respectfully submits that the Examiner seems to have made contradictory statements here. As discussed above, the Examiner first argued that the claims at issue in DDR Holdings and the claims of the instant Application "are not analogous because they do not address a problem unique to computer networks" but then acknowledged that "the problem may arise in a computer environment." Applicant respectfully submits that "taking a computer system repository attribute from one computer system (e.g., a source information system on premises of an enterprise and operating in an enterprise computing environment) and mapping it to the same retentional policy as a different computer system repository attribute from a second system (e.g., a target information system of a different type)" is not something that "may" or "may not" arise in a computer environment. This problem is unique, i.e., can only occur, in a computer environment. At least for this reason, the claims at issue in DDR Holdings and the claims of the instant Application" are indeed analogous and, therefore, the holding of DDR Holdings applies. Examiner respectfully disagrees because there is no inconsistency in the Office Action. The Examiner acknowledged that the claim operations occur in a computer environment, however, that does not establish that the claims solve a problem unique to computer technology or improve the functioning of a computer or network. Rather, the claimed importing, converting, updating, and mapping of repository specific retention policies merely automate the processing and management of compliance policies using generic computing components. Examiner notes that the claims are analogous to DDR Holdings, which involved a specific technological solution that altered the generic operation of computer networks. Applicant respectfully submits that the Examiner's argument "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" generalizes the claimed invention at a high level of abstraction that is untethered from the language of the claims. The Examiner's rationale and statements run afoul of the Federal Circuit's decision in Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016). Examiner respectfully disagrees because Applicant’s reliance on Enfish is unpersuasive because the Examiner’s characterization is based on the claim language, which recites importing, converting, mapping, updating, storing, and distributing retention policies across desperate information systems. These limitations are directed to the processing and management of information and do not recite a specific improvement to the operation of the computer, database architecture, or network technology as in Enfish.
Applicant respectfully submits that the Examiner's analysis conveys a high level of abstraction and is untethered from the language of the claims. Like the district court analysis disapproved by the Federal Circuit, the Examiner's analysis failed to meaningfully consider what the invention is "directed to," and instead falls into the trap of concluding that a claim "constitutes an abstract idea of information processing that can be performed conceptually and does not reflect a technological improvement to computer systems themselves," rather than as a whole informed by the specification. Examiner respectfully disagrees because the Examiner considered the claim as a whole, consistent with the Alice/Mayo framework. Examiner notes that while the claim is implemented in a computer environment, the recited limitations are directed to processing and managing retention policy information using generic computing components and do not recite a specific technological improvement to computer functionality or another technology. Accordingly, the Examiner’s characterization is grounded in the claim language and remains proper under 35 USC 101. Applicant further argues that In this case, as a whole, the claimed invention solves a problem that not only can only arise in a computer environment, but is also rather specific to "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." To solve this specific problem, the claim recites a particular ordered combination of limitations. No record evidence shows that the particular ordered combination of limitations recited in the claim "can be performed conceptually." The Examiner has not cited any reference or technical documentation to support this assertion. Nor has the Examiner cited any reference or technical documentation to show that a person of ordinary skill in the art would have the general knowledge of solving a problem that arises in a computer environment by performing a solution "conceptually" as the Examiner alleged. Examiner respectfully disagrees because the 101 rejection is based on the claim language itself, not on factual findings regarding the capabilities of generic computer systems. The Examiner is not asserting that the ordered combination is well-understood, routine, or conventional under Step 2B, but rather that, under Step 2A, the additional elements merely implement the abstract idea using generic computer technology without reciting a technological improvement.
Applicant respectfully submits that the Examiner then argued that "[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." However, the claims in the instant Applicant do not recite "organizing and translating information between systems using generic computing functionality." It is unclear what the Examiner meant by "the focus" or how "the focus" proposed by the Examiner solves the identified problem of "taking a computer system repository attribute from one computer system (e.g., a source information system on premises of an enterprise and operating in an enterprise computing environment) and mapping it to the same retentional policy as a different computer system repository attribute from a second system (e.g., a target information system of a different type)." No record evidence shows and the Examiner has not cited any reference or technical documentation in support of the argument that "organizing and translating information between systems using generic computing functionality" can solve the identified problem. Examiner respectfully disagrees because the 101 rejection is based on the claim language itself and the nature of the recited limitations under Step 2A of the eligibility analysis, not on factual findings regarding whether the claimed operations are well-understood, routine, or conventional under Step 2B. Accordingly, no such evidentiary showing is required for the rationale set forth in the Office Action. Applicant further argues that this claim limitation particularly points out and distinctly claims "a federated compliance management system operating in a cloud computing environment" performing a specific import action. No record evidence shows that the recited "federated compliance management system operating in a cloud computing environment" is a "generic computing component" as the Examiner alleged. The Examiner respectfully disagrees for the same reasons set forth above. Additionally, these elements provide the computing environment in which the abstract idea of importing, converting, updating, and managing retention policies is implemented without improving the functionality of the computer or cloud technology itself.
Applicant further argues that the recited "federated compliance management system operating in a cloud computing environment" imports a specific "repository-specific retention policy" from "a source information system communicatively connected to the federated compliance management system over a network." So, this claim limitation also particularly points out and distinctly claims how the specific import action is performed by the recited "federated compliance management system operating in a cloud computing environment" - "over a network." No record evidence shows that performing such an import action over a network can be achieved by "abstract data mapping and policy alignment using generic computing components." Examiner respectfully disagrees. Examiner notes that that importing a repository specific retention policy over a network merely uses generic networking functionality to implement the abstract idea and does not recite a technological improvement to the operation of the computer, network, or cloud computing environment. Applicant further argues that the claim limitation at issue distinctly distinguishes the recited "federated compliance management system operating in a cloud computing environment" from the source system by particularly pointing out that the source information system is "on premises of an enterprise and operating in an enterprise computing environment." Thus, the claim limitation at issue expressly recites how two computer systems - the recited "federated compliance management system operating in a cloud computing environment" and the recited "source system on premises of an enterprise and operating in an enterprise computing environment" interact over a network to achieve a specific result - importing a "repository-specific retention policy" from the source system over a network. This action, in and by itself, can only occur in a networked computing environment and, indeed, involves two different computing environments: a cloud computing environment and an enterprise computing environment. Examiner respectfully disagrees because interaction between a cloud system and an on-premises system over a network merely provides the context in which the abstract idea is performed and does not recite a technological improvement to the computer, network, or cloud computing environment.
Applicant further argues that as submitted in the Previous Reply, this policy conversion with dynamic attribute mapping solves another specific technical problem that specifically arising in the realm of computer networks - how to dynamically map attributes across disparate, distributed, networked information systems is indeed a technical problem that specifically arising in the realm of computer networks. See Previous Reply, page 11. 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 dynamically mapping attributes between disparate information systems improves the management of compliance policy information, not the operation of the computer network, or repository technology itself. Although, the mapping occurs across different repository types, the claim merely uses generic computing components to implement the abstract idea rather than reciting a specific technological improvement. Applicant further disagrees with this argument and points out that the Examiner's argument is not based on an analysis of the actual claim language, as what Applicant has done above. Again, like the district court analysis disapproved by the Federal Circuit, the Examiner's argument generalizes the claim at a high level of abstraction and is untethered from the language of the claim. Examiner respectfully disagrees because the Examiner’s characterization is based on the claim language as a whole. The recited importing, converting, updating, and generating of policies describe the processing and management of compliance information across systems and do not recite an improvement to the operation of the computer, network, or repository technology itself. Accordingly, the Examiner’s analysis is not an oversimplification, but reflects the focus of the claimed invention under the 101 eligibility analysis.
Applicant further argues that on page 9 of the Office Action, the Examiner repeated prior arguments and insisted that "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" and that the claims "describe a desired results achieved through generic computing components." Applicant specifically disagrees with this line of arguments and points out that the Examiner's argument is based on a generalization of the claimed invention at a high level of abstraction and is rather untethered from the language of the claims. Applicant respectfully submits that this kind of analysis has already been disapproved by the Federal Circuit as "all but ensures that the exceptions to § 101 swallow the rule." Enfish. Examiner respectfully disagrees because the Examiner’s analysis is based on the claim language as a whole, not an impermissible oversimplification. Examiner notes that the recited converting, mapping, and updating of policy information describe the processing and management of compliance information across disparate systems and do not recite a specific improvement to the functionality of the computer, network, or cloud computing technology. Accordingly, the claims remain directed to an abstract idea implementation using generic computing components, rather than a technological improvement as contemplated by Enfish. 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
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/A.W.H./ Examiner, Art Unit 3626
/JESSICA LEMIEUX/Supervisory Patent Examiner, Art Unit 3626
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