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 .
Status of Claims
This is in reply to communication filed on 04/20/2026.
Claims 1, 11 and 20 have been amended.
Claims 1-20 are currently pending and have been examined.
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 05/12/2026 has been entered.
Response to Arguments
Regarding 35 USC § 101 rejection:
Applicant argument submitted under the title “CLAIM REJECTIONS UNDER 35 U.S.C. § 101” in pages 9-10.
Applicant's arguments have been fully considered but they are not persuasive.
Applicant contends that amended independent claims 1, 11 and 20 do not recite a method of organizing human activity because the claims require interaction between a computing system and a client device, including transmission of invoice items to an invoice graphical user interface (GUI) display. This argument is not persuasive.
Under the Step 2A, Prong One, the focus of the claimed invention remains directed to generating, grouping, ranking, rounding, and presenting invoice items associated with invoicing operations, these activities constitute commercial of business practices involving the creation and management of invoices. The recitation of a computing system, client device, processor, database system, network connection, and GUI display merely provides a technological environment in which the invoicing functions are performed. The fact that information is generated by one device and transmitted to another device for display does not alter the fundamental character of the claim. The claims continue to recite concepts associated with managing and presenting invoice information, which fall within certain methods of organizing human activity, including commercial interaction and business relations.
Applicant further argues that the claims integrate any judicial exception into a practical application because the processor applies a virtualization layer and virtualization engines to determine whether invoice items should be grouped into a common invoice, ranked hierarchically, and subjected to customized rounding.
Further, under Step 2A, Prong Two, the additional elements must impose a meaningful limit on the judicial exception such that the claim as a whole is directed to a practical application rather than the exception itself. The claimed virtualization layer and virtualization engines are recited at a high level of generality and are used as tools to perform the invoicing-related determinations. The claims do not recite any improvement to virtualization technology, container technology, processor operation, network communications, database functionality, or GUI technology itself. Rather, the virtualization layer and virtualization engines are invoked to execute application that carry out business-related determinations concerning invoice grouping, invoice hierarchy, and invoice rounding.
Applicant asserts the other computing systems cannot perform these functions. However, the relevant inquiry under Step 2A, Prong Two is not whether the claims perform different business operations, but whether the claims improve the functioning of a computer or another technology or technical field. The claimed grouping of invoice items, hierarchical ranking of invoice items, and customized rounding of invoice values constitute improvement, if any, to the content of the invoicing process rather than to the operation of the underlying computer technology.
The claims do not recite a specific technological solution to a technological problem. Instead, the claimed processor applies software components to analyze invoice information and determine how that information should be organized and displayed. Such use of computing components to implement invoicing rules and presentation logic does not integrate the judicial exception into a practical application.
Applicant also relies on the recitation of an invoice GUI display. However, the claims merely display the results of the invoicing determinations. Presenting information, even in particular arrangement or hierarchy, does not constitute an improvement to GUI technology where the claims do not recite a specific improvement in the manner by which the GUI operates or enables user interaction. The GUI serves only as a mechanism for displaying the results of the abstract invoicing analysis.
Accordingly, when considered as whole, the claims recite the use of generic computing components, including a processor, database system, network, client device, virtualization layer, virtualization engines, and GUI, to perform and display determinations relating to invoice management. These additional elements do not integrate the recited judicial exception into a practical application nor include “significantly more” than the judicial exceptions.
Therefore, the rejection of claims 1-20 under 35 USC § 101 is 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 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception without significantly more.
Step 1:
Claims 1-10 recite a method, which is directed to a process.
Claims 11-19 recite at least one non-transitory machine-readable storage medium, which is directed to a manufacture.
Claim 20 recite a device, which is directed to a machine.
Therefore, each claim falls within one of the four statutory categories.
Step 2A, Prong 1 (Is a judicial exception recited?):
The independent claims 1, 11 and 20 recite the abstract idea of generating and displaying invoices, see specification [0014].
1) Claims 1, 11 and 20 recite a certain method of organizing human activity. The claims recite a commercial interaction to generate and display invoices by: identifying records associated with a key value; identifying invoice configuration metadata; grouping records into invoice groups based on common field values and invoice configuration criteria; determining whether invoice items should be grouped into the same invoice; ranking invoice items hierarchically; assigning hierarchical levels; performing customized rounding of invoice amounts; displaying invoice information according to the assigned hierarchy and grouping. These limitations describe commercial and financial activities involving invoice preparation, billing organization, record categorization, accounting adjustments, and presentation of billing information. Such activities constitute a fundamental business practice and therefore fall within the category of certain methods of organizing human activity. See MPEP 2106.04(a)(2); Alice Corp. v. CLS Bank Int’l, 573 U.S. 208 (2014) and Bilski v. Kappos, 561 U.S. 593 (2010).
2) These claims recite a mental process. The limitations of identifying records, identifying metadata, determining whether invoice items belong together, assigning hierarchical rankings, grouping records according to common values, and rounding invoice amounts recite evaluations and judgments that can practically be performed in the human mind or with pencil and paper. Such limitations therefore additionally recite mental processes. See MPEP 2106.04(a)(2); CyberSource Corp. v. Retail Decisions, Inc., 654 F.3d 1366 (Fed. Cir. 2011); Electric Power Group, LLC v. Alstom S.A., No. 15-1778 (Fed. Cir. 2016).
Accordingly, claims recite abstract idea.
Step 2A, Prong 2 (Is the exception integrated into a practical application?):
This judicial exception is not integrated into a practical application because the claims satisfy the following criteria, which indicate that the claims do not integrate the abstract idea into practical application:
The claimed additional limitations are:
Claim 1: a database system, processor, an invoice graphical user interface (GUI), client device coupled to the database system over a network, a virtualization layer; virtualization engines executing applications,
Claim 11: at least one non-transitory machine-readable storage medium that provides instructions that, when executed by at least one processor, are configurable to cause the at least one processor to perform operations, a database system, an invoice graphical user interface (GUI), client device coupled to the database system over a network, a virtualization layer; virtualization engines executing applications,
Claim 20: at least one non-transitory machine-readable storage medium that stores software; and at least one processor, coupled to the at least one non-transitory machine-readable storage medium, to execute the software that implements a billing service, a database system, an invoice graphical user interface (GUI), client device coupled to the database system over a network, a virtualization layer; virtualization engines executing applications,
The additional limitations are directed to using a generic computer to process information and perform the abstract idea. Therefore, the limitations merely amount to adding the words “apply it” (or an equivalent) to the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea, as discussed in MPEP 2106.05(f). Further, the claimed “virtualization layer” and “virtualization engines” and executing applications by the virtualization layer do not improve virtualization technology, computer functionality, networking technology, database operation, or GUI technology. Rather, these components are invoked as tools to perform the abstract operations of grouping invoice items, ranking invoice items, assigning hierarchy levels, and rounding invoice values. The claims do not recited any particular technological improvement to virtualization architecture, resource allocation, virtual machine operation, application deployment, or computer performance. Instead, the virtualization components merely serve as generic computing environments in which the abstract invoicing rules are executed. See Alice, 573 U.S. at 225-26; Customedia Technologies, LLC v. Dish Network Corporation, No. 18-2239 (Fed. Cir. Dec. 6, 2020).
Likewise, the recited hierarchical graphical indications and indentation merely organize and display information according to the results of the abstract business rules. The Federal Circuit has repeatedly held that organizing, displaying, and presenting information does not integrate an abstract idea into a practical application absent an improvement to the functioning of the computer itself. See Trading Techs. Int'l, Inc. v. IBG LLC, 921 F.3d 1084 (Fed. Cir. 2019); Interval Licensing LLC v. AOL, Inc., 896 F.3d 1335 (Fed. Cir. 2018).
Accordingly, the claims do not integrate the abstract idea into a practical application.
Step 2B (Does the claim recite additional elements that amount to significantly more that the judicial exception?):
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception.
As for Step 2B analysis, knowing the consideration is overlapping with Step 2A, Prong 2. The Step 2B considerations have already been substantially addressed under Step 2A Prong 2, see Step 2A Prong 2 analysis above. As discussed above, the additional imitations amount to adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea, as discussed in MPEP 2106.05(f). The additional elements, individually and in combination, merely require generic computer components by “apply it” (or an equivalent) in order to perform functions of: storing records in a database; retrieving records; transmitting information over a network; executing software applications; displaying information on a GUI; organizing and presenting data.
The claims do not recite any specialized hardware, any unconventional database architecture, any improvement to virtualization technology, any new GUI technology, or any technological solution to a technological problem. Instead, the claim merely automates a longstanding invoicing process involving grouping billing records, assigning hierarchy levels, rounding amounts, and presenting invoice information,
The use of a processor, database system, client device, virtualization layer, virtualization engines, and network amounts to no more than instructions to apply the abstract idea using generic computer components, such generic implementation does not provide an inventive concept sufficient to transform the abstract idea into patent-eligible subject matter. See Alice, 573 U.S. at 225-26; BuySAFE, Inc. v. Google, Inc., 765 F.3d 1350 (Fed. Cir. 2014); Inventor Holdings, LLC v. Bed Bath & Beyond, Inc., 876 F.3d 1372 (Fed. Cir. 2017).
Accordingly, the claims do not include “significantly more” than the judicial exceptions.
In addition, the dependent claims recite:
Step 2A, Prong 1 (Is a judicial exception recited?):
Dependent claims 2-10 and 12-19 recitations further narrowing the abstract idea recited in the independent claims 1, 11 and 20 and therefore directed towards the same abstract idea.
Step 2A, Prong 2 and Step 2B:
The dependent claims 2-10 and 12-19 further narrow the abstract idea recited in the independent claims 1, 11 and 20 and are therefore directed towards the same abstract idea.
The dependent claims recite the following additional limitations:
Claims 8 and 18: a database of the database system,
Claims 12-19: the at least one non-transitory machine-readable storage medium,
However, the examiner finds each of these additional elements to be directed to merely “apply it” or applying a generic technology to perform the recited abstract idea of generating invoices, the recitation to the generic computer technology that is being used as a tool to execute the steps that define the abstract idea do not provide for integration at the 2nd prong and do not provide for significantly more at step 2B.
Therefore, the limitations on the invention of claims 1-20, when viewed individually and in ordered combination are directed to in-eligible subject matter.
Distinguished Over Prior Art
Examiner is in agreement with applicant’s amendments and arguments filed on 05/27/2025. The claims 1-20, in present form, have overcome the prior art rejections and the examiner has been unable to find the claimed limitations in the prior art. The prior art on record, alone or in combination, neither anticipates, reasonably teaches, nor renders obvious the applicant's claimed invention. The examiner has been unable to find the claimed limitations in any prior art. Accordingly, the applicant needs to address the outstanding rejections above in order to issue an allowability notice. The reason to withdraw the 35 USC 103 rejection of claims 1-20 in the instant application is because the prior art of record fails to teach the overall combination as claimed. Therefore, it would not have been obvious to one of ordinary skill in the art to modify the prior art to meet the combination above without unequivocal hindsight and one of ordinary skill would have no reason to do so. Upon further searching the examiner could not identify any prior art to teach these limitations. The prior art on record, alone or in combination, neither anticipates, reasonably teaches, not renders obvious the Applicant’s claimed invention. Accordingly, the examiner recommends addressing the outstanding rejections above.
Conclusion
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/AVIA SALMAN/Primary Patent Examiner, Art Unit 3627
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