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 02/26/2026.
Claims 1-12 and 20 have been cancelled.
Claims 13 and 21 have been amended.
Claims 13-19 and 21 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 02/26/2026 has been entered.
Response to Arguments
In response to Applicant Arguments /Remarks made in an amendment filled on 02/26/2026:
Regarding 35 USC § 101 rejection:
Applicant argument submitted under the title “Response to Rejections Under 35 USC § 101” in pages 6-11, that:
“Claims 13-19 and 21 stand rejected under 35 U.S.C. § 101 as allegedly being directed to a judicial exception without significantly more. These rejections are respectfully traversed. The MPEP sets forth a revised two-prong test for the directed-to analysis under Step 2A. Prong Two involves "evaluat[ing] whether the claim as a whole integrates the recited judicial exception into a practical application of the exception," such as by reflecting an improvement to technology. MPEP 2106.04(II)(A)(2). The claims are patent eligible at least under Step 2A, Prong Two because the claims are directed to a practical application of technology.
Claim 1, as amended, recites, in part: …
displaying, at the first user interface, aggregated data for each of a plurality of EDI and non-EDI invoices, the aggregated data including one or more of an automated approval status, a manual review status, and an invoice amount, wherein the automated approval status is triggered upon an automated payment at the automated invoice processing API and the automated rejection status is triggered upon the automated rejection at the automated invoice processing API,
selecting an invoice having an automated rejection status;
displaying, at the second user interface, manual review data, the manual review data
including one or more candidate location and a probability that each selectable
location is an intended location;
selecting a candidate location; and
processing the invoice having an automated rejection status …
The instant claims disclose an audit database coupled with a combined set of user interfaces that lead to increased accuracy and efficiency in invoice workflow management and improved user experience compared with conventional solutions. In particular, the instant claims disclose that the audit database includes one or more decoupled rate check rules and models and decoupled event check rules and models which can be accessed via an audit UI. In this manner, a user can independently adjust such rules and models based on a desired level of sensitivity or efficiency. Furthermore, the combined set of user interfaces both display automated approval or rejected statuses, determined via the adjustable rules and models, and also provide a streamlined audit interface for accepting or modifying an automated outcome. Therefore, this system allows for both EDI and non-EDI invoices from a variety of shippers across a first-mile, middle-mile, and last-mile of a retail enterprise system to be automatically, and simultaneously, processed in a coordinated manner, within minimal process dependencies and significantly improved user experiences, thereby resulting in significant improvements in terms of flexibility, speed, and accuracy.
Thus, claim 1 includes a practical application under Prong Two and is patent eligible under Section 101. The remaining claims are patentable under section 101 for similar reasons. Reconsideration and allowance are requested”.
Applicant's arguments have been fully considered but they are not persuasive.
In response, the examiner respectfully disagrees and emphasizes none of the receiving, accessing, performing, receiving, performing, sending, generating, displaying, selecting, displaying, selecting, processing steps, whether taken individually or collectively, have not been shown to affect any form of technical change or improvement whatsoever, and are abstract idea. Applicant's claims have not been shown to modify, reconfigure, manipulate, or transform the computer, computer software, or any technical elements in any discernible manner, much less yield an improvement thereto. There is simply no showing of implementing any of the claim steps, individually or in combination, amounts to a technological improvement, nor the alleged “increased accuracy and efficiency in invoice workflow management and improved user experience compared with conventional solutions” suggested by Applicant. Although Applicant asserts that “resulting in significant improvements in terms of flexibility, speed, and accuracy” the examiner first notes that tracking loads of items within a supply chain and managing corresponding invoices is not reasonably understood as a technology, but instead involves organizing of human activity.
Furthermore, the recited “computer”, “an invoice management software platform”, “audit database can be accessed via an audit UI”, “an automated invoice processing API”, “the audit UI further comprises a first user interface and a second user interface”, this 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. Applicant's Specification acknowledges that nothing more than general purpose computers is needed to implement the invention. Thus, any improvement achieved by automating the claim steps (i.e., using generic computing devices/software) is not a technical improvement, but instead would come from the capabilities of a general-purpose computer rather than the sequence of steps/activities recited in the method itself, which does not materially alter the patent eligibility of the claim.
Even assuming, for the sake of argument, that the claims amount to an improvement over prior art techniques for tracking loads of items within a supply chain and managing corresponding invoices, such an improvement would be considered, at most, an improvement confined within the abstract idea itself, which is not enough to confer eligibility on the claim. For the reasons above, Applicant’s argument is not persuasive.
Regarding Claim Rejections - 35 USC § 103:
Applicant’s arguments, have been fully considered and are persuasive. The 35 USC§ 103 rejection of claims 13-19 and 21 has been withdrawn.
Applicant’s arguments with respect to claim rejections - 35 USC § 103 have been fully considered and are persuasive. The reason to withdraw the prior art rejection of claims 13-19 and 21 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. Therefore, the rejection has been withdrawn.
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 13-19 and 21 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception without significantly more.
Step 1:
Claims 13-19 recite a method, which is directed to a process.
Claim 21 recites a platform, 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 13 and 21 recite the abstract idea of tracking loads of items within a supply chain and managing corresponding invoices, see specification [0001]. This idea is described by the steps of
receiving a plurality of EDI and non-EDI invoices from a plurality of shippers at a rate API, the plurality of EDI and non-EDI invoices including a first generated invoice and a plurality of generated transactions related to shipping charges, wherein the plurality of shippers includes at least a first shipper sending EDI invoices and a second shipper sending non-EDI invoices, the first shipper and the second shipper moving products within one or more of a first-mile portion, middle-mile portion, and last-mile portion;
accessing a set of models and rules such that the models and rules can be manually adjusted based on a desired confidence level, wherein the set of models and rules include one or more of a decoupled rate check model, decoupled rate check rule, decoupled load check model, and decoupled load check rule;
performing a system rate check at the rate API of the plurality of generated transactions related to shipping charges against the models and rules stored to generate a system rate check output;
receiving a plurality of generated transactions related to inventory movements at a load API;
performing a system event check at the load API to generate a system event check output of the plurality of generated transactions related to inventory movements against the models and rules stored;
sending the system rate check and the system event check output;
generating a result, the result corresponding to at least one of automated payment of the first generated invoice or manual review of the first generated invoice based on an indication that the system rate check output and the system event check output are within the set of models and rules stored in response to both the EDI invoices and the non-EDI invoices;
displaying aggregated data for each of a plurality of EDI and non-EDI invoices, the aggregated data including one or more of an automated approval status, a manual review status, and an invoice amount, wherein the automated approval status is triggered upon an automated payment at the automated invoice processing API and the automated rejection status is triggered upon the automated rejection at the automated invoice processing API,
selecting an invoice having an automated rejection status;
displaying manual review data, the manual review data including one or more candidate location and a probability that each selectable location is an intended location;
selecting a candidate location; and
processing the invoice having an automated rejection status
A) These claims recite a certain method of organizing human activity. The claims recite to a certain method of organizing human activity as the above abstract idea limitations are directed to managing personal behavior or relationships or interactions between people. The examiner finds the claims to simply recites steps of following rules or instructions receive information, generate information, display results. The specification states that the invention recites need to rapidly and accurately review and approve invoices and shipment details and provide freight invoice audit capability. Generally speaking, complex supply chain systems are managed using multiple software components that are operated separately from one another. Commercially available software systems are individually available to manage aspects of supply chain shipment management, invoice payment, and auditing. The outputs of these separate systems may then be required to be integrated at yet another in-house software tool or may need to be manually compared between systems to ensure that a particular shipment has been delivered and invoiced correctly (specification [0003]). The Examiner additionally finds the claims to be similar to an example the courts have identified as being a certain method of organizing human activity:
i. filtering content, BASCOM Global Internet v. AT&T Mobility, LLC, 827 F.3d 1341, 1345-46, 119 USPQ2d 1236, 1239 (Fed. Cir. 2016) (finding that filtering content was an abstract idea under step 2A, but reversing an invalidity judgment of ineligibility due to an inadequate step 2B analysis);
ii. considering historical usage information while inputting data, BSG Tech. LLC v. Buyseasons, Inc., 899 F.3d 1281, 1286, 127 USPQ2d 1688, 1691 (Fed. Cir. 2018);
iii. a series of instructions of how to hedge risk, Bilski v. Kappos, 561 U.S. 593, 595, 95 USPQ2d 1001, 1004 (2010).
B) The claims recite a mental process. Before computers one could mentally or a human using paper and pen to receive information, generate information, display results. The claims are merely directed to track loads of items within a supply chain and managing corresponding invoices, all of which are data collection, analysis, and presentation of results. The Examiner find the recited claims to be similar to a claim to "collecting information, analyzing it, and displaying certain results of the collection and analysis," where the data analysis steps are recited at a high level of generality such that they could practically be performed in the human mind, Electric Power Group v. Alstom, S.A., 830 F.3d 1350, 1353-54, 119 USPQ2d 1739, 1741-42 (Fed. Cir. 2016), which the courts have also found to recite a mental process.
No mathematical formulas are expressly recited; the exceptions arise from organizing human activity and mental-process style data handling/presentation.
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 13: computer, an invoice management software platform, audit database can be accessed via an audit UI, an automated invoice processing API, the audit UI further comprises a first user interface and a second user interface,
Claim 21: at least one computing system of a retail enterprise, the at least one computing system including a processor and a memory storing instructions which, when executed, cause the at least one computing system, an invoice management software platform, computer, audit database can be accessed via an audit UI, an automated invoice processing API, the audit UI further comprises a first user interface and a second user interface,
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).
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).
In addition, the dependent claims recite:
Step 2A, Prong 1 (Is a judicial exception recited?):
Dependent claims 14-19 recitations further narrowing the abstract idea recited in the independent claims 13 and 21 and therefore directed towards the same abstract idea.
Step 2A, Prong 2 and Step 2B:
The dependent claims 14-19 further narrow the abstract idea recited in the independent claims 13 and 21 and are therefore directed towards the same abstract idea.
The dependent claims recite the following additional limitations:
Claims 14 and 19: computer,
Claim 18: the automated invoice processing API,
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 tracking loads of items within a supply chain and managing corresponding 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 13-19 and 21, 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 02/26/2026. The claims 13-19 and 21, 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 13-19 and 21 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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