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 action is in reply to the application filed on January 7, 2026.
Claims 2, 3, 8, 11, 12, and 18-20 were cancelled.
Claims 1, 4, 5, 10, 14, and 14 were amended.
Claim(s) 1, 4-7, 9, 10, and 13-17 are currently pending and have been examined.
This action is made Non-Final.
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 January 7, 2026 has been entered.
Response to Arguments
Applicant argued that Examiner’s 101 rejection was improper because the currently pending claims are not directed to an abstract idea and do recite a technical improvement in semantic classification of tax-related documents. Examiner disagrees. Applicant’s claimed invention is directed towards classifying tax data used in the further of tax compliance, which is an example of a legal interaction. These types of concepts fall under the enumerated grouping of abstract ideas described as certain methods of organizing human activity. Therefore, Applicant’s claimed invention is directed towards an abstract idea. Applicant’s claimed invention demonstrates a technical application for the semantic classification of tax-related documents, but that technical application does not amount to a technical improvement because there wasn’t a technological problem or limitation overcome in its application. Therefore, Examiner finds Applicant’s argument non-persuasive.
Applicant argued that Examiner’s 101 rejection was improper because the claimed invention demonstrates integration of the judicial exception into a practical application that improves computer functionality and supports real-world compliance processes. Examiner disagrees. Applicant’s claimed invention does not demonstrate an improvement in computer functionality because the computer was not modified in any material way. In fact, the Specification states, “Computing system 900 may take the form of one or more personal computers…” (Specification, pgh 22). Neither the Specification nor the claims provide details of any modification to the computer itself. Logically, there can’t be an improvement to computer functionality without any change to how the computer operates. Therefore, Examiner finds Applicant’s argument non-persuasive.
Applicant argued that Examiner’s 101 rejection was improper because the amended claim does not recite an abstract idea, law of nature or natural phenomenon under Step2A Prong 1 and recites additional elements that integrate the judicial exception into a practical application under Step 2A Prong 2. Examiner disagrees. As previously shown, Applicant’s claimed invention does recite an abstract idea. Applicant’s claimed invention also does not integrate the judicial exception into a practical application because the claimed invention does not improve the functioning of a computer, apply the judicial exception with or by use of, a particular machine, or apply or use the judicial exception is some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment. Therefore, Examiner finds Applicant’s argument non-persuasive.
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.
Claim(s) 1, 4-7, 9, 10, and 13-17 is/are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Claim(s) 1, 4-7, 9, 10, and 13-17 are directed to a system, method, or product, which are/is one of the statutory categories of invention. (Step 1: YES).
The Examiner has identified independent system claim 1 as the claim that represents the claimed invention for analysis and is similar to independent method Claim 10. Claim 1 recites the following limitations:
a processor configured to: during a training phase, receive a training data set including multiple training pairs, each training pair including a respective training article and a ground truth training tax category, wherein the training data set further includes negative training pairs, the respective training article of the negative training pairs being irrelevant to the ground truth training tax category;
input the training data set to an untrained or not fully trained ML model, wherein features of each training article, including a relative positional relationship of words indicating the ground truth training tax category to other words in the training article, are encoded as embeddings; and
train the untrained or not fully trained ML model to classify each training article into the respective ground truth training tax category for each of the input pairs, to thereby generate a trained ML model; and
during an inference phase, receive a tax-related article that details, summarizes, or outlines taxes enacted a taxing jurisdiction;
input the tax-related article to an article embedding encoder to generate article embeddings;
generate, via a category embedding encoder, tax category embeddings;
perform a similarity search between the tax category embeddings and the article embeddings;
classify the tax-related article into one or more candidate tax categories based on a result of the similarity search;
concatenate the tax-related article with each of the candidate tax categories to form a plurality of input pairs;
input the input pairs to the trained ML model;
determine, via the trained ML model, a respective confidence score for classifying the tax-related article into each of the candidate tax categories for each of the input pairs;
output the candidate tax categories for the tax-related article and the respective confidence scores to a client computing device of a user which is communicatively coupled to the computing system; and
receive, from the client computing device, feedback on accuracy of the candidate tax categories and adjust a similarity threshold and/or candidate selection count based on the feedback to reduce false positives in subsequent inferences, wherein
the processor is configured to apply a cosine similarity search between the article embeddings and the tax category embeddings generated by respective Bidirectional Encoder Representations from Transformers (BERT)-based encoders, and compute the respective confidence scores via the trained ML model using a softmax function applied to logits of true and false tokens.
These limitations, under their broadest reasonable interpretation, cover performance of the limitation as certain methods of organizing human activity because the limitations recite commercial or legal interactions. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation as a commercial or legal interaction, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea. The processor, ML model, client computing device, and computing system in Claim 1 are just applying generic computer components to the recited abstract limitations. The recitation of generic computer components in a claim does not necessarily preclude that claim from reciting an abstract idea. Claim(s) 10 is also abstract for similar reasons. (Step 2A-Prong 1: YES. The claims recite an abstract idea)
This judicial exception is not integrated into a practical application. In particular, the claims recite the additional elements of a processor, ML model, client computing device, and computing system. The computer hardware/software is/are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function) such that it amounts to no more than mere instructions to apply the exception using a generic computer component. 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 and are at a high level of generality. Therefore, claim(s) 1 and 10 are directed to an abstract idea without a practical application. (Step 2A-Prong 2: NO. The additional claimed elements are not integrated into a practical application)
The claims do 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 element of using computer hardware amounts to no more than mere instructions to apply the exception using a generic computer component. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Accordingly, these additional elements do not change the outcome of the analysis when considered separately and as an ordered combination. Thus, claim(s) 1 and 10 are not patent eligible. (Step 2B: NO. The claims do not provide significantly more)
Dependent claims 4-7, 9, and 13-17 further define the abstract idea that is present in their respective independent claim(s) 1 and 10 and thus correspond to certain methods of organizing human activity and hence are abstract for the reasons presented above. Dependent claims 4-7, 9, and 13-17 do not include any additional elements that integrate the abstract idea into a practical application or are sufficient to amount to significantly more than the judicial exception when considered both individually and as an ordered combination. Therefore, dependent claims 4-7, 9, and 13-17 are directed to an abstract idea. Thus, claim(s) 1, 4-7, 9, 10, and 13-17 are not patent-eligible.
Conclusion
Pertinent Art
The prior art made of record and not relied upon is considered pertinent to Applicant’s disclosure. Subrahmaniam (US 2024/0029175) discloses systems and methods that process, classify, and provide intelligent insights related to received documents.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to JOHN O PRESTON whose telephone number is (571)270-3918. The examiner can normally be reached 9:00 am - 5:00 pm.
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, MICHAEL ANDERSON can be reached on 571-270-0508. 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.
/JOHN O PRESTON/Examiner, Art Unit 3693
March 6, 2026
/ELIZABETH H ROSEN/Primary Examiner, Art Unit 3693