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 .
Response to Amendment
The examiner acknowledges applicant’s arguments in the Response dated January 9, 2026 as part of the Request for Continued Examination directed to the rejection set forth in the Final Office Action dated November 10, 2025. Claims 1, 4-19, and 21-23 are pending in the application and subject to examination as part of this office action.
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, 4-19, and 21-23 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
The determination of subject matter eligibility under 35 USC 101, relies on the Mayo/Alice two-step analysis.
In step 1 of the analysis, the claims are evaluated to determine whether they fall within one of the four statutory categories (i.e., process, machine, manufacture, or composition of matter). In the present case, claims 1 and 4-16 are directed to a system controller (i.e., a machine), claims 17-18 and 23 are directed to a system controller device (i.e., a machine), and claims 19 and 21-22 is directed to a method (i.e., a process). The claims are, therefore directed to one of the four statutory categories.
Under prong 1 of step 2A, the examiner is directed to determine whether the claim recites a judicial exception. The claims are compared to groupings of subject matter that have been found by courts as abstract ideas. These groupings include
(a) Mathematical concepts—mathematical relationships, mathematical formulas or equations, mathematical calculations;
(b) Certain methods of organizing human activity—fundamental economic principles or practices (including hedging, insurance, mitigating risk); commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations); managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions); and
(c) Mental processes—concepts performed in the human mind (including an observation, evaluation, judgment, opinion).
Claim 1 recites (the abstract idea is underlined) a system controller for a plurality of Electronic Gaming Machines (EGMs) comprising:
a processor circuit; and
a memory comprising machine-readable instructions that, when executed by the processor circuit, cause the processor circuit to:
control a Graphical User Interface (GUI) of the system controller to cause a display device of the system controller to display:
a system path area comprising a depiction of a first hierarchy path comprising a top level of a hierarchy of the plurality of EGMs, a first sub-level of the hierarchy, and a plurality of nested sub-levels of the hierarchy between the top level and the first sub-level; and
an object group area comprising depictions of a first plurality of objects in the first sub-level of the hierarchy, each object of the first plurality of objects
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comprising one of:
an EGM in the first sub-level; and a sub-level below the first sub-level;
in response to receipt of an alert condition indication relating to a first EGM of the plurality of EGMs in an alert condition, control the GUI to cause the display device to display a depiction of an alert relating to a first object of the first plurality of objects the first object comprising one of:
the first EGM in the alert condition; and
a second sub-level below the first sub-level containing the first EGM in the alert condition; and
in response to a user input associated with the first object received via an input device of the system controller,:
control the GUI to cause the display device to display a depiction of the first EGM in the alert condition; and
control the GUI to modify the object group area to display depictions of a second plurality of objects in the second sub-level comprising the first EGM in the alert condition.
Claim 17 recites (the abstract idea is underlined) a computer system controller device for a plurality of Electronic Gaming Machines (EGMs) comprising:
a display device;
an input device;
a processor circuit; and
a memory comprising machine-readable instructions that, when executed by the processor circuit, cause the processor circuit to:
control a Graphical User Interface (GUI) of the system controller to display, by the display device:
a system path area comprising a depiction of a first hierarchy path comprising a top level of a hierarchy of a plurality of EGMs, a first sub-level of the hierarchy, and a plurality of nested sub-levels of the hierarchy between the top level and the first sub-level; and
an object group area comprising depictions of a first plurality of objects in the first sub-level of the hierarchy, each object of the first plurality of objects comprising one of:
a EGM in the first sub-level; and
a sub-level below the first sub-level;
in response to receipt of an alert condition indication relating to a first EGM of the plurality of EGMs in an alert condition, control the GUI to display, by the display device, a depiction of an alert relating to a first object of the first plurality of objects, the first object comprising one of:
the first EGM in the alert condition; and
a second sub-level below the first sub-level containing the first EGM in the alert condition,
wherein the GUI further comprises an object group overview area comprising:
depictions of a second plurality of objects in the first sub-level of the hierarchy, each object of the second plurality of objects comprising one of:
an EGM in the first sub-level; and
a sub-level below the first sub-level; and
a graphical area indication comprising a first subset of objects of the second plurality of objects, the first subset of objects corresponding to the first plurality of objects displayed in the object group area; and
in response to a user input associated with a second subset of objects of the second plurality of objects:
control the GUI to modify a graphical area indication to comprise the second subset of objects; and
control the to modify the object group area to display depictions of the second subset of objects.
Claim 19 recites (the abstract idea is underlined) a method comprising:
controlling a Graphical User Interface (GUI) to display, by a display device of a system controller for a plurality of Electronic Gaming Machines (EGMs):
a system path area comprising a depiction of a first hierarchy path comprising a top level of a hierarchy of a plurality of EGMs, a first sub-level of the hierarchy, and a plurality of nested sub-levels of the hierarchy between the top level and the first sub- level; and
an object group area comprising depictions of a first plurality of objects in the first sub-level of the hierarchy, each object of the first plurality of objects comprising one of:
an EGM in the first sub-level; and
a sub-level below the first sub-level;
receiving an alert indication relating to a first EGM of the plurality of EGMs in an alert condition; and
in response to receiving the alert indication, displaying, by the display device, a depiction of an alert relating to a first object of the first plurality of objects, the first object comprising one of:
the first EGM in the alert condition; and
a second sub-level below the first sub-level containing the first EGM in the alert condition; and
in response to a user input associated with a filter condition:
controlling the GUI to display an indication of the filter condition in an object filter area of the GUI; and
controlling a GUI to modify the object group area to modify depictions of a first subset of the first plurality of objects not corresponding to the filter condition.
The present claims are directed to a graphical user interface (GUI) for visualization of an EGM or gaming device network, and related systems, devices, and methods (Specification [0001]). These steps fall under the category of certain methods of organizing human activity. Specifically, they are directed to the sub-category of managing personal behavior or relationships or interactions between people because the claims disclose filtering content, similar to BASCOM Global Internet v. AT&T Mobility, LLC, 827 F.3d 1341, 1345-46, 119 USPQ2d 1236, 1239 (Fed. Cir. 2016) .
The present claims also fall into the category of mental processes because the steps "can be performed in the human mind, or by a human using a pen and paper." In particular, claims 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).
Accordingly, the claim recites an abstract idea.
Under prong 2 of Step 2A, the examiner considers whether additional elements integrate the abstract idea into a practical application. To do so, the examiner looks to the following exemplary considerations, looking at the elements individually and in combination:
• an additional element reflects an improvement in the functioning of a computer, or an improvement to other technology or technical field;
• an additional element that applies or uses a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition (not considered relevant to the present claims);
• an additional element implements a judicial exception with, or uses a judicial exception in conjunction with, a particular machine or manufacture that is integral to the claim;
• an additional element effects a transformation or reduction of a particular article to a different state or thing; and
• an additional element applies or uses the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception.
The additional elements in the present claims are a plurality of Electronic Gaming Machines (EGMs), a processor circuit, a memory, a display device, an EGM, an input device, and a system controller. The additional elements do no integrate the judicial exception into a practical application. In particular, the additional elements do not reflect an improvement in the functioning of a computer, or an improvement to other technology or technical field. The additional elements do not implement a judicial exception with, or uses a judicial exception in conjunction with, a particular machine or manufacture that is integral to the claim. The additional elements do not effect a transformation or reduction of a particular article to a different state or thing. The additional elements do not apply or use the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment. Accordingly, the additional elements do not integrate the abstract idea into a practical application because they does not impose any meaningful limits on practicing the abstract idea.
Under step 2B, the examiner evaluates whether the additional elements amount to significantly more than the judicial exception itself. The examiner considers if the additional elements:
• add a specific limitation or combination of limitations that are not well-understood, routine, conventional activity in the field, which is indicative that an inventive concept may be present; or
• simply appends well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception, which is indicative that an inventive concept may not be present.
The present claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. The additional elements are well-understood, routine, or conventional, as shown:
a processor circuit, a memory, a display device, an input device, a system controller (Walker et al., US 2004/0082384 A1, components well known in the art, specifically a processor, Ram and ROM, a data storage device, a random number generator, a communication port, a hopper controller, a hopper, a video controller, a touch screen, a coin acceptor controller, a coin acceptor, a bill acceptor controller, a bill acceptor, a reel controller, reels, an input device, an output device and a sensor [0058]); and
a plurality of Electronic Gaming Machines (EGMs), an EGM (Parham, US 2006/0089196 A1, the design and operation of gaming devices is well known and conventional gaming machines are available such as from International Gaming Technology.TM. and Bally.TM. [0022]).
Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept.
As a result, the claims are not directed to patent eligible subject matter.
Claim Rejections - 35 USC § 112
The following is a quotation of 35 U.S.C. 112(b):
(b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention.
The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph:
The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention.
Claim 17 recites “control the to modify” (line 38). It appears that applicant intended to insert an acronym (possibly “GUI”). Dependent claims 18 and 23 inherit this discrepancy by nature of their dependencies. Appropriate correction is required.
Prior Art
There are currently no prior art rejections against claims 1, 4-19, and 21-23.
Response to Arguments
Applicant's arguments filed January 9, 2026 have been fully considered but they are not persuasive.
Applicant argues “
As previously discussed, claim 1 is not directed to a judicial exception, and accordingly satisfies the first prong. In particular, the term "certain methods of organizing human activity" grouping is specifically limited to "certain" methods, i.e., specific enumerated methods and not all methods of organizing human activity. These "certain" methods consist of fundamental economic principles or practices, commercial or legal interactions, managing personal behavior, and relationships or interactions between people. Here, in contrast, claim 1 is directed to, inter alia, a specialized system controller for a plurality of EGMs that performs a detailed set of operations that, taken as a whole, describe a game management arrangement at the plurality of EGMs. Thus, for at least this reason, claim 1 is eligible under step 2A. (Response [pp. 11-12])
Applicant’s argument that “claim 1 is directed to, inter alia, a specialized system controller for a plurality of EGMs that performs a detailed set of operations that, taken as a whole, describe a game management arrangement at the plurality of EGMs” is not persuasive.
In BASCOM, the patent at issue was directed to filtering content on the internet. The Court stated:
The claims of the ’606 patent are directed to filtering content on the Internet. Specifically, claim 1 is directed to a “content filtering system for filtering content retrieved from an Internet computer network.” ’606 patent, 6:62– 64. Claim 22 similarly is directed to an “ISP server for filtering content.” Id. at 8:63. The specification reinforces this notion by describing the invention as relating “generally to a method and system for filtering Internet content.” Id. at 1:7–11. We agree with the district court that filtering content is an abstract idea because it is a longstanding, well-known method of organizing human behavior, similar to concepts previously found to be abstract. See Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 1367 (Fed. Cir. 2015) (holding that “tracking financial transactions to determine whether they exceed a pre-set spending limit (i.e., budgeting)” is an abstract idea that “is not meaningfully different from the ideas found to be abstract in other cases . . . involving methods of organizing human activity”); see also Content Extraction, 776 F.3d at 1347 (finding that “1) collecting data, 2) recognizing certain data within the collected data set, and 3) storing that recognized data in a memory” was an abstract idea because “data collection, recognition, and storage is undisputedly well-known” and “humans have always performed these functions”); Digitech Image Techs., LLC v. Elecs. for Imaging, Inc., 758 F.3d 1344, 1350 (Fed. Cir. 2014) (finding that “a process of organizing information through mathematical correlations” is an abstract idea). An abstract idea on “an Internet computer BASCOM GLOBAL INTERNET v. AT&T MOBILITY LLC 13 network” or on a generic computer is still an abstract idea. See Intellectual Ventures I, 792 F.3d at 1368 n.2 (collecting cases). BASCOM Global Internet Services, Inc. v. AT&T Mobility LLC, 2015-1763, slip op. at 12-13 (Fed. Cir., June 27, 2016.
The present claims filter the gaming devices based on hierarchy paths and alert conditions. As such, the examiner maintains that the present claims are directed to filtering content similar to BASCOM and therefore falls into the subcategory of managing personal behavior or relationships or interactions between people, which falls under certain methods of organizing human activity.
Additionally, the present claims also fall into the category of mental processes because the claims are similar to the claims recited in Electric Power Group, LLC v. ALSTOM S.A. In Electric Power Group, the patents at issue described systems and methods for performing real-time performance monitoring of an electric power grid by collecting data from multiple data sources, analyzing the data, and displaying the results. Electric Power Group, LLC v. Alstom S.A., 2015-1778, slip op. at 2 (Fed. Cir., Aug. 1, 2016).
The court in Electric Power Group stated: “Though lengthy and numerous, the claims do not go beyond requiring the collection, analysis, and display of available information in a particular field, stating those functions in general terms, without limiting them to technical means for performing the functions that are arguably an advance over conventional computer and network technology” (Electric Power Group, LLC v. Alstom S.A., 2015-1778, slip op. at 2 (Fed. Cir., Aug. 1, 2016)).
The court in Electric Power Group further stated
Information as such is an intangible. See Microsoft Corp. v. AT & T Corp., 550 U.S. 437, 451 n.12 (2007); Bayer AG v. Housey Pharm., Inc., 340 F.3d 1367, 1372 (Fed. Cir. 2003). Accordingly, we have treated collecting information, including when limited to particular content (which does not change its character as information), as within the realm of abstract ideas. See, e.g., Internet Patents, 790 F.3d at 1349; OIP Techs., Inc. v. Amazon. com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015); Content Extraction & Transmission LLC v. Wells Fargo Bank, Nat’l Ass’n, 776 F.3d 1343, 1347 (Fed. Cir. 2014); Digitech Image Techs., LLC v. Elecs. for Imaging, Inc., 758 F.3d 1344, 1351 (Fed. Cir. 2014); CyberSource Corp. v. Retail Decisions, Inc., 654 F.3d 1366, 1370 (Fed. Cir. 2011). In a similar vein, we have treated analyzing information by steps people go through in their minds, or by mathematical algorithms, without more, as essentially mental processes within the abstract-idea category. See, e.g., TLI Commc’ns, 823 F.3d at 613; Digitech, 758 F.3d at 1351; SmartGene, Inc. v. Advanced Biological Labs., SA, 555 F. App’x 950, 955 (Fed. Cir. 2014); Bancorp Servs., L.L.C. v. Sun Life Assurance Co. of Canada (U.S.), 687 F.3d 1266, 1278 (Fed. Cir. 2012); CyberSource Corp. v. Retail Decisions, Inc., 654 F.3d 1366, 1372 (Fed. Cir. 2011); SiRF Tech., Inc. v. Int’l Trade Comm’n, 601 F.3d 1319, 1333 (Fed. Cir. 2010); see also Mayo, 132 S. Ct. at 1301; Parker v. Flook, 437 U.S. 584, 589–90 (1978); Gottschalk v. Benson, 409 U.S. 63, 67 (1972). And we have recognized that merely presenting the results of abstract processes of collecting and analyzing information, without more (such as identifying a particular tool for presentation), is abstract as an ancillary part of such collection and analysis. See, e.g., Content Extraction, 776 F.3d at 1347; Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709, 715 (Fed. Cir. 2014).
Here, the claims are clearly focused on the combination of those abstract-idea processes. The advance they purport to make is a process of gathering and analyzing ELECTRIC POWER G 8 ROUP, LLC v. ALSTOM S.A. information of a specified content, then displaying the results, and not any particular assertedly inventive technology for performing those functions. They are therefore directed to an abstract idea. The claims here are unlike the claims in Enfish. There, we relied on the distinction made in Alice between, on one hand, computer-functionality improvements and, on the other, uses of existing computers as tools in aid of processes focused on “abstract ideas” (in Alice, as in so many other § 101 cases, the abstract ideas being the creation and manipulation of legal obligations such as contracts involved in fundamental economic practices). Enfish, 822 F.3d at 1335–36; see Alice, 134 S. Ct. at 2358–59. That distinction, the Supreme Court recognized, has common-sense force even if it may present line-drawing challenges because of the programmable nature of ordinary existing computers. In Enfish, we applied the distinction to reject the § 101 challenge at stage one because the claims at issue focused not on asserted advances in uses to which existing computer capabilities could be put, but on a specific improvement—a particular database technique—in how computers could carry out one of their basic functions of storage and retrieval of data. Enfish, 822 F.3d at 1335–36; see Bascom, 2016 WL 3514158, at *5; cf. Alice, 134 S. Ct. at 2360 (noting basic storage function of generic computer). Electric Power Group, LLC v. Alstom S.A., 2015-1778, slip op. at 7-8 (Fed. Cir., Aug. 1, 2016)
Applicant goes on to state:
In addition, claim 1 recites a "system controller" for a plurality of "EGMs" that "control[s] a Graphical User Interface (GUI) ". As a result, the claims are similar to the claims at issue in Core Wireless Licensing S.A.R.L., v. LG Electronics, Inc., 880 F.3d 1356 (Fed Cir 2018) (finding claims directed to an improved user interface for electronic devices to be patent eligible). Thus, for this additional reason, claim 1 is eligible under step 2A, prong one. (Response [p. 12])
The presence or absence of hardware components does not preclude the identification of an abstract idea under prong 1 of step 2A.
Next, applicant argues that the rejections of claims 1 and 4-20 violates the Administrative Procedures Act (APA) (Response [p. 12]). Applicant goes on to recite claim limitations from several issued patents arguing that the present claims recite features that were previously found to be subject matter eligible in the same area of technology and in the same art unit (Response [pp. 12-18]).
Patent eligibility (Alice/Mayo test) is determined on a case-by-case basis, and inconsistencies in past examination do not invalidate a current, correct rejection. The USPTO examines each application independently based on its own merits and claim language. The existence of similar, previously issued patents does not compel the USPTO to allow a new application that is found to be directed to an abstract idea.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to WERNER G GARNER whose telephone number is (571)270-7147. The examiner can normally be reached M-F 7:30-15:30 EST.
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/WERNER G GARNER/ Primary Examiner, Art Unit 3715