Prosecution Insights
Last updated: October 02, 2026
Application No. 18/019,952

DATA PROCESSING SYSTEMS AND METHODS FOR AUTOMATICALLY REDACTING UNSTRUCTURED DATA FROM A DATA SUBJECT ACCESS REQUEST

Final Rejection §101
Filed
Feb 06, 2023
Priority
Aug 06, 2020 — provisional 63/061,894 +1 more
Examiner
JAMI, HARES
Art Unit
2164
Tech Center
2100 — Computer Architecture & Software
Assignee
OneTrust LLC
OA Round
6 (Final)
73%
Grant Probability
Favorable
7-8
OA Rounds
0m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 73% — above average
73%
Career Allowance Rate
518 granted / 707 resolved
+18.3% vs TC avg
Strong +29% interview lift
Without
With
+29.4%
Interview Lift
resolved cases with interview
Typical timeline
3y 1m
Avg Prosecution
19 currently pending
Career history
734
Total Applications
across all art units

Statute-Specific Performance

§101
20.9%
-19.1% vs TC avg
§103
49.9%
+9.9% vs TC avg
§102
9.8%
-30.2% vs TC avg
§112
14.1%
-25.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 707 resolved cases

Office Action

§101
DETAILED ACTION This is in response to the reply filed on 07/07/2026. Claims 21-40 are pending in this Action. Claims 1-20 had been previously cancelled. Remark In the response filed 07/07/2026, claims 21, 24, 28, 31, and 37 have been amended, no claim has been cancelled, and no new claim has been added. Response to Arguments The Applicant's arguments filed 07/07/2026 with respect to 35 USC 101 rejections of claims 21-40 for being directed to abstract idea have been fully considered but they are not persuasive. The applicant in pages 10-13 of the Remark under argument A. Applicant submits the claims do not recite a mental process (Prong One of Step 2A) alleges that the limitations of “receiving…data”, “maintaining the identity graph in a non-transitory, computer-readable medium” and “querying…based on the data type” are not mental process and cannot be performed in the human mind. The Examiner agrees. The Examiner has treated said limitation as non-mental processes and additional limitations. As such, said limitations have been analyzed under Step 2A, Prong 1 and Step 2B for being extra-solution and/or well-understood, conventional, and generic computer activities. However, the Examiner disagrees with the applicant’s assertion the method steps such as “generating an identity graph” that includes nodes and edges and “removing…the second piece of data from the responsive data”, as recited in claim 21 cannot be performed mentally. The Applicant argues that “…unlike a generic data lookup or filtering routine, claim 21 incorporates ‘an identity graph for the data subject comprising a plurality of nodes, wherein the identity graph is maintained in a non-transitory, computer- readable medium and wherein each node of the plurality of nodes indicates a data source, at least one type of personal data for the data subject stored at the data source, a method of accessing the data source, and a data type identifier used at the data source.’ This represents a specific, concrete, technical limitation that cannot be ‘generated’ by the human mind as claimed.” MPEP 2016 urges Examiners to establish broadest reasonable interpretation of claim as a whole: It is essential that the broadest reasonable interpretation (BRI) of the claim be established prior to examining a claim for eligibility. The BRI sets the boundaries of the coverage sought by the claim and will influence whether the claim seeks to cover subject matter that is beyond the four statutory categories or encompasses subject matter that falls within the exceptions. See MyMail, Ltd. v. ooVoo, LLC, 934 F.3d 1373, 1379, 2019 USPQ2d 305789 (Fed. Cir. 2019) ("Determining patent eligibility requires a full understanding of the basic character of the claimed subject matter"), citing Bancorp Servs., LLC v. Sun Life Assurance Co. of Can. (U.S.), 687 F.3d 1266, 1273-74, 103 USPQ2d 1425, 1430 (Fed. Cir. 2012); In re Bilski, 545 F.3d 943, 951, 88 USPQ2d 1385, 1388 (Fed. Cir. 2008) (en banc ), aff'd by Bilski v. Kappos, 561 U.S. 593, 95 USPQ2d 1001 (2010) ("claim construction … is an important first step in a § 101 analysis"). Evaluating eligibility based on the BRI also ensures that patent eligibility under 35 U.S.C. 101 does not depend simply on the draftsman’s art. Alice, 573 U.S. 208, 224, 110 USPQ2d at 1984, 1985 (citing Parker v. Flook, 437 U.S. 584, 593, 198 USPQ 193, 198 (1978) and Mayo, 566 U.S. at 72, 101 USPQ2d at 1966). Moreover, MPEP 2106.04 states: Accordingly, the "mental processes" abstract idea grouping is defined as concepts performed in the human mind, and examples of mental processes include observations, evaluations, judgments, and opinions… The courts do not distinguish between mental processes that are performed entirely in the human mind and mental processes that require a human to use a physical aid (e.g., pen and paper or a slide rule) to perform the claim limitation. See, e.g., Benson, 409 U.S. at 67, 65, 175 USPQ at 674-75, 674 (noting that the claimed "conversion of [binary-coded decimal] numerals to pure binary numerals can be done mentally," i.e., "as a person would do it by head and hand."); Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 1139, 120 USPQ2d 1473, 1474 (Fed. Cir. 2016) (holding that claims to a mental process of "translating a functional description of a logic circuit into a hardware component description of the logic circuit" are directed to an abstract idea, because the claims "read on an individual performing the claimed steps mentally or with pencil and paper")… Nor do the courts distinguish between claims that recite mental processes performed by humans and claims that recite mental processes performed on a computer. The Examiner contends that based on broadest and reasonable interpretation (BRI) of the claim limitation, “an identifying graph” comprising nodes indicating a data source, one type of personal data, a method of accessing the data source, and a data type identifier (as recited in claim 21) is interpreted as a graph/tree data structure including data (e.g., nodes) indicating multiple different data types. It is merely non-functional descriptive material defining data. It is not a computer function. Thus, a human being is capable of generating a graph (i.e., a data structure) with multiple nodes representing different data types with aid of a pen and paper. The courts do not distinguish between mental processes that are performed entirely in the human mind and mental processes that require a human to use a physical aid (e.g., pen and paper or a slide rule) to perform the claim limitation. See, e.g., Benson, 409 U.S. at 67, 65, 175 USPQ at 674-75, 674. As such, giving the limitations their broadest and reasonable interpretations, the limitation of generating an identity graph including nodes and edges could be performed mentally aided with a pen and paper. For example, a person can manually generate a graph with multiple nodes and edges on a paper sheet. The nodes can include data elements such IDs, names, attributes, note, etc. As such, in the process of generating a graph, a person can use the concepts of observation, evaluation and/or judgement and manually with aid of a pen and paper to generate a graph containing nodes. Said limitation is not a pure computer function (e.g., storing data in a memory) and nothing in this limitation precludes the limitation from being performed in the human mind. Furthermore, the feature of “removing…the second piece of data from the responsive data” as recited at a high level of generality constitutes the concepts of observation, evaluation and/or judgement in which a user in response to determination that data does not match the identifying data (which is evaluation and judgement), manually remove the data from a response. Said limitation is not a pure computer function (e.g., storing data in a memory) and nothing in this limitation precludes the limitation from being performed in the human mind. Under broadest and reasonable interpretation, the processed data does not necessarily need to be very large or complex. It could be simply unstructured data such as an email or a message which is well withing capability of a human. A human being (e.g., a developer) can process such data (e.g., an email or a message) by observing and evaluating the received data to generate an identity graph using a pen and paper. He/she could further judge whether the identity graph includes identifying data, identify a first data type identifier associated with a first data source matches the first categorization, and remove the fourth piece of data from the second responsive data responsive to determining that the fourth piece of data found in the second responsive data does not match the second piece of data. As, can be seen, the functions of identifying and determining involves the concepts of observation, evaluation, and judgment. The redaction process could be performed manually based on observation, evaluation, and judgment. Although it might be time consuming, the human brain is capable of processing large and complex data. Thus, given a BRI to the step of “removing” a piece of data from the responsive data, it could be interpreted as deleting a piece data. Said step could be practically performed mentally and manually. It involves the concepts of evaluation and/or judgment, and a user or an administrator can manually remove (e.g., delete) a piece of data from data. It is not required to be a computer function or a computer to implement it. Thus, the step of “removing” a piece of data from the responsive data could be a mental process. Therefore, the above-mentioned functions (e.g., identifying, generating, determining, and/or removing) are considered to be mental processes, under Step 2A, prong 1 analysis. Moreover, The applicant in pages 14-15 of the Remark argues that The Office Action's Prong Two analysis is also deficient with respect to the limitation "querying, by the computing hardware, based on the data type identifier, and via the one or more source-specific access methods stored in the identity graph, the [first or second] data source using the identifying data." The Office Action characterizes this entire querying operation, along with receiving operations, as "insignificant extra pre-solution activities of data gathering, data input, searching data and receiving results," but does not address the particular requirement that the query be performed "via the one or more source-specific access methods stored in the identity graph." That omission is material. The claimed operation is not a generic "searching data" step; it requires source-specific access methods to be stored in the identity graph and invoked at query time based on a data type identifier to interface with data sources that may use different identifiers, storage formats, and access mechanisms. The Specification explains that the identity graph stores, for each data source, the personal data handled by that source and the means by which the personal data may be accessed, and that an access method may be a particular query, a query template, a script, or another means of accessing data at the data source. By requiring the computing hardware to perform queries through these pre-stored, source-specific access methods, the claims impose a meaningful technological limit on any alleged abstract idea and integrate the alleged exception into a practical application…. The Examiner respectfully disagrees. The MPEP asserts that it is essential the broadest reasonable interpretation (BRI) of the claim be established prior to examining a claim for eligibility in both steps 2A and 2B. See MPEP 2106.04(II) and 2106.05.B(II). The applicant alleges that the searching step “requires source-specific access methods to be stored in the identity graph and invoked at query time based on a data type identifier to interface with data sources that may use different identifiers, storage formats, and access mechanisms. The Specification explains that the identity graph stores, for each data source, the personal data handled by that source and the means by which the personal data may be accessed, and that an access method may be a particular query, a query template, a script, or another means of accessing data at the data source.” The Examiner hold that in accordance with BRI, the limitation of “querying, by the computing hardware, based on the data type identifier, and via the one or more source-specific access methods stored in the identity graph, the [first or second] data source using the identifying data,” recited at a high level of generality without “specific technological details” to achieve the result. The subject matter of “one or more source-specific access method” is not defined in the claim and it could be interpreted merely accessing a source such a database, storage, or a data structure, such as, using a SQL if the source is a relational database. The features such as “invoked at query time based on a data type identifier to interface with data sources that may use different identifiers, storage formats, and access mechanisms. The Specification explains that the identity graph stores, for each data source, the personal data handled by that source and the means by which the personal data may be accessed, and that an access method may be a particular query, a query template, a script, or another means of accessing data at the data source” are not required by the limitation of “querying…”. In accordance with BRI and MPEP 2111, the Examiner is not allowed to import that limitation of the specification into the claim. Therefore, giving the limitation of “querying…” its BRI, it is no more than searching a source in a generic way (e.g., using a SQL if the source is relational database) using a data identifier. Thus, contrary to the applicant allegation, limitation “querying” without requiring specifying technological details to achieve the result is considered to be an extra-solution activity of searching data. However, Applicant can amend the claim and add detailed technological features to the “querying” limitation and make the “querying” step more specific. Furthermore, the Examiner respectfully disagrees with the applicant’s assertion that the functions of identifying the data type identifier, determining based on identity graph…does not match the identifying data, and responsive to determining…removing the second piece of data are additional limitations under Step 2A, prong 2 analysis. The Examiner respectfully disagrees with the applicant’s allegation in pages 15-16 of the Remark that: With respect to the limitation added in the previous response, namely, "generating an identity graph for the data subject comprising a plurality of nodes, wherein the identity graph is maintained in a non-transitory, computer-readable medium, and wherein each node of the plurality of nodes indicates a data source, at least one type of personal data for the data subject stored at the data source, one or more source-specific access methods, and a data type identifier used at the data source," Applicant submits the Office Action is incorrect that this limitation merely "constitutes a concept which could be practically performed in the human mind." Office Action, p. 3. …The identity graph data structure is technically distinct from conventional data storage approaches. Each node in the graph encapsulates multiple technical attributes: (1) a reference to a specific data source, which may be a database, API endpoint, file system, or other storage system; (2) metadata indicating the type of personal data stored at that source; (3) one or more source-specific access methods, which may include API calls, database queries, authentication protocols, or other machine-executable access procedures for the particular source; and (4) a data type identifier that corresponds to the schema or naming convention used within that particular data source. Again, the limitation is recited at a high level of generality and given the claim its BRI, each node in the graph includes data that merely defines multiple non-functional features. These data definitions included in each node (e.g., indicating a data source, at least one type of personal data for the data subject stored at the data source, one or more source-specific access methods, and a data type identifier used at the data source) are merely non-functional descriptive material. The Examiner holds that said feature without reciting any functionality are merely data definitions. As such, a person with aid of pen and paper can manually generate a graph with multiple nodes and include multiple data definition in each node. Therefore, this step involves the concepts of observation, evaluation and/or judgement that could be practically performed in the human mind. It does not require a computer to be performed. Again, the features that applicant alleges that said limitation requires (e.g., Each node in the graph encapsulates multiple technical attributes: (1) a reference to a specific data source, which may be a database, API endpoint, file system, or other storage system; (2) metadata indicating the type of personal data stored at that source; (3) one or more source-specific access methods, which may include API calls, database queries, authentication protocols, or other machine-executable access procedures for the particular source; and (4) a data type identifier that corresponds to the schema or naming convention used within that particular data source.) are not recited in the limitation. Based on BRI and MPEP 2111, the Examiner is not allowed to import that limitation of the specification into the claim. Therefore, the Examiner contends that the limitation of “generating an identity graph for the data subject comprising a plurality of nodes, wherein each of the plurality of nodes indicates a data source, at least one type of personal data for the data subject stored at the data source, a method of accessing the data source, and a data type identifier used at the data source “ is a mental process. It is recited at a high level of generality. In accordance with BRI, this limitation constitutes a concept which could be practically performed in the human mind. A person can manually generate a graph comprising multiple nodes representing different types of data using a pen and paper. The claim limitation of generating “an identifying graph” comprising nodes indicating a data source, one type of personal data, a method of accessing the data source, and a data type identifier (as recited in claim 21) is merely a graph/tree data structure including data (e.g., nodes) indicating multiple different data types. As it can been seen, it is merely a non-functional descriptive material describing data formats. It is not a computer function. Thus, a human being is capable of generating an identifying graph with multiple nodes representing different data types with aid of a pen and paper. As such, the function of generating a graph, identifying, determining, and removing/ are not computer functions or non-mental processes to be considered as additional limitations. Therefore, said limitations are not eligible as additional limitations to be analyzed under Step 2A, prong 2 because they are considered to be mental processes. Moreover, the applicant in pages 17-21 of the Remark argues (Argument ii) that “any alleged mental process is integrated into a practical application because the claims provide an improvement to technology.” The applicant also alleges that “traditional systems lack an efficient, accurate, and privacy-preserving way to identify and redact extraneous personal data in distributed data environments. The present claims provide an improvement because, as a whole, the claims construct and use an identity graph to represent identity-based data, dynamically resolve categorization-based identifiers to be used in queries, and automatically redact mismatched data using graph-based determinations.” The applicant also asserts that the aforementioned limitations of “generating an identity graph…”, “identifying…”, "determining, by the computing hardware and based on the identity…”, "responsive to determining that the second piece of data found in the responsive data does not match the identifying data, redacting…” recited in claim 21 achieve the alleged improvement. The applicant also alleges that “the Specification specifically describes data sources having different data structures, storage formats, and software architectures; identity graph nodes that store the means for accessing each data source and data type identifiers used at the source; and use of that graph to retrieve known personal data across data sources for subsequent redaction. The Office Action does not address those specific technical mechanisms and therefore does not provide the reasoned Prong Two explanation required to maintain the rejection.” The Examiner respectfully disagrees As stablished above, said limitations of “generating an identity graph…”, “identifying…”, "determining, by the computing hardware and based on the identity…”, "responsive to determining that the second piece of data found in the responsive data does not match the identifying data, redacting…” recited in claim 21 are mental processes because these functions could be practically performed in the human mind. Mental processes such as “generating an identity graph…”, “identifying…”, "determining, by the computing hardware and based on the identity…”, "responsive to determining that the second piece of data found in the responsive data does not match the identifying data, redacting…” are not capable of improving a manner in which a computer functions or technology, and thus incapable of integrating the recited judicial exception into a practical application. It is important to note that in order for a method claim to improve computer functionality, the broadest reasonable interpretation of the claim must be limited to computer implementation. That is, a claim whose entire scope can be performed mentally, cannot be said to improve computer technology. Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 120 USPQ2d 1473 (Fed. Cir. 2016). As such, said mental processes cannot improve computer technology. Furthermore, the additional limitations of “receiving”, “query”, and “storing” data as recited in claim 21 are considered to be extra-solution and/or well-understood, conventional, and generic computer functions. The addition of such extra-solution activities to the recited abstract idea of claim 21 is not sufficient to improve a computer functionality or technology and integrate the recited judicial exception into a practical application. “Because a judicial exception alone is not eligible subject matter, if there are no additional claim elements besides the judicial exception, or if the additional claim elements merely recite another judicial exception, that is insufficient to integrate the judicial exception into a practical application.” See MPEP 2106.04(d) Furthermore, as described in the specification of current application the focus of the invention is to transform the manual process of redacting to “a method for automatically redacting” information or unstructured data (e.g., paragraphs 9, 22, and 65). It is noted that courts have established that “mere automation of manual processes, such as using a generic computer to process an application for financing a purchase, Credit Acceptance Corp. v. Westlake Services, 859 F.3d 1044, 1055, 123 USPQ2d 1100, 1108-09 (Fed. Cir. 2017) or speeding up a loan-application process by enabling borrowers to avoid physically going to or calling each lender and filling out a loan application, LendingTree, LLC v. Zillow, Inc., 656 Fed. App'x 991, 996-97 (Fed. Cir. 2016) (non-precedential)” is not sufficient to show improvement in computer functionality. Additionally, the Examiner respectfully disagrees with the applicant’s allegation that the present invention is similar to Enfish. Applicant’s reliance on Enfish for the eligibility of the claims of the instant application have been fully considered but are likewise not deemed to be persuasive. In order to rely on Enfish, improvement in the functionality of the computer itself must be proved. The specification needs to distinguish between the invention and conventional solutions. The specification must identify improvement in the functionality of the computer itself, tying the particular features of the claims to that improvement and how the claims are directed to improvement. The Examiner is unable to match the fact of the instant application to guidance of Enfish to establish improvement in the functionality of the computer itself to render the claims eligible. In this case, the claimed invention is unable to improve computer functionality because as established above it could be implemented mentally and under the broadest reasonable interpretation of the claim must be limited to computer implementation. That is, a claim whose entire scope can be performed mentally, cannot be said to improve computer technology. Therefore, claims 21, 28, and 34 lack additional limitations that improve computer functioning or technology and integrate the recited judicial exception into a practical application under Step 2A, Prong 2. Additionally, the applicant in pages 21-22 of the Remark asserts …claims 21, 28, and 34 recite a series of steps and specific elements that lead to a useful result. These features are not merely generic recitations of computer hardware or steps. Instead, they are unconventional features, which when considered as a whole amount to "significantly more" than any alleged judicial exception. For example, claim 21 recites an "identity graph" and a structured series of steps governing its application. For example, the identity graph comprises a plurality of nodes, "wherein each of the plurality of nodes indicates a data source, at least one type of personal data for the data subject stored at the data source, a method of accessing the data source, and a data type identifier used at the data source." The graph nodes define not only a data source, but also a type of personal data, an access method, and data type identifiers. Thus, the graph defines a specific architecture and flow that enhances system performance, avoids unnecessary computation, and enforces data privacy dynamically. The Examiner respectfully disagrees. Again, as established above the limitations (e.g., generating and identity graph, identifying, or determining) that the applicant consider as additional limitations are actually mental processes. These mental processes cannot add significantly to more than an abstract idea. Furthermore, as established in Step 2B analysis (see below), the claims do not include any limitation that could add significantly to more than abstract idea. The claim invention fails to improve computer technology or amount to inventive concept for the reasons that stated above. As explained above, in accordance with BRI, the limitation of “querying, by the computing hardware, based on the data type identifier, and via the one or more source-specific access methods stored in the identity graph, the [first or second] data source using the identifying data,” recited at a high level of generality without “specific technological details” to achieve the result. The subject matter of “one or more source-specific access method” is not defined in the claim and it could be interpreted merely accessing a source such a database, storage, or a data structure, such as, using a SQL if the source is relational database. Therefore, giving the limitation of “querying…” its BRI, it is merely searching a source in a generic way (e.g., using a SQL if the source is relational database) using a data identifier. Thus, contrary to the applicant allegation, limitation “querying” without requiring specifying technological details to achieve the result is considered to be a well-understood, conventional, and routine activity of searching data. This limitation does not include any inventive concept. Therefore, the additional limitations recited in the claims (e.g., receiving a request for target data, querying, receiving response data) are considered to be well-understood, conventional, and routine computer activities that do not add to more than an abstract idea. Therefore, the limitations of claims 21, 28, and 34 individually or in combination (claims as whole) fail to add significantly to more than an abstract idea. As such, the claims are patent ineligible. Based on above explanation and reasonings, the 35 USC 101 rejections of claims 21-40 for being directed to abstract idea are maintained. Claim Rejections - 35 USC § 101 35 U.S.C. 101 reads as follows: Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title. Claims 21-40 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter of abstract ideas. Step 1: Claims 21-40 are directed to a method/device/storage which is one of the statutory categories of invention. Step 2A: Prong 1: Claims 21, 28, and 34 are directed to an abstract idea without significantly more. Regarding amended claims 21 and 28, the claims recite the steps of: Identifying…a categorization for the identifying data; [recited at a high level of generality and given the claim its broadest and reasonable interpretation (BRI), it constitutes an observation and evaluation concepts which could be practically performed in the human mind] generating an identity graph for the data subject comprising a plurality of nodes, wherein each of the plurality of nodes indicates a data source, at least one type of personal data for the data subject stored at the data source, a method of accessing the data source, and a data type identifier used at the data source; [recited at a high level of generality and given the claim its BRI, it constitutes a concept which could be practically performed in the human mind. A person can manually generate a graph comprising multiple nodes representing different types of data using a pen and paper. The subject matter of “a data source, at least one type of personal data for the data subject stored at the data source, a method of accessing the data source, and a data type identifier used at the data source” considered to be non-functional descriptive data.] determining…that a node of the plurality of nodes of the identity graph for the data subject includes the identifying data mapped to the categorization; [recited at a high level of generality and given the claim its BRI, it constitutes an observation and evaluation concept which could be practically performed in the human mind] Identifying…a data type identifier associated with a data source that matches the categorization, wherein the data type identifier can be used in querying the data source; [recited at a high level of generality and given the claim its BRI, it constitutes an observation and evaluation concept which could be practically performed in the human mind] Identifying…the categorization for a second piece of data found in the responsive data; [constitutes an observation and evaluation concept which could be practically performed in the human mind] determining…based on the identity graph, that the second piece of data found in the responsive data does not match the identifying data; [recited at a high level of generality and given the claim its BRI, it constitutes an evaluation concept which could be practically performed in the human mind] and responsive to determining that the second piece of data found in the responsive data does not match the identifying data, removing…the second piece of data from the responsive data. [recited at a high level of generality and given the claim its BRI, it constitutes a concept which could be practically performed in the human mind. In response to an evaluation, a person could manually redact information]. Regarding claim 34, the claim recites the steps of: Identifying…a first categorization for the identifying data; identifying...that an identity graph for the data subject includes the identifying data mapped to the first categorization; identifying…a first data type identifier associated with a first data source that matches the first categorization, wherein the first data type identifier can be used in querying the first data source; identifying…a second categorization for a second piece of data in the first responsive data; identifying…that the identity graph for the data subject includes the second piece of data mapped to the second categorization; identifying… a second data type identifier associated with a second data source that matches the second categorization, wherein the second data type identifier can be used in querying the second data source; identifying…the second categorization for a fourth piece of data found in the second responsive data; [recited at a high level of generality and given the claim its BRI, said steps constitute observation and evaluation concepts which could be practically performed in the human mind] determining, by the computing hardware and based on the identity graph, that the fourth piece of data found in the second responsive data does not match the second piece of data; [recited at a high level of generality and given the claim its BRI, it constitutes an evaluation concept which could be practically performed in the human mind] and responsive to determining that the fourth piece of data found in the second responsive data does not match the second piece of data, removing, by the computing hardware, the fourth piece of data from the second responsive data. [recited at a high level of generality and given the claim its BRI, it constitutes a concept which could be practically performed in the human mind. In response to an evaluation, a person could manually remove information]. The above-mentioned steps are processes that, under its broadest reasonable interpretation, covers performance of the limitation in the mind. A human can mentally identify different personal data and categories and determine second data associated with other entities/persons and redact it. That is, other than reciting computing hardware, a storage medium, and/or processing hardware, nothing in the claim element precludes the step from practically being performed in a human mind or with pen and paper. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind, then it falls within the “Mental Processes” grouping of abstract ideas (concepts performed in the human mind including an observation, evaluation, judgment, and opinion). Prong 2: This judicial exception is not integrated into a practical application. Claims 21, 28, and 34 recite the additional steps of: receiving, by computing hardware, a request for target data for a data subject, wherein the request comprises identifying data for the data subject; querying, by the computing hardware, based on the data type identifier, and via the one or more source-specific access methods stored in the identity graph, the [first or second] data source using the identifying data; and receiving, by the computing hardware, from the data source responsive data for the data subject, wherein the responsive data comprises a second and/or third piece of data matching the identifying data. These steps at a high level of generality are considered as insignificant extra pre-solution activities of data gathering, data input, searching data and receiving results. See MPEP 2106.04(d) and 2106.05(g). Moreover, the limitation of “wherein the identity graph is maintained in a non-transitory, computer-readable medium” also recited at a high level of generality and is considered as an insignificant extra pre-solution activity of storing data. See MPEP 2106.04(d) and 2106.05(g). Furthermore, claims 21, 28, and 34 recites generic computer components (e.g., computing hardware, a storage medium, and/or processing hardware) to implement the steps of the invention. Said generic computer components are recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using a generic computer component and considered to be insignificant extra solution activities. Accordingly, these additional elements do not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. The claim is directed to an abstract idea. See MPEP 2106.04(d) and 2106.05(g). Step 2B: The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. Claims 21, 28, and 34 recite the additional steps of: receiving, by computing hardware, a request for target data for a data subject, wherein the request comprises identifying data for the data subject; querying, by the computing hardware, based on the data type identifier, and via the one or more source-specific access methods stored in the identity graph, the [first or second] data source using the identifying data; and receiving, by the computing hardware, from the data source responsive data for the data subject, wherein the responsive data comprises a second and/or third piece of data matching the identifying data. These steps at a high level of generality are considered as well-understood and routine computer activities of data gathering, data input, searching data and receiving results. See MPEP 2106.04(d) and 2106.05(g). Moreover, the limitation of “wherein the identity graph is maintained in a non-transitory, computer-readable medium” also recited at a high level of generality and is considered as a well-understood and routine computer activity of storing data. See MPEP 2106.04(d) and 2106.05(g). Furthermore, claims 21, 28, and 34 recites generic computer components (e.g., computing hardware, a storage medium, and/or processing hardware) to implement the steps of the invention. Said generic computer components are recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using a generic computer component and considered to be well- understood and routine computer activities. Therefore, the claims are not patent eligible. Regarding dependent claims 22-27, 29-33, and 35-40, the dependent claims also lack additional elements that sufficient to integrate the judicial exception into a practical application or amount to significantly more than abstract idea found in the independent claims. The dependent claims further recite the additional step for “determining…”, “identifying…”, “generating the identity graph…”, and/or “generating metadata...” that could be performed mentally failing to integrate the judicial exception into a practical application or to amount significantly to more than abstract idea. Moreover, the dependent claims additional steps for generic computer functions of “scanning the data sources”, “generating a graphical user interface…”, and/or “transmitting an instruction…” which are considered to be insignificant extra solution and/or well-understood routine computer routines of searching data, displaying data, and send data over a network failing to integrate the judicial exception into a practical application or to amount significantly to more than an abstract idea. Conclusion 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 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 mailing date of this final action. Points of Contact Any inquiry concerning this communication or earlier communications from the examiner should be directed to HARES JAMI whose telephone number is (571)270-1291. The examiner can normally be reached M-F 9:00a-5:00p. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Amy Ng can be reached at (571) 270-1698. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /Hares Jami/ Primary Examiner, Art Unit 2164 09/04/2026
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Prosecution Timeline

Show 11 earlier events
Sep 22, 2025
Response Filed
Oct 21, 2025
Final Rejection mailed — §101
Dec 22, 2025
Response after Non-Final Action
Feb 23, 2026
Request for Continued Examination
Mar 04, 2026
Response after Non-Final Action
Apr 17, 2026
Non-Final Rejection mailed — §101
Jul 07, 2026
Response Filed
Sep 09, 2026
Final Rejection mailed — §101 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

7-8
Expected OA Rounds
73%
Grant Probability
99%
With Interview (+29.4%)
3y 1m (~0m remaining)
Median Time to Grant
High
PTA Risk
Based on 707 resolved cases by this examiner. Grant probability derived from career allowance rate.

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