DETAILED ACTION
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 February 26, 2026 has been entered. Claims 1, 5, 6, 8, 9, 11, 13-16, 21, and 23-24 have been amended. Claims 17-20 are cancelled. Claims 1-16 and 21-24 are presented for examination.
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 .
Response to Arguments
Applicant's arguments filed February 26, 2026 have been considered but they are not fully persuasive.
Regarding the rejection under 35 U.S.C. § 101, on page 12 of the response, Applicant argues:
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At present, the claims focus on preparing the workflow for future active implementation. Inasmuch as the claims “implement” the workflow by transmitting a command to a device and “execute” the workflow function in response to a command, the last limitation of claims 1 and 21 says that these steps/operations are “to enable the specific user to perform the security function.” It is not readily evident in the claims that the various devices are fully controlled by the additional elements as human movement is detected by other additional elements, for example. Currently, the transmission of commands to the devices and execution of corresponding workflow functions by the devices seems to be limited to updating instructions for how the devices may be utilized by the specific user. The claims recite “to enable the specific user to perform the security function.” Thus, active control of the devices in accordance with the various commands that are changed as users move around is not performed within the scope of the claims. Even if an argument were to be made that the devices are actively controlled in executing active operations corresponding to each device when they execute re-assigned and/or updated instructions, at best, this would merely present a general idea of a solution as opposed to specific technical operations and/or a particular technical solution. As explained in MPEP § 2106.05(a), “[a]n important consideration in determining whether a claim improves technology is the extent to which the claim covers a particular solution to a problem or a particular way to achieve a desired outcome, as opposed to merely claiming the idea of a solution or outcome. McRO, 837 F.3d at 1314-15, 120 USPQ2d at 1102-03; DDR Holdings, 773 F.3d at 1259, 113 USPQ2d at 1107. In this respect, the improvement consideration overlaps with other considerations, specifically the particular machine consideration (see MPEP § 2106.05(b)), and the mere instructions to apply an exception consideration (see MPEP § 2106.05(f)). Thus, evaluation of those other considerations may assist examiners in making a determination of whether a claim satisfies the improvement consideration.”
On page 13 of the response, Applicant argues:
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The Examiner points out that there is no active, dynamically-performed location tracking of the specific user by additional elements in the claims. The trigger and responsive action are recited as being executed “while the specific user is assigned to or physically present at the first location,” for example; however, the specific user may simply be assigned to the location, which does not guarantee that the specific user is actually present at a particular location.
Applicant argues that “the claimed process transforms the physical security system from a configuration where the first device is active to a configuration where the third device is active, ensuring continuous operation. This transformation of the underlying machine state confirms that the claims are not abstract, but are directed to a concrete technical application.” (Page 13 of Applicant’s response) the Examiner does not find such a transformation to be one where an article is converted from one state or thing to a different state or thing altogether.
Applicant submits that the claims in the instant application are akin to USPTO Example 37 (relocation of icons) (pages 13-14 of Applicant’s response). The Examiner respectfully disagrees. There is no movement of icons on a screen in response to which icons are detected as being used most often by a user in Applicant’s claims.
Applicant submits that the claims in the instant application are akin to USPTO Example 42 (transmission of notifications) (page 14 of Applicant’s response). The Examiner respectfully disagrees. There is standardization of formats in Applicant’s claims.
On page 14 of the response, Applicant argues, “The claimed mechanism of simultaneously commissioning a new device via a first command while decommissioning an old device via a second command to maintain a continuous security function across multiple locations for a specific user is not a well-understood, routine, or conventional activity. Generic computers do not inherently possess the logic to perform this specific dual-command physical reconfiguration based on real-time location changes and device capability matching.” As explained above and in the rejection, the claims focus on preparing the workflow for future active implementation. Inasmuch as the claims “implement” the workflow by transmitting a command to a device and “execute” the workflow function in response to a command, the last limitation of claims 1 and 21 says that these steps/operations are “to enable the specific user to perform the security function.” It is not readily evident in the claims that the various devices are fully controlled by the additional elements as human movement is detected by other additional elements, for example. Currently, the transmission of commands to the devices and execution of corresponding workflow functions by the devices seems to be limited to updating instructions for how the devices may be utilized by the specific user. The claims recite “to enable the specific user to perform the security function.” Thus, active control of the devices in accordance with the various commands that are changed as users move around is not performed within the scope of the claims.
If supported by Applicant’s original disclosure, it would be helpful if the claims were amended with more specific technical details as to how a user’s location is continuously monitored by additional elements and then used to actively activate and deactivate operations as the user is moving in and out of areas corresponding to different devices and available operations personalized to each specific user.
Regarding the art rejection, Applicant’s claim amendments overcome the rejection.
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 1-16 and 21-24 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter.
Claims 1-16 and 21-24 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. The claimed invention is directed to “a system, method, and apparatus for implementing and updating workflows associated with users across multiple differing systems and devices” (Spec: ¶ 21) without significantly more.
Step
Analysis
1: Statutory Category?
Yes – The claims fall within at least one of the four categories of patent eligible subject matter. Process (claims 1-16), Apparatus (claims 21-24)
Independent claims:
Step
Analysis
2A – Prong 1: Judicial Exception Recited?
Yes – Aside from the additional elements identified in Step 2A – Prong 2 below, the claims recite:
[Claims 1, 21] A method of updating workflows associated with a user, the method comprising:
maintaining a workflow particularly created for a specific user to enable the specific user to perform a security function, the workflow defining a configuration of physical devices assigned to the specific user, the workflow indicating that a trigger and a responsive action are respectively executed on a first physical device and a second physical device assigned to the specific user while the specific user is assigned to or physically present at a first location;
executing, based on the workflow particularly created for the specific user, the trigger while the specific user is assigned to or physically present at the first location;
executing, based on the workflow particularly created for the specific user, the responsive action while the specific user is assigned to or physically present at the first location;
detecting a change in location of the specific user based on the specific user being reassigned to or physically present at a second location different from the first location and responsively determining that a physical device selected from one of the first physical device and the second physical device is no longer available to be assigned to the specific user at the second location for executing the workflow particularly created for the specific user;
accessing a device list, wherein the device list identifies a set of physical devices available at the second location and indicates device capabilities associated with the set of physical devices;
identifying a third physical device selected from the device list based on determining that the third physical device is (i) available to be assigned to the specific user at the second location for execution of the workflow particularly created for the specific user and (ii) capable of executing a workflow function at the second location, the workflow function corresponding to one of the trigger or responsive action executed by the selected physical device at the first location;
updating the workflow particularly created for the specific user to re-assign execution of the workflow function executed by the selected physical device at the first location to the third physical device for the specific user, the updating including modifying the configuration of physical devices by replacing an identifier of the selected physical device indicated in the workflow with an identifier of the third physical device; and
implement the updated workflow by transmitting a first command instructing the third physical device to execute the workflow function corresponding to the one of the trigger or responsive action at the second location and transmitting a second command instructing the selected physical device to stop execution of the one of the trigger or responsive action at the first location;
in response to the first command, executing, by the third physical device, the workflow function corresponding to the one of the trigger or responsive action at the second location to enable the specific user to perform the security function.
Aside from the additional elements, the aforementioned claim details exemplify the abstract idea(s) of a mental process (since the details include concepts performed in the human mind, including an observation, evaluation, judgment, and/or opinion). As explained in MPEP § 2106(a)(2)(C)(III), “The courts consider a mental process (thinking) that ‘can be performed in the human mind, or by a human using a pen and paper’ to be an abstract idea. CyberSource Corp. v. Retail Decisions, Inc., 654 F.3d 1366, 1372, 99 USPQ2d 1690, 1695 (Fed. Cir. 2011). As the Federal Circuit explained, ‘methods which can be performed mentally, or which are the equivalent of human mental work, are unpatentable abstract ideas the ‘basic tools of scientific and technological work’ that are open to all.’’ 654 F.3d at 1371, 99 USPQ2d at 1694 (citing Gottschalk v. Benson, 409 U.S. 63, 175 USPQ 673 (1972)).” The limitations reproduced above, as drafted, are a process that, under its broadest reasonable interpretation, covers performance of the limitations in the mind but for the recitation of generic computer components. That is, other than reciting the additional elements identified in Step 2A – Prong 2 below, nothing in the claim elements precludes the steps from practically being performed in the mind and/or by a human using a pen and paper. For example, but for the recitations of generic computer and other processing components (identified in Step 2A – Prong 2 below), the respectively recited steps/functions of the claims, as drafted and set forth above, are a process that, under its broadest reasonable interpretation, covers performance of the limitations in the mind and/or with the use of pen and paper. A human user could observe situations to gather the type of data recited (including related to the nature of various devices and sensed information), make device selection decisions related to workflow, update a workflow, implement a workflow, execute certain actions based on triggers, etc. Replacing one device with another may simply refer to updating which device is currently selected for a given operation (e.g., as part of a workflow). If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind (and/or with pen and paper) but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. Accordingly, the claims recite an abstract idea.
Aside from the additional elements, the aforementioned claim details exemplify a method of organizing human activity (since the details include examples of commercial or legal interactions, including advertising, marketing or sales activities or behaviors, and/or business relations and managing personal behavior or relationships or interactions between people, including social activities, teaching, and following rules or instructions). More specifically, the evaluated process is related to “a system, method, and apparatus for implementing and updating workflows associated with users across multiple differing systems and devices” (Spec: ¶ 21), which (under its broadest reasonable interpretation) is an example of managing humans (i.e., organizing human activity); therefore, aside from the recitations of generic computer and other processing components (identified in Step 2A – Prong 2 below), the limitations identified in the more detailed claim listing above encompass the abstract idea of organizing human activity. A human user may also be instructed to perform actions based on triggers, which is another example of organizing human activity.
Additionally, regarding the limitations:
implement the updated workflow by transmitting a first command instructing the third physical device to execute the workflow function corresponding to the one of the trigger or responsive action at the second location and transmitting a second command instructing the selected physical device to stop execution of the one of the trigger or responsive action at the first location;
in response to the first command, executing, by the third physical device, the workflow function corresponding to the one of the trigger or responsive action at the second location to enable the specific user to perform the security function,
(aside from generally performing these operations at the workflow server and transmitting communications via the network interface) the transmission of the commands seems to merely configure the respective devices for future user by a human user. This speaks to instructing human users to perform activities, which is another example of organizing human activity.
At present, the claims focus on preparing the workflow for future active implementation. Inasmuch as the claims “implement” the workflow by transmitting a command to a device and “execute” the workflow function in response to a command, the last limitation of claims 1 and 21 says that these steps/operations are “to enable the specific user to perform the security function.” It is not readily evident in the claims that the various devices are fully controlled by the additional elements as human movement is detected by other additional elements, for example. Currently, the transmission of commands to the devices and execution of corresponding workflow functions by the devices seems to be limited to updating instructions for how the devices may be utilized by the specific user. The claims recite “to enable the specific user to perform the security function.” Thus, active control of the devices in accordance with the various commands that are changed as users move around is not performed within the scope of the claims.
2A – Prong 2: Integrated into a Practical Application?
No – The judicial exception(s) is/are not integrated into a practical application.
Claim 1 recites a workflow server to generally implement the claim operations. Claim 1 also recites the workflow indicating that a trigger and a responsive action are executed respectively on a first physical device and on a second physical device.
Additionally, claim 1 implements the updated workflow by transmitting a command instructing the third physical device to execute the workflow function corresponding to the one of the trigger or responsive action at the second location.
Claim 1 recites that the trigger is executed by the first physical device, that the responsive action is executed by the second physical device, and that the third physical device executes the workflow function corresponding to the one of the trigger or responsive action.
Claim 1 recites that certain operations are performed in a memory of the workflow server and that transmission may occur via a network interface of the workflow server.
Method claims are defined by positively recited steps. The capabilities of the various devices and sensors are not positively recited in method claim 1 and these details simply define tools used to maintain the workflow and a corresponding field of use.
Claim 21 recites similar additional elements to those recited in claim 1.
The claims as a whole merely describe how to generally “apply” the abstract idea(s) in a computer environment. The claimed processing elements are recited at a high level of generality and are merely invoked as a tool to perform the abstract idea(s). Simply implementing the abstract idea(s) on a general-purpose processor is not a practical application of the abstract idea(s); Applicant’s specification discloses that the invention may be implemented using general-purpose processing elements and other generic components (Spec: ¶ 26 – “These computer program instructions may be provided to a processor of a general purpose computer, special purpose computer, or other programmable data processing apparatus to produce a machine, such that the instructions, which execute via the processor of the computer or other programmable data processing apparatus, create means for implementing the functions/acts specified in the flowchart and/or block diagram block or blocks.”).
The use of a processor/processing elements (e.g., as recited in all of the claims) facilitates generic processor operations. The use of a memory or machine-readable media with executable instructions facilitates generic processor operations.
The additional elements are recited at a high-level of generality (i.e., as generic processing elements performing generic computer functions) such that the incorporation of the additional processing elements amounts to no more than mere instructions to apply the judicial exception(s) using generic computer components. There is no indication in the Specification that the steps/functions of the claims require any inventive programming or necessitate any specialized or other inventive computer components (i.e., the steps/functions of the claims may be implemented using capabilities of general-purpose computer components). Accordingly, the additional elements do not integrate the abstract ideas into a practical application because they do not impose any meaningful limits on practicing the abstract idea. The claims are directed to an abstract idea(s).
The processing components presented in the claims simply utilize the capabilities of a general-purpose computer and are, thus, merely tools to implement the abstract idea(s). As seen in MPEP § 2106.05(a)(I) and § 2106.05(f)(2), the court found that accelerating a process when the increased speed solely comes from the capabilities of a general-purpose computer is not sufficient to show an improvement in computer-functionality and it amounts to a mere invocation of computers or machinery as a tool to perform an existing process (see FairWarning IP, LLC v. Iatric Sys., 839 F.3d 1089, 1095, 120 USPQ2d 1293, 1296 (Fed. Cir. 2016)).
There is no transformation or reduction of a particular article to a different state or thing recited in the claims.
Additionally, even when considering the operations of the additional elements as an ordered combination, the ordered combination does not amount to significantly more than what is present in the claims when each operation is considered separately.
At present, the claims focus on preparing the workflow for future active implementation. Inasmuch as the claims “implement” the workflow by transmitting a command to a device and “execute” the workflow function in response to a command, the last limitation of claims 1 and 21 says that these steps/operations are “to enable the specific user to perform the security function.” It is not readily evident in the claims that the various devices are fully controlled by the additional elements as human movement is detected by other additional elements, for example. Currently, the transmission of commands to the devices and execution of corresponding workflow functions by the devices seems to be limited to updating instructions for how the devices may be utilized by the specific user. The claims recite “to enable the specific user to perform the security function.” Thus, active control of the devices in accordance with the various commands that are changed as users move around is not performed within the scope of the claims. Even if an argument were to be made that the devices are actively controlled in executing active operations corresponding to each device when they execute re-assigned and/or updated instructions, at best, this would merely present a general idea of a solution as opposed to specific technical operations and/or a particular technical solution. As explained in MPEP § 2106.05(a), “[a]n important consideration in determining whether a claim improves technology is the extent to which the claim covers a particular solution to a problem or a particular way to achieve a desired outcome, as opposed to merely claiming the idea of a solution or outcome. McRO, 837 F.3d at 1314-15, 120 USPQ2d at 1102-03; DDR Holdings, 773 F.3d at 1259, 113 USPQ2d at 1107. In this respect, the improvement consideration overlaps with other considerations, specifically the particular machine consideration (see MPEP § 2106.05(b)), and the mere instructions to apply an exception consideration (see MPEP § 2106.05(f)). Thus, evaluation of those other considerations may assist examiners in making a determination of whether a claim satisfies the improvement consideration.”
2B: Claim(s) Provide(s) an Inventive Concept?
No – The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception(s). As discussed above with respect to integration of the abstract idea(s) into a practical application, the use of the additional elements to perform the steps identified in Step 2A – Prong 1 above amounts to no more than mere instructions to apply the exceptions using a generic computer component(s). Mere instructions to apply an exception using a generic computer component(s) cannot provide an inventive concept. The claims are not patent eligible.
Dependent claims:
Step
Analysis
2A – Prong 1: Judicial Exception Recited?
Yes – Aside from the additional elements identified in Step 2A – Prong 2 below, the claims recite:
[Claim 2] detect a predefined environmental condition at the first location and in response execute the trigger by transmitting a message indicating an occurrence of the predefined environmental condition at the first location.
[Claim 3] receive the message indicating the occurrence of the predefined environmental condition at the first location and in response execute the action.
[Claims 4, 22] wherein the third physical device is of a device type different from that of the selected physical device.
[Claims 5, 23] wherein the selected physical device is the first physical device executing the trigger at the first location, wherein identifying the third physical device comprises:
determining that each physical device included in the device list is of a device type different that of the first physical device; and
selecting the third physical device from the device list upon determining that the third physical device is capable of executing the workflow function corresponding to the trigger at the second location.
[Claims 6, 24] wherein the selected physical device includes a sensor capable of executing the trigger by detecting a predefined environmental condition using visual sensor data captured corresponding to the first location, wherein identifying the third physical device comprises:
determining that the device list does not include a sensor that is capable of capturing visual data for detecting the predefined environmental condition at the second location; and
selecting the third physical device from the device list upon determining that the third physical device includes a sensor that is capable of executing the workflow function corresponding to the trigger by detecting the predefined environmental condition using non-visual data captured corresponding to the second location.
[Claim 7] wherein the sensor included in the selected physical device is a camera sensor and the sensor included in the third physical device is a non-camera sensor.
[Claim 8] wherein the selected physical device is the second physical device executing the responsive action at the first location, wherein identifying the third physical device comprises:
determining that each physical device included in the device list is of a device type different that of the first physical device; and
selecting the third physical device from the set of physical devices included in the device list upon determining that the third physical device is capable of executing the workflow function corresponding to the responsive action at the second location.
[Claim 9] wherein the selected physical device includes an effector capable of executing the responsive action by presenting a visual output indicating an occurrence of a predefined environmental condition at the first location to the specific user, the method comprising:
determining that the device list does not include an effector that is capable of rendering a visual output indicating an occurrence of the predefined environmental condition at the second location; and
selecting the third physical device from the device list upon determining that the third physical device includes an effector that is capable of executing the workflow function corresponding to the responsive action at the second location by providing a non-visual output indicating an occurrence of the predefined environmental condition at the second location to the specific user.
[Claim 10] wherein the effector included in the second physical device is an electronic display and the effector included in the third physical device is an electronic speaker.
[Claim 11] wherein the second physical device includes an effector capable of executing the responsive action by presenting a non-visual output indicating an occurrence of a predefined environmental condition at the first location to the specific user, the method comprising:
determining that the device list does not include an effector that is capable of providing a non-visual output indicating an occurrence of the predefined environmental condition at the second location; and
selecting the third physical device from the device list upon determining that the third physical device includes an effector that is capable of executing the workflow function corresponding to the responsive action at the second location by rendering a visual output indicating an occurrence of the predefined environmental condition at the second location to the specific user.
[Claim 12] wherein the effector included in the second physical device is an electronic speaker and the effector included in the third physical device is an electronic display.
[Claim 13] wherein identifying the third physical device comprises: determining that the specific user is authorized to use the third physical device for executing the workflow function corresponding to the one of the trigger or responsive action at the second location.
[Claim 14] determining that the specific user is no longer assigned to or physically present at the second location; and
transmitting a third message to stop execution of the workflow function corresponding to the one of the trigger or responsive action at the second location.
[Claim 15] wherein when the selected physical device is the first physical device, wherein updating the workflow comprises:
including, in the updated workflow, information indicating that the trigger is executed by the third physical device and the responsive action is executed by the second physical device while the specific user is assigned to or physically present at a second location.
[Claim 16] wherein when the selected physical device is the second physical device, wherein updating the workflow comprises:
including, in the updated workflow, information indicating that the trigger is executed on the first physical device and the responsive action is executed on the third physical device while the specific user is assigned to or physically present at the second location.
The dependent claims further present details of the abstract ideas identified in regard to the independent claims above.
Aside from the additional elements, the aforementioned claim details exemplify the abstract idea(s) of a mental process (since the details include concepts performed in the human mind, including an observation, evaluation, judgment, and/or opinion). As explained in MPEP § 2106(a)(2)(C)(III), “The courts consider a mental process (thinking) that ‘can be performed in the human mind, or by a human using a pen and paper’ to be an abstract idea. CyberSource Corp. v. Retail Decisions, Inc., 654 F.3d 1366, 1372, 99 USPQ2d 1690, 1695 (Fed. Cir. 2011). As the Federal Circuit explained, ‘methods which can be performed mentally, or which are the equivalent of human mental work, are unpatentable abstract ideas the ‘basic tools of scientific and technological work’ that are open to all.’’ 654 F.3d at 1371, 99 USPQ2d at 1694 (citing Gottschalk v. Benson, 409 U.S. 63, 175 USPQ 673 (1972)).” The limitations reproduced above, as drafted, are a process that, under its broadest reasonable interpretation, covers performance of the limitations in the mind but for the recitation of generic computer components. That is, other than reciting the additional elements identified in Step 2A – Prong 2 below, nothing in the claim elements precludes the steps from practically being performed in the mind and/or by a human using a pen and paper. For example, but for the recitations of generic computer and other processing components (identified in Step 2A – Prong 2 below), the respectively recited steps/functions of the claims, as drafted and set forth above, are a process that, under its broadest reasonable interpretation, covers performance of the limitations in the mind and/or with the use of pen and paper. A human user could observe situations to gather the type of data recited (including related to the nature of various devices and sensed information), make device selection decisions related to workflow, update a workflow, implement a workflow, execute certain actions based on triggers, etc. Replacing one device with another may simply refer to updating which device is currently selected for a given operation (e.g., as part of a workflow). If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind (and/or with pen and paper) but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. Accordingly, the claims recite an abstract idea.
Aside from the additional elements, the aforementioned claim details exemplify a method of organizing human activity (since the details include examples of commercial or legal interactions, including advertising, marketing or sales activities or behaviors, and/or business relations and managing personal behavior or relationships or interactions between people, including social activities, teaching, and following rules or instructions). More specifically, the evaluated process is related to “a system, method, and apparatus for implementing and updating workflows associated with users across multiple differing systems and devices” (Spec: ¶ 21), which (under its broadest reasonable interpretation) is an example of managing humans (i.e., organizing human activity); therefore, aside from the recitations of generic computer and other processing components (identified in Step 2A – Prong 2 below), the limitations identified in the more detailed claim listing above encompass the abstract idea of organizing human activity. A human user may also be instructed to perform actions based on triggers, which is another example of organizing human activity.
Additionally, regarding the limitations:
implement the updated workflow by transmitting a first command instructing the third physical device to execute the workflow function corresponding to the one of the trigger or responsive action at the second location and transmitting a second command instructing the selected physical device to stop execution of the one of the trigger or responsive action at the first location;
in response to the first command, executing, by the third physical device, the workflow function corresponding to the one of the trigger or responsive action at the second location to enable the specific user to perform the security function,
(aside from generally performing these operations at the workflow server and transmitting communications via the network interface) the transmission of the commands seems to merely configure the respective devices for future user by a human user. This speaks to instructing human users to perform activities, which is another example of organizing human activity.
At present, the claims focus on preparing the workflow for future active implementation. Inasmuch as the claims “implement” the workflow by transmitting a command to a device and “execute” the workflow function in response to a command, the last limitation of claims 1 and 21 says that these steps/operations are “to enable the specific user to perform the security function.” It is not readily evident in the claims that the various devices are fully controlled by the additional elements as human movement is detected by other additional elements, for example. Currently, the transmission of commands to the devices and execution of corresponding workflow functions by the devices seems to be limited to updating instructions for how the devices may be utilized by the specific user. The claims recite “to enable the specific user to perform the security function.” Thus, active control of the devices in accordance with the various commands that are changed as users move around is not performed within the scope of the claims.
2A – Prong 2: Integrated into a Practical Application?
No – The judicial exception(s) is/are not integrated into a practical application.
The dependent claims include the additional elements of their independent claims.
Claim 1 recites a workflow server to generally implement the claim operations. Claim 1 also recites the workflow indicating that a trigger and a responsive action are executed respectively on a first physical device and on a second physical device.
Additionally, claim 1 implements the updated workflow by transmitting a command instructing the third physical device to execute the workflow function corresponding to the one of the trigger or responsive action at the second location.
Claim 1 recites that the trigger is executed by the first physical device, that the responsive action is executed by the second physical device, and that the third physical device executes the workflow function corresponding to the one of the trigger or responsive action.
Claim 1 recites that certain operations are performed in a memory of the workflow server and that transmission may occur via a network interface of the workflow server.
Claim 2 recites wherein the first physical device includes a sensor configured to detect a predefined environmental condition at the first location and in response execute the trigger by transmitting a signal indicating an occurrence of the predefined environmental condition at the first location to the second physical device.
Claim 3 recites wherein the second physical device includes an effector configured to receive the signal indicating the occurrence of the predefined environmental condition at the first location from the first physical device and in response execute the action.
Claim 14 recites transmitting a command instructing the third physical device to stop execution of the workflow function corresponding to the one of the trigger or responsive action at the second location.
Method claims are defined by positively recited steps. The capabilities of the various devices and sensors are not positively recited in method claims 1-16 and these details simply define tools used to maintain the workflow and a corresponding field of use.
Claims 21-24 recite similar additional elements to those recited in claims 1 and 4-6.
The claims as a whole merely describe how to generally “apply” the abstract idea(s) in a computer environment. The claimed processing elements are recited at a high level of generality and are merely invoked as a tool to perform the abstract idea(s). Simply implementing the abstract idea(s) on a general-purpose processor is not a practical application of the abstract idea(s); Applicant’s specification discloses that the invention may be implemented using general-purpose processing elements and other generic components (Spec: ¶ 26 – “These computer program instructions may be provided to a processor of a general purpose computer, special purpose computer, or other programmable data processing apparatus to produce a machine, such that the instructions, which execute via the processor of the computer or other programmable data processing apparatus, create means for implementing the functions/acts specified in the flowchart and/or block diagram block or blocks.”).
The use of a processor/processing elements (e.g., as recited in all of the claims) facilitates generic processor operations. The use of a memory or machine-readable media with executable instructions facilitates generic processor operations.
The additional elements are recited at a high-level of generality (i.e., as generic processing elements performing generic computer functions) such that the incorporation of the additional processing elements amounts to no more than mere instructions to apply the judicial exception(s) using generic computer components. There is no indication in the Specification that the steps/functions of the claims require any inventive programming or necessitate any specialized or other inventive computer components (i.e., the steps/functions of the claims may be implemented using capabilities of general-purpose computer components). Accordingly, the additional elements do not integrate the abstract ideas into a practical application because they do not impose any meaningful limits on practicing the abstract idea. The claims are directed to an abstract idea(s).
The processing components presented in the claims simply utilize the capabilities of a general-purpose computer and are, thus, merely tools to implement the abstract idea(s). As seen in MPEP § 2106.05(a)(I) and § 2106.05(f)(2), the court found that accelerating a process when the increased speed solely comes from the capabilities of a general-purpose computer is not sufficient to show an improvement in computer-functionality and it amounts to a mere invocation of computers or machinery as a tool to perform an existing process (see FairWarning IP, LLC v. Iatric Sys., 839 F.3d 1089, 1095, 120 USPQ2d 1293, 1296 (Fed. Cir. 2016)).
There is no transformation or reduction of a particular article to a different state or thing recited in the claims.
Additionally, even when considering the operations of the additional elements as an ordered combination, the ordered combination does not amount to significantly more than what is present in the claims when each operation is considered separately.
At present, the claims focus on preparing the workflow for future active implementation. Inasmuch as the claims “implement” the workflow by transmitting a command to a device and “execute” the workflow function in response to a command, the last limitation of claims 1 and 21 says that these steps/operations are “to enable the specific user to perform the security function.” It is not readily evident in the claims that the various devices are fully controlled by the additional elements as human movement is detected by other additional elements, for example. Currently, the transmission of commands to the devices and execution of corresponding workflow functions by the devices seems to be limited to updating instructions for how the devices may be utilized by the specific user. The claims recite “to enable the specific user to perform the security function.” Thus, active control of the devices in accordance with the various commands that are changed as users move around is not performed within the scope of the claims. Even if an argument were to be made that the devices are actively controlled in executing active operations corresponding to each device when they execute re-assigned and/or updated instructions, at best, this would merely present a general idea of a solution as opposed to specific technical operations and/or a particular technical solution. As explained in MPEP § 2106.05(a), “[a]n important consideration in determining whether a claim improves technology is the extent to which the claim covers a particular solution to a problem or a particular way to achieve a desired outcome, as opposed to merely claiming the idea of a solution or outcome. McRO, 837 F.3d at 1314-15, 120 USPQ2d at 1102-03; DDR Holdings, 773 F.3d at 1259, 113 USPQ2d at 1107. In this respect, the improvement consideration overlaps with other considerations, specifically the particular machine consideration (see MPEP § 2106.05(b)), and the mere instructions to apply an exception consideration (see MPEP § 2106.05(f)). Thus, evaluation of those other considerations may assist examiners in making a determination of whether a claim satisfies the improvement consideration.”
2B: Claim(s) Provide(s) an Inventive Concept?
No – The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception(s). As discussed above with respect to integration of the abstract idea(s) into a practical application, the use of the additional elements to perform the steps identified in Step 2A – Prong 1 above amounts to no more than mere instructions to apply the exceptions using a generic computer component(s). Mere instructions to apply an exception using a generic computer component(s) cannot provide an inventive concept. The claims are not patent eligible.
Allowable Subject Matter
Claims 1-16 and 21-24 are allowed over the prior art of record. The claims remain rejected under 35 U.S.C. § 101.
The following is a statement of reasons for the indication of allowable subject matter:
Fu et al. (US 10,986,717) most closely addresses the various concepts recited in each of the independent claims, as seen in the last art rejection of claims 1-16 and 21-24 in the Office action dated December 3, 2025. Additionally, Kaplita et al. (US 2021/0084474) discusses use of a sensor-enabled holster (¶¶ 33, 78). Petri et al. (US 10,904,376) controls the operations of devices within a geofence (col. 3: 14-32; col. 21: 15-32). Jeon et al (US 2016/0198295) activates and deactivates functions on a user’s device depending on the geofenced areas the user is leaving and entering (¶ 17).
However, the Examiner finds that one of ordinary skill in the art prior to Applicant’s invention would not have, in light of the teachings of the aforementioned references, found it obvious to create the claimed invention with the level of detail and specific manner of integration of operations as they are presented in each of the independent claims. Therefore, claims 1-16 and 21-24 are deemed to be allowable over the prior art of record.
Conclusion
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/SUSANNA M. DIAZ/
Primary Examiner
Art Unit 3625A