DETAILED ACTION
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 .
Claim Rejections - 35 U.S.C. §101
2. 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 – 6, 8, 9, 12 and 23 - 27 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature , a natural phenomenon or an abstract idea.) without significantly more. The totality of the claims recite a combination of mental processes and mathematical concepts. The claims are analyzed for subject matter eligibility using a two-part subject matter eligibility analysis (MPEP 2016).
Independent claim 1 recites, “A method comprising:…” and as such falls within one of the statutory categories of patentability.
Step 2a Prong 1
Independent claim 1 is however rejected under 35 U.S.C. 101 because the
claimed invention recites an abstract idea without significantly more. The claim
recites, “assigning, via the at least one processor, a unique identifier to the entity, the unique identifier comprising: (a) a domain portion defining a jurisdiction of the entity”, “(b) a sub-domain portion comprising: (i) a designation of an entity type of the entity”, “(ii) an agency code for a legal authority holding a registration for the entity within the jurisdiction; and (iii) a date of registration or formation of the entity”, “and (c) a registration identifier portion of the entity in the jurisdiction, wherein the unique identifier complies with ISO 8000-116 standard when the entity is a legal entity and has been granted legal status by a governing body of a nation, state, or community, and wherein components of the unique identifier are in an order consisting of: the domain portion, followed by the designation of the entity type, followed by the agency code, followed by the date of registration or formation, followed by the registration identifier portion, wherein the domain portion and the sub-domain portion are separated by a period ("."), the sub-domain portion and the registration identifier portion are separated by a colon (":")”, “validating, via the at least one processor, the unique identifier by (A) comparing the unique identifier against a defined structure using regular expressions and (B) by comparing data elements of the unique identifier against authoritative data sources to validate: (i) values in the domain portion against predefined jurisdictions; (ii) the sub-domain portion against predefined valid values for entity types; (iii) the agency code against registration agency codes for the jurisdiction” and “and (iv) that a date component of the unique identifier is a valid date.”
These limitations of assigning a unique identifier comprising component parts that comply with an ISO standard … and a subsequent validation of a unique identifier …” under its broadest reasonable interpretation, covers certain methods of organizing human activity and describes concepts related to commercial or legal interactions (including agreements in the form of contracts, legal obligations, advertising, marketing or sales activities or behaviors, and business relations. The Supreme Court has identified a number of concepts falling within the "certain methods of organizing human activity" grouping as abstract ideas.
Registering an organization identifier in accordance with ISO 8000-116 constitutes a legal and commercial interaction because the registration associates a business entity with an identifier derived from or traceable to an official registration maintained by a competent governmental or authorize registry. The registration records or verifies the entity’s legally recognized identity, jurisdiction, registry source, and registration number, thereby facilitating recognition of the entity in commercial transactions, compliance processes, and intergovernmental business relationships.
Thus the aforementioned grouping of steps falls within the enumerated group of abstract idea comprising certain methods of organizing human activity. See MPEP § 2106.04(a)(2), subsection II.
Step 2A Prong 2
This judicial exception is not integrated into a practical application. In particular, the claim only recites the additional elements of, “receiving, via at least one processor of a computer system, a name of an entity and associated information about the entity;”, “executing, via the at least one processor, a Globally Unique Identifier (GUID) hash function on the unique identifier, resulting in a unique hash code which is a 128-bit integer number;”, “storing the unique hash code along with the name of the entity in a database for fast retrieval of information about the entity, the database being a cloud-based storage system;”, “receiving, at the computer system, a query, the query having a form of "Who is" and the unique hash code;”, “sending, via the at least one processor, the query and the unique hash code to the database;” and “receiving, from the database in response to the query and the unique hash code, the name of the entity and information about the entity, the information comprising an entity status of the entity, and wherein the (1) sending of the query and the unique hash code and (2) the receiving of the name of the entity and the information about the entity (a) use multiple Application Program Interface (API) endpoints, and (b) occur via batch transmissions.”
First, the step of “executing, via the at least one processor, a Globally Unique Identifier (GUID) hash function on the unique identifier, resulting in a unique hash code which is a 128-bit integer number;” is an abstract idea and falls within the mathematical concepts – mathematical relationships, mathematical formulas or equations, mathematical calculations (see MPEP § 2106.04(a)(2), subsection I) grouping.
An abstract idea upon another abstract idea is still an abstract idea, thus the additional claim elements merely recite another judicial exception, that is insufficient to integrate the judicial exception into a practical application. See, e.g., RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327, 122 USPQ2d 1377 (Fed. Cir. 2017) ("Adding one abstract idea (math) to another abstract idea (encoding and decoding) does not render the claim non-abstract"); Genetic Techs. v. Merial LLC, 818 F.3d 1369, 1376, 118 USPQ2d 1541, 1546 (Fed. Cir. 2016) (eligibility "cannot be furnished by the unpatentable law of nature (or natural phenomenon or abstract idea) itself.").
Second, the steps of, “receiving, via at least one processor of a computer system, a name of an entity and associated information about the entity;” “storing the unique hash code along with the name of the entity in a database for fast retrieval of information about the entity, the database being a cloud-based storage system;”, “receiving, at the computer system, a query, the query having a form of "Who is" and the unique hash code;”, “sending, via the at least one processor, the query and the unique hash code to the database;” and “receiving, from the database in response to the query and the unique hash code, the name of the entity and information about the entity, the information comprising an entity status of the entity, and wherein the (1) sending of the query and the unique hash code and (2) the receiving of the name of the entity and the information about the entity (a) use multiple Application Program Interface (API) endpoints, and (b) occur via batch transmissions” are mere data gathering steps and constitute insignificant extra-solution activities that are not integrated into a practical application. These steps constitute an abstract idea.
The courts have held that adding insignificant extra-solution activity to the judicial exception, e.g., mere data gathering in conjunction with a law of nature or abstract idea such as a step of obtaining information about credit card transactions so that the information can be analyzed by an abstract mental process, as discussed in CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375, 99 USPQ2d 1690, 1694 (Fed. Cir. 2011) (see MPEP § 2106.05(g) have found not to be enough to qualify as "significantly more" when recited in a claim with a judicial exception. Accordingly, these additional elements of “receiving, … a name of an entity and associated information, storing the unique hash code along with the name of the entity in a database …;”, “receiving, … a query, …;”, “sending, …the query and the unique hash code to the database;” and “receiving, from the database in response to the query and the unique hash code, … “” 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
Step 2B
The additional elements of “receiving, via at least one processor of a computer system, a name of an entity and associated information about the entity;” “storing the unique hash code along with the name of the entity in a database for fast retrieval of information about the entity, the database being a cloud-based storage system;”, “receiving, at the computer system, a query, the query having a form of "Who is" and the unique hash code;”, “sending, via the at least one processor, the query and the unique hash code to the database;” and “receiving, from the database in response to the query and the unique hash code, the name of the entity and information about the entity, the information comprising an entity status of the entity, and wherein the (1) sending of the query and the unique hash code and (2) the receiving of the name of the entity and the information about the entity (a) use multiple Application Program Interface (API) endpoints, and (b) occur via batch transmissions” are insignificant extra-solution activities. The courts have held simply appending well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception, e.g., a claim to an abstract idea requiring no more than a generic computer to perform generic computer functions that are well-understood, routine and conventional activities previously known to the industry, as discussed in Alice Corp., 573 U.S. at 225, 110 USPQ2d at 1984 (see MPEP § 2106.05(d)) do not qualify as "significantly more" when recited in a claim with a judicial exception.
Reference is made to Storer et al., (United States Patent Publication Number 2023/0133610) which teaches, “the retrieval of an object in a cloud-based storage environment, wherein this auxiliary object can be assigned an identifier that not only uniquely identifies the auxiliary object but also identifies, within the identifier itself, the relationship to the first object. In Fig. 5, steps are provided where, Generating the identifier for the auxiliary object can comprise hashing 520 the entity identifier for the first object and adding 525 the hash of the entity identifier for the first object to the unique name for the auxiliary object, The generated identifier for the auxiliary object can further comprise an identifier of an entity type for the entity identifier and/or an indication of a namespace for an owner of the first object. And The SCS 435 can store 530 the generated identifier for the auxiliary object in a table 440. The SCS 435 can also store 535 the auxiliary object in the data repository using the one or more backend services 420 and 425. [0059] – [0060].
These claim limitations, when considered individually and in combination and under their broadest reasonable interpretation, covers mental processes. If a claim limitation, under its broadest reasonable interpretation, covers mental processes , then it falls within the “Mental Process” grouping of abstract ideas. Accordingly, the claims recites an abstract idea. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Thus, the claim is not patent eligible.
Claim 2 is rejected under 35 U.S.C. 101 because the claimed invention is
directed to an abstract idea without significantly more. The claim depends from
independent claim 1 and does not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Step 2A/2B
The claim recites, “wherein the domain portion complies with ISO 3166-1 and ISO 3166-2 standards.” Evaluating the constituent portions of an entity and concluding a specific portion complies with an standard is a mental process that constitutes an abstract idea.
An abstract idea upon another abstract idea is still an abstract idea, thus the additional claim elements merely recite another judicial exception, that is insufficient to integrate the judicial exception into a practical application. See, e.g., RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327, 122 USPQ2d 1377 (Fed. Cir. 2017) ("Adding one abstract idea (math) to another abstract idea (encoding and decoding) does not render the claim non-abstract"); Genetic Techs. v. Merial LLC, 818 F.3d 1369, 1376, 118 USPQ2d 1541, 1546 (Fed. Cir. 2016) (eligibility "cannot be furnished by the unpatentable law of nature (or natural phenomenon or abstract idea) itself.").
These claim limitations, under their broadest reasonable interpretation, covers mental processes. If a claim limitation, under its broadest reasonable interpretation, covers mental processes , then it falls within the “Mental Process” grouping of abstract ideas. Accordingly, the claims recites an abstract idea. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Thus, the claim is not patent eligible.
Claim 3 is rejected under 35 U.S.C. 101 because the claimed invention is
directed to an abstract idea without significantly more. The claim depends from
independent claim 1 and does not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Step 2A/2B
The claim recites, “wherein the jurisdiction of the entity comprises (1) a jurisdiction country of the entity and (2) a jurisdiction state or region in the jurisdiction country of the entity.” Evaluating the composition of an entity and concluding a specific part refers to jurisdictional data is a mental process that constitutes an abstract idea.
An abstract idea upon another abstract idea is still an abstract idea, thus the additional claim elements merely recite another judicial exception, that is insufficient to integrate the judicial exception into a practical application. See, e.g., RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327, 122 USPQ2d 1377 (Fed. Cir. 2017) ("Adding one abstract idea (math) to another abstract idea (encoding and decoding) does not render the claim non-abstract"); Genetic Techs. v. Merial LLC, 818 F.3d 1369, 1376, 118 USPQ2d 1541, 1546 (Fed. Cir. 2016) (eligibility "cannot be furnished by the unpatentable law of nature (or natural phenomenon or abstract idea) itself.").
These claim limitations, under their broadest reasonable interpretation, covers mental processes. If a claim limitation, under its broadest reasonable interpretation, covers mental processes , then it falls within the “Mental Process” grouping of abstract ideas. Accordingly, the claims recites an abstract idea. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Thus, the claim is not patent eligible.
Claim 4 is rejected under 35 U.S.C. 101 because the claimed invention is
directed to an abstract idea without significantly more. The claim depends from
dependent claim 3 and does not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Step 2A/2B
The claim recites, “wherein the jurisdiction country complies with ISO 3166-1 standard and the jurisdiction state or region complies with ISO 3166-2 standard.” Evaluating the composition of an entity and concluding a specific part that refers to jurisdictional data complies with an applicable standard is a mental process that constitutes an abstract idea.
An abstract idea upon another abstract idea is still an abstract idea, thus the additional claim elements merely recite another judicial exception, that is insufficient to integrate the judicial exception into a practical application. See, e.g., RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327, 122 USPQ2d 1377 (Fed. Cir. 2017) ("Adding one abstract idea (math) to another abstract idea (encoding and decoding) does not render the claim non-abstract"); Genetic Techs. v. Merial LLC, 818 F.3d 1369, 1376, 118 USPQ2d 1541, 1546 (Fed. Cir. 2016) (eligibility "cannot be furnished by the unpatentable law of nature (or natural phenomenon or abstract idea) itself.").
These claim limitations, under their broadest reasonable interpretation, covers mental processes. If a claim limitation, under its broadest reasonable interpretation, covers mental processes , then it falls within the “Mental Process” grouping of abstract ideas. Accordingly, the claims recites an abstract idea. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Thus, the claim is not patent eligible.
Claim 5 is rejected under 35 U.S.C. 101 because the claimed invention is
directed to an abstract idea without significantly more. The claim depends from
independent claim 1 and does not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Step 2A/2B
The claim recites, “wherein the registration identifier portion for the jurisdiction comprises a plurality of characters or numbers, or both.” Evaluating the composition of an entity and concluding a specific part that refers to jurisdictional data is potentially made up of alpha-numeric characters constitutes an abstract idea.
An abstract idea upon another abstract idea is still an abstract idea, thus the additional claim elements merely recite another judicial exception, that is insufficient to integrate the judicial exception into a practical application. See, e.g., RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327, 122 USPQ2d 1377 (Fed. Cir. 2017) ("Adding one abstract idea (math) to another abstract idea (encoding and decoding) does not render the claim non-abstract"); Genetic Techs. v. Merial LLC, 818 F.3d 1369, 1376, 118 USPQ2d 1541, 1546 (Fed. Cir. 2016) (eligibility "cannot be furnished by the unpatentable law of nature (or natural phenomenon or abstract idea) itself.").
These claim limitations, under their broadest reasonable interpretation, covers mental processes. If a claim limitation, under its broadest reasonable interpretation, covers mental processes , then it falls within the “Mental Process” grouping of abstract ideas. Accordingly, the claims recites an abstract idea. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Thus, the claim is not patent eligible.
Claim 6 is rejected under 35 U.S.C. 101 because the claimed invention is
directed to an abstract idea without significantly more. The claim depends from
independent claim 1 and does not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Step 2A/2B
The claim recites, “wherein the registration identifier portion comprises a plurality of characters or numbers, or both.” Evaluating the composition of an entity and concluding a registration portion is potentially made up of alpha-numeric characters constitutes an abstract idea.
An abstract idea upon another abstract idea is still an abstract idea, thus the additional claim elements merely recite another judicial exception, that is insufficient to integrate the judicial exception into a practical application. See, e.g., RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327, 122 USPQ2d 1377 (Fed. Cir. 2017) ("Adding one abstract idea (math) to another abstract idea (encoding and decoding) does not render the claim non-abstract"); Genetic Techs. v. Merial LLC, 818 F.3d 1369, 1376, 118 USPQ2d 1541, 1546 (Fed. Cir. 2016) (eligibility "cannot be furnished by the unpatentable law of nature (or natural phenomenon or abstract idea) itself.").
These claim limitations, under their broadest reasonable interpretation, covers mental processes. If a claim limitation, under its broadest reasonable interpretation, covers mental processes , then it falls within the “Mental Process” grouping of abstract ideas. Accordingly, the claims recites an abstract idea. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Thus, the claim is not patent eligible
Claim 8 is rejected under 35 U.S.C. 101 because the claimed invention is
directed to an abstract idea without significantly more. The claim depends from
independent claim 1 and does not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Step 2A/2B
The claim recites, “wherein the domain portion and the sub-domain portion form a prefix of the unique identifier, and the registration identifier portion forms a suffix of the unique identifier.” Evaluating the composition of an entity and concluding it is an aggregation or concatenation of constituent parts forming an prefix and suffix constitutes an abstract idea.
An abstract idea upon another abstract idea is still an abstract idea, thus the additional claim elements merely recite another judicial exception, that is insufficient to integrate the judicial exception into a practical application. See, e.g., RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327, 122 USPQ2d 1377 (Fed. Cir. 2017) ("Adding one abstract idea (math) to another abstract idea (encoding and decoding) does not render the claim non-abstract"); Genetic Techs. v. Merial LLC, 818 F.3d 1369, 1376, 118 USPQ2d 1541, 1546 (Fed. Cir. 2016) (eligibility "cannot be furnished by the unpatentable law of nature (or natural phenomenon or abstract idea) itself.").
These claim limitations, under their broadest reasonable interpretation, covers mental processes. If a claim limitation, under its broadest reasonable interpretation, covers mental processes , then it falls within the “Mental Process” grouping of abstract ideas. Accordingly, the claims recites an abstract idea. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Thus, the claim is not patent eligible
Claim 9 is rejected under 35 U.S.C. 101 because the claimed invention is
directed to an abstract idea without significantly more. The claim depends from
dependent claim 8 and does not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Step 2A/2B
The claim recites, “wherein the prefix and the suffix of the unique identifier are separated by a colon (":") character.” Evaluating the composition of an entity and concluding it is an aggregation or concatenation of constituent parts forming an prefix and suffix constitutes an abstract idea.
An abstract idea upon another abstract idea is still an abstract idea, thus the additional claim elements merely recite another judicial exception, that is insufficient to integrate the judicial exception into a practical application. See, e.g., RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327, 122 USPQ2d 1377 (Fed. Cir. 2017) ("Adding one abstract idea (math) to another abstract idea (encoding and decoding) does not render the claim non-abstract"); Genetic Techs. v. Merial LLC, 818 F.3d 1369, 1376, 118 USPQ2d 1541, 1546 (Fed. Cir. 2016) (eligibility "cannot be furnished by the unpatentable law of nature (or natural phenomenon or abstract idea) itself.").
These claim limitations, under their broadest reasonable interpretation, covers mental processes. If a claim limitation, under its broadest reasonable interpretation, covers mental processes , then it falls within the “Mental Process” grouping of abstract ideas. Accordingly, the claims recites an abstract idea. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Thus, the claim is not patent eligible
Claim 12 is rejected under 35 U.S.C. 101 because the claimed invention is
directed to an abstract idea without significantly more. The claim depends from
independent claim 1 and does not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Step 2A/2B
The claim recites, “wherein the unique identifier further includes another portion including any one of a metropolitan area, a county, a city, a borough, or a region within a jurisdiction country of the entity.” Evaluating the constituent portions of an identifier and concluding a specific portion includes locality data is a mantal process and therefore an abstract idea.
An abstract idea upon another abstract idea is still an abstract idea, thus the additional claim elements merely recite another judicial exception, that is insufficient to integrate the judicial exception into a practical application. See, e.g., RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327, 122 USPQ2d 1377 (Fed. Cir. 2017) ("Adding one abstract idea (math) to another abstract idea (encoding and decoding) does not render the claim non-abstract"); Genetic Techs. v. Merial LLC, 818 F.3d 1369, 1376, 118 USPQ2d 1541, 1546 (Fed. Cir. 2016) (eligibility "cannot be furnished by the unpatentable law of nature (or natural phenomenon or abstract idea) itself.").
These claim limitations, under their broadest reasonable interpretation, covers mental processes. If a claim limitation, under its broadest reasonable interpretation, covers mental processes , then it falls within the “Mental Process” grouping of abstract ideas. Accordingly, the claims recites an abstract idea. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Thus, the claim is not patent eligible.
Independent claim 23 corresponds to independent claim 1 but for the recitation of, “A system comprising: a computer system configured to:.” These claim limitations, under their broadest reasonable interpretation, covers mental processes but for the recitation of “A system comprising: a computer system configured to:.” That is, other than reciting “A system comprising: a computer system configured to:.” nothing in the claim element precludes the step from practically being performed in the mind. If a claim limitation, under its broadest reasonable interpretation, covers mental processes , then it falls within the “Mental Process” grouping of abstract ideas. Accordingly, the claims recites an abstract idea. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Thus, the claim is not patent eligible.
Claim 24 is rejected under 35 U.S.C. 101 because the claimed invention is
directed to an abstract idea without significantly more. The claim depends from
independent claim 23 and does not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Step 2A/2B
The claim recites, “wherein the unique identifier further includes another portion disposed between the domain portion and the sub-domain portion, the another portion further refining the jurisdiction of the entity.” Evaluating the constituent portions of an entity and concluding a positional constituent refines the entity is a mental process and therefore an abstract idea.
An abstract idea upon another abstract idea is still an abstract idea, thus the additional claim elements merely recite another judicial exception, that is insufficient to integrate the judicial exception into a practical application. See, e.g., RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327, 122 USPQ2d 1377 (Fed. Cir. 2017) ("Adding one abstract idea (math) to another abstract idea (encoding and decoding) does not render the claim non-abstract"); Genetic Techs. v. Merial LLC, 818 F.3d 1369, 1376, 118 USPQ2d 1541, 1546 (Fed. Cir. 2016) (eligibility "cannot be furnished by the unpatentable law of nature (or natural phenomenon or abstract idea) itself.").
These claim limitations, under their broadest reasonable interpretation, covers mental processes. If a claim limitation, under its broadest reasonable interpretation, covers mental processes , then it falls within the “Mental Process” grouping of abstract ideas. Accordingly, the claims recites an abstract idea. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Thus, the claim is not patent eligible.
Claim 25 is rejected under 35 U.S.C. 101 because the claimed invention is
directed to an abstract idea without significantly more. The claim depends from
independent claim 23 and does not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Step 2A/2B
The claim recites, “wherein said database is configured to receive a query from a client computer to provide the information about the entity using the unique identifier.” A database retrieving data based on a received query is mere data gathering and as such an insignificant extra solution activity and therefore an abstract idea.
An abstract idea upon another abstract idea is still an abstract idea, thus the additional claim elements merely recite another judicial exception, that is insufficient to integrate the judicial exception into a practical application. See, e.g., RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327, 122 USPQ2d 1377 (Fed. Cir. 2017) ("Adding one abstract idea (math) to another abstract idea (encoding and decoding) does not render the claim non-abstract"); Genetic Techs. v. Merial LLC, 818 F.3d 1369, 1376, 118 USPQ2d 1541, 1546 (Fed. Cir. 2016) (eligibility "cannot be furnished by the unpatentable law of nature (or natural phenomenon or abstract idea) itself.").
These claim limitations, under their broadest reasonable interpretation, covers mental processes. If a claim limitation, under its broadest reasonable interpretation, covers mental processes , then it falls within the “Mental Process” grouping of abstract ideas. Accordingly, the claims recites an abstract idea. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Thus, the claim is not patent eligible
Claim 26 is rejected under 35 U.S.C. 101 because the claimed invention is
directed to an abstract idea without significantly more. The claim depends from
independent claim 23 and does not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Step 2A/2B
The claim recites, “wherein the sub-domain portion has an order of:(1) the designation of the entity type;(2) the agency code; and(3) the date of registration or formation.” Evaluating the relational position of constituent parts in an entity is an observation that comprises a mental process and as such an abstract idea.
An abstract idea upon another abstract idea is still an abstract idea, thus the additional claim elements merely recite another judicial exception, that is insufficient to integrate the judicial exception into a practical application. See, e.g., RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327, 122 USPQ2d 1377 (Fed. Cir. 2017) ("Adding one abstract idea (math) to another abstract idea (encoding and decoding) does not render the claim non-abstract"); Genetic Techs. v. Merial LLC, 818 F.3d 1369, 1376, 118 USPQ2d 1541, 1546 (Fed. Cir. 2016) (eligibility "cannot be furnished by the unpatentable law of nature (or natural phenomenon or abstract idea) itself.").
These claim limitations, under their broadest reasonable interpretation, covers mental processes. If a claim limitation, under its broadest reasonable interpretation, covers mental processes , then it falls within the “Mental Process” grouping of abstract ideas. Accordingly, the claims recites an abstract idea. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Thus, the claim is not patent eligible
Claim 27 is rejected under 35 U.S.C. 101 because the claimed invention is
directed to an abstract idea without significantly more. The claim depends from
independent claim 1 and does not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Step 2A/2B
The claim recites, “wherein the sub-domain portion has an order of:(1) the designation of the entity type;(2) the agency code; and(3) the date of registration or formation.” Evaluating the relational position of constituent parts in an entity is an observation that comprises a mental process and as such an abstract idea.
An abstract idea upon another abstract idea is still an abstract idea, thus the additional claim elements merely recite another judicial exception, that is insufficient to integrate the judicial exception into a practical application. See, e.g., RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327, 122 USPQ2d 1377 (Fed. Cir. 2017) ("Adding one abstract idea (math) to another abstract idea (encoding and decoding) does not render the claim non-abstract"); Genetic Techs. v. Merial LLC, 818 F.3d 1369, 1376, 118 USPQ2d 1541, 1546 (Fed. Cir. 2016) (eligibility "cannot be furnished by the unpatentable law of nature (or natural phenomenon or abstract idea) itself.").
These claim limitations, under their broadest reasonable interpretation, covers mental processes. If a claim limitation, under its broadest reasonable interpretation, covers mental processes , then it falls within the “Mental Process” grouping of abstract ideas. Accordingly, the claims recites an abstract idea. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Thus, the claim is not patent eligible
Reason for Not Applying Prior Art
3. The following limitations in independent claims 1 and 23 were searched for but notwithstanding, relevant prior art was not found that taught each and every limitation, “assigning, via the at least one processor, a unique identifier to the entity, the unique identifier comprising:(a) a domain portion defining a jurisdiction of the entity;(b) a sub-domain portion comprising: (i) a designation of an entity type of the entity; (ii) an agency code for a legal authority holding a registration for the entity within the jurisdiction; and (iii) a date of registration or formation of the entity; and (c) a registration identifier portion of the entity in the jurisdiction; and wherein components of the unique identifier are in an order consisting of: the domain portion, followed by the designation of the entity type, followed by the agency code, followed by the date of registration or formation, followed by the registration identifier portion, validating, via the at least one processor, the unique identifier by (A) comparing the unique identifier against a defined structure using regular expressions and (B) by comparing data elements of the unique identifier against authoritative data sources to validate: (i) values in the domain portion against predefined jurisdictions; (ii) the sub-domain portion against predefined valid values for entity types; (iii) the agency code against registration agency codes for the jurisdiction; and (iv) that a date component of the unique identifier is a valid date”
Subsequent dependent claims inherit the same conclusion.
Conclusion
4. The prior art made of record and not relied upon is considered pertinent to
applicant's disclosure.
ALEI: The Authoritative Legal Entity Identifier 2018 teaches, “The ALEI is simply the identifier code that results from the combination of the registration place and the registration number. Organizations simply combine the ISO code for their place of incorporation with the
registration number assigned at birth or incorporation” Page 3
5. Any inquiry concerning this communication or earlier communications from the
examiner should be directed to Kweku Halm whose telephone number is (469) 295-
9144. The examiner can normally be reached on 7:30AM - 5:30PM Mon - Thur. If
attempts to reach the examiner by telephone are unsuccessful, the examiner's
supervisor, Sanjiv Shah can be reached on (571) 272-4098. The fax phone
number for the organization where this application or proceeding is assigned is 571-273-
8300.
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(EBC) at 866-217-9197 (toll-free).
/KWEKU WILLIAM HALM/Examiner, Art Unit 2166
/SANJIV SHAH/Supervisory Patent Examiner, Art Unit 2166
