DETAILED ACTION
Notice of Pre-AIA or AIA Status
1. The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . This office action is in response to applicant's communication of December 8, 2025. The rejections are stated below. Claims 1-20 are pending and have been examined.
Continued Examination Under 37 CFR 1.114
2. 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 12/8/2025 has been entered.
Response to Amendment/Arguments
3. Applicant's arguments filed 12/8/2025 concerning 35 U.S.C. 101 have been considered but they are not persuasive. Applicant arguments do not overcome the finding that the claimed invention is directed to an abstract idea and lacks an inventive concept. The controlling legal framework for this analysis is the Supreme Court’s Alice/Mayo two-step test. While the applicant cites the Enfish decision and Example 37 from the USPTO’s eligibility guidance, these do not supersede the Alice analysis. Enfish pertains to claims directed to a specific improvement in computer functionality, which is distinct from the present claims. The present claims are directed to the abstract idea of coordinating and automating a service process, specifically the process of matching a customer with a pre-approved service provider based on eligibility and location, which is a fundamental business practice.
Applicant’s arguments that the claims are not directed to a “method of organizing human activity” are unpersuasive. Claim 1 recites the process of receiving a loss report, verifying policyholder eligibility against rules, filtering a list of pre-authorized repair facilities, and presenting options to the user. This is a form of “commercial or legal interaction” and “managing transactions or relationships,” which are enumerated categories of abstract ideas in the eligibility guidance. The claim’s recitation of a “machine-learning ML model” to perform eligibility checks is linking the use of the judicial exception to a particular technological environment..
Applicant’s description of technical improvements, such as reducing bandwidth or computer resource usage, are merely the inherent results of automating a manual process. The specification describes efficiency benefits but does not describe a specific technical improvement in the functioning of the computer itself. The claim does not recite a new database structure, a specific algorithmic improvement to machine learning, or a novel graphical user interface architecture.
Regarding Step 2A, Prong Two, the additional elements do not integrate the abstract idea into a practical application. The elements, such as receiving specific data fields (VIN, point of impact), generating a query, and prepopulating a form, are data-gathering and data-display steps required for any computerized implementation of this service process. They do not impose a meaningful limit beyond merely instructing one to “apply it” on a computer.
With respect to Step 2B, the claim does not recite an inventive concept. The combination of the recited steps, data input, query generation, eligibility checking using an ML model, filtering, and portal display amounts to an instruction to automate the underlying abstract process using standard computing tools. The recitation of a “trained ML model” is insufficient because the claim provides no details about the model’s architecture, its specific training, or how it represents an improvement over other rule-checking mechanisms. It is simply a black box recited to perform the abstract idea.
The Appeals Review Panel decision referenced by the applicant is not binding precedent and is fact-specific to the claims and specification of that application. In the present case, the claim as a whole is directed to an abstract idea implemented with generic computer technology. Therefore, the rejection under 35 U.S.C. § 101 is sustained.
Claim Rejections - 35 USC § 101
4. 35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
5. Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea of enabling a policyholder of an insurance policy to identify a repair facility in real-time without significantly more.
Claim 9 is directed to a method which is one of the four statutory categories of invention (Step 1: YES).
6. Claim 9 recites “a … for enabling a policyholder of an automobile insurance policy to identify a … in …, the method is implemented by a … comprising at least one … in communication with at least one … the method comprises:
receiving, from a … associated with the policyholder, an initial loss claim filed by the policyholder, including a user device location, a vehicle identification number, a point of impact, and a vehicle drivability indication;
in response to said receiving, … generating a query using (1) a claim identifier associated with the initial loss claim filed by the policyholder, and (ii) a policyholder identifier associated with the policyholder,
retrieving at the least one policyholder insurance data by applying the generated query to an …, the … associated with an insurance provider providing the automobile insurance policy to the policyholder;
training a … to perform eligibility checks using training insurance data, wherein an eligibility check includes applying eligibility rules stored in the … to determine policyholder eligibility based on associated insurance data;
determining whether the policyholder is eligible to receive an insurance vehicle repair by performing an eligibility check by …, using one more of the claim identifier and the policyholder identifier as inputs to the …ML model and receiving an eligibility decision as output from the … ML model;
in response to determining the policyholder is ineligible, preventing access to a … via the … associated with the policyholder;
filtering the list of … using the vehicle identification number and the point of impact from the initial claim data to isolate a plurality of certified repair facilities from the list of select service locations, wherein a certified repair facility is a select service location certified to conduct the insurance vehicle repair of the policyholder to remediate damage related to the point of impact;
prepopulating one or more data fields, with at least some of the retrieved policyholder insurance data, and
… display … a policyholder information portion including the prepopulated one or more data fields and one or more of the certified repair facilities;
receiving, via the …, a selection of a certified repair facility from the one or more certified repair facilities;
and
initiating the insurance vehicle repair by transmitting selection information and at least some of the policyholder insurance data to the selected certified repair facility”.
7. These limitations describe an abstract idea of enabling a policyholder of an insurance policy to identify a repair facility and corresponds to Certain Methods of Organizing Human Activity (commercial or legal interaction and managing transactions or relationships). Accordingly, the claim 9 recites an abstract idea (Step 2A: Prong 1: YES).
8. This judicial exception is not integrated into a practical application. The additional elements, e.g., in real-time, computer system comprising at least one processor in communication with at least one memory, user device, insurance provider database, training a machine-learning model, trained model, re-training the ML model, computing devices, and interface of the certified repair self-service portal do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment. “Specifically, with respect to ‘training a machine-learning model’ and ‘re-training the ML model’, as Applicant has not claimed specific technical details regarding how the model is trained and subsequently re-trained (MPEP 2106.05(f)(1)) the limitations are no more than using a computer to create and then update a model.” Therefore, claim 9 is directed to an abstract idea without a practical application (Step 2A - Prong 2: NO).
9. Claim 9 does not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when considered separately and as an ordered combination, they do not add significantly more (also known as an “inventive concept”) to the exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements amount to no more than mere instructions to apply the exception using a generic computer component (MPEP 2106.05(f)). Accordingly, these additional elements, when considered separately and as an ordered combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Thus, claim 9 is not patent eligible (Step 2B: NO).
10. Claim 10 recites “wherein the policyholder insurance data further includes vehicle repair provisions of the automobile insurance policy as of the date and time the claim identifier is generated” which further define the abstract idea.
11. Claim 11 recites “wherein the policyholder insurance data further includes a vehicle material and part list based on the vehicle identification number” which further define the abstract idea.
12. Claim 12 recites “wherein the policyholder insurance data further includes a vehicle structural or engine damage indication based on the point of impact” which further define the abstract idea.
13. Claim 13 recites “verifying that the policyholder is eligible to receive an insurance vehicle repair by determining that a pay code for the initial loss claim has been generated and …” which further define the abstract idea. The claim includes “stored within the memory” as an additional element. However, the additional element does no more than link the judicial exception to a particular technological environment. Specifically, with respect to “stored within the memory”, this represents use of a computer (e.g. receive, store or transmit data) to perform an economic or other task and does not provide a practical application (MPEP 2106.05(f)(2)). Therefore, as the additional elements do not provide a practical application they do not improve the functioning of a computer or to any other technology or technical field.
14. Claim 14 recites “wherein the initial loss claim further includes …, the method comprising: determine, … an extent of damage to the vehicle, and further filtering the list of select service location based upon the extent of damage to the vehicle” which further define the abstract idea. The claim includes “one or more images” as additional elements. However, the additional elements do no more than link the judicial exception to a particular technological environment.
15. Claim 15 recites “further comprising updating a claim file of the policyholder to include the certified repair facility selection, and wherein the claim file contains information associated with the initial loss claim” which further define the abstract idea.
16. Claim 16 recites “generating a file note for a claims handler, wherein the file note includes the certified repair facility selection” which further define the abstract idea.
17. Claims 1 and 17 also recite the abstract idea of enabling a policyholder of an insurance policy to identify a repair facility and corresponds to Certain Methods of Organizing Human Activity (commercial or legal interaction and managing transactions or relationships). Claim 1 includes the additional elements of “a computer system comprising at least one processor in communication with at least one memory, real-time, user device, insurance provider database, train a machine-learning model, trained model, re-train the ML model, computing devices, and interface of the certified repair self-service portal”. Claim 17 includes the additional elements of “at least one non-transitory computer-readable storage media having computer-executable instructions embodied thereon that when executed by at least processor, user device, insurance provider database, train a machine-learning model, trained model, re-train the ML model, computing devices, and interface of the certified repair self-service portal”. The additional elements of claims 1 and 17 do no more than serve as a tool to implement the abstract idea and/or provide a particular technological environment. There is no improvement to the functioning of a computer, or to any other technology or technical field (MPEP 2106.05(a).
18. Claim 2 recites “wherein the policyholder insurance data further includes vehicle repair provisions of the automobile insurance policy as of the date and time the claim identifier is generated” which further define the abstract idea. The claim includes “CRSS computer system” as an additional element. However, the additional element does no more than link the judicial exception to a particular technological environment.
19. Claim 3 recites “wherein the policyholder insurance data further includes a vehicle material and part list based on the vehicle identification number” which further define the abstract idea. The claim includes “CRSS computer system” as an additional element. However, the additional element does no more than link the judicial exception to a particular technological environment.
20. Claim 4 recites “wherein the initial loss claim further includes a vehicle structural or engine damage indication based on the point of impact” which further define the abstract idea. The claim includes “CRSS computer system” as an additional element. However, the additional element does no more than link the judicial exception to a particular technological environment.
21. Claim 5 recites “verifying that the policyholder is eligible to receive an insurance vehicle repair by determining that a pay code for the initial loss claim has been generated and …” which further define the abstract idea. The claim includes “wherein said processor is further programmed” and “stored within the memory” as an additional element. However, the additional element does no more than link the judicial exception to a particular technological environment. Specifically, with respect to “stored within the memory”, this represents use of a computer (e.g. receive, store or transmit data) to perform an economic or other task and does not provide a practical application (MPEP 2106.05(f)(2)). Therefore, as the additional elements do not provide a practical application they do not improve the functioning of a computer or to any other technology or technical field.
22. Claim 6 recites “wherein the initial loss claim further includes … said … to: determine, using the …,an extent of damage to the vehicle, and further filer the list of select service locations based upon the extent of damage to the vehicle” which further define the abstract idea. The claim includes “CRSS computer system, one or more images” as additional elements. However, the additional elements do no more than link the judicial exception to a particular technological environment.
23. Claim 7 recites “to update a claim file of the policyholder to include the certified repair facility selection, and wherein the claim file contains information associated with the initial loss claim” which further define the abstract idea. The claim includes “CRSS computer system” and “wherein said processor is further programmed” as an additional elements. However, the additional elements does no more than link the judicial exception to a particular technological environment.
24. Claim 8 recites “generate a file note for a claims handler, wherein the file note includes the certified repair facility selection” which further define the abstract idea. The claim includes “CRSS computer system” and “wherein said processor is further programmed” as an additional elements. However, the additional elements does no more than link the judicial exception to a particular technological environment.
25. Claim 18 recites “wherein the policyholder insurance data further includes at least one of: (i) vehicle repair provisions of the automobile insurance policy as of the date and time the claim identifier is generated, (ii) a vehicle material and part list based on the vehicle identification number” which further define the abstract idea. The claim includes “non-transitory computer-readable storage media” as an additional element. However, the additional element does no more than link the judicial exception to a particular technological environment.
26. Claim 19 recites “verify that the policyholder is eligible to receive an insurance vehicle repair by determining that a pay code for the initial loss claim has been generated and stored within the memory” which further define the abstract idea. The claim includes “non-transitory computer-readable storage media” as an additional element. However, the additional element does no more than link the judicial exception to a particular technological environment.
27. Claim 20 recites “wherein the initial loss claim further includes …, the method comprising: determine, … an extent of damage to the vehicle, and further filtering the list of select service location based upon the extent of damage to the vehicle” which further define the abstract idea. The claim includes “non-transitory computer-readable storage media and one or more images” as an additional elements. However, the additional elements do no more than link the judicial exception to a particular technological environment.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to KEVIN T POE whose telephone number is (571)272-9789. The examiner can normally be reached on Monday-Friday 9:30am through 6pm EST.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Ryan Donlon can be reached on 571-270-3602. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/K.T.P/Examiner, Art Unit 3692 /KEVIN T POE/
/RYAN D DONLON/Supervisory Patent Examiner, Art Unit 3692 January 30, 2026