Prosecution Insights
Last updated: April 19, 2026
Application No. 18/142,657

Opposing Polarity Machine Learning Device and Method

Non-Final OA §101
Filed
May 03, 2023
Examiner
MANG, VAN C
Art Unit
2126
Tech Center
2100 — Computer Architecture & Software
Assignee
Bottomline Technologies Inc.
OA Round
1 (Non-Final)
75%
Grant Probability
Favorable
1-2
OA Rounds
3y 10m
To Grant
99%
With Interview

Examiner Intelligence

Grants 75% — above average
75%
Career Allow Rate
181 granted / 241 resolved
+20.1% vs TC avg
Strong +27% interview lift
Without
With
+26.9%
Interview Lift
resolved cases with interview
Typical timeline
3y 10m
Avg Prosecution
31 currently pending
Career history
272
Total Applications
across all art units

Statute-Specific Performance

§101
31.2%
-8.8% vs TC avg
§103
42.5%
+2.5% vs TC avg
§102
8.0%
-32.0% vs TC avg
§112
13.5%
-26.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 241 resolved cases

Office Action

§101
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 . Information Disclosure Statement The information disclosure statement (IDS) submitted on 05/03/2023 is in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner. Claim Rejections - 35 USC § 101 35 U.S.C. 101 reads as follows: Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title. Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea and does not integrate the judicial exception into a practical application or amount to significantly more than the judicial exception. Regarding claim 1 Step 1: The claim recites a device; therefore, it falls into the statutory category of machine. Step 2A Prong 1: The claim recites multiple mental processes, as explained below. The claim recites, inter alia: “…the memory comprising: historical records including records of opposing polarities; an input record received from the input device; “…separate the historical records into a first polarity list of the historical records and a second polarity list of the historical records;” This limitation is directed to the abstract idea of a mental process (concepts performed in the human mind, including observation and evaluation [see MPEP 2106.04(a)(2) III. C.]). “…combine the first polarity confidence measure with the second polarity confidence measure to form a combined confidence measure; and output the combined confidence measure on the display.” This limitation is directed to the abstract idea of a mental process (concepts performed in the human mind, including observation and evaluation [see MPEP 2106.04(a)(2) III. C.]). Step 2A Prong 2: This judicial exception is not integrated into a practical. In particular, the claim only recites additional elements that are mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea. See MPEP 2106.05(f). The additional element of “An opposing polarity machine learning device comprising: circuitry; a communications interface connected to the circuitry; an input device connected to the circuitry; and machine readable media with instructions for the circuitry to: a display connected to the circuitry; and memory, connected to the circuitry… train a first machine learning model by processing the first polarity list of the historical records through a machine learning algorithm;… train a second machine learning model by processing the second polarity list of the historical records through the machine learning algorithm …process the input record through the first machine learning model to form a first polarity confidence measure; process the input record through the second machine learning model to form a second polarity confidence measure”, as drafted, is reciting generic computer components. The generic computer components in these steps are recited at a high-level of generality (i.e., as a generic computer component performing a generic computer function) such that it amounts no more than mere instructions to apply the exception using a generic computer component. In addition, the claim limitation “store the first machine learning model in the memory; … store the second machine learning model in the memory” as explained by the Supreme Court, the addition of insignificant extra-solution activity does not amount to an inventive concept, particularly when the activity is well-understood or conventional. See MPEP 2106.05(g). Accordingly, this additional element does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Step 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. The additional element of using generic computer components to perform the abstract idea 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. The only remaining limitation of the claim “store the first machine learning model in the memory; … store the second machine learning model in the memory” constitute storing and retrieving information in memory, which the courts have found to be well-understood, routine, and conventional. See MPEP 2106.05(d)(II); Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015). Accordingly, this additional element does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Regarding claim 2 Step 1: The claim recites a device; therefore, it falls into the statutory category of machine. Step 2A Prong 1: “where the instructions further include an output of the first polarity confidence measure and the second polarity confidence measure.” This limitation is directed to the abstract idea of a mental process (including an observation, evaluation, judgement, opinion) which can be performed by the human mind, or by a human using pen and paper (see MPEP 2106.04(a)(2) III. C.). Thus, the judicial exception is not integrated into a practical application (see MPEP 2106.04(d) I.), failing step 2A prong 2. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception under step 2B. Regarding claim 3 Step 1: The claim recites a device; therefore, it falls into the statutory category of machine. Step 2A Prong 1: “where the instructions further include an output of at least a portion of the input record.” This limitation is directed to the abstract idea of a mental process (including an observation, evaluation, judgement, opinion) which can be performed by the human mind, or by a human using pen and paper (see MPEP 2106.04(a)(2) III. C.). Thus, the judicial exception is not integrated into a practical application (see MPEP 2106.04(d) I.), failing step 2A prong 2. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception under step 2B. Regarding claim 4 Step 1: The claim recites a device; therefore, it falls into the statutory category of machine. Step 2A Prong 1: The claim recites multiple mental processes, as explained below. The claim recites, inter alia: “where the instructions further include an input of an indication of agreement with the combined confidence” This limitation is directed to the abstract idea of a mental process (including an observation, evaluation, judgement, opinion) which can be performed by the human mind, or by a human using pen and paper (see MPEP 2106.04(a)(2) III. C.). Thus, the judicial exception is not integrated into a practical application (see MPEP 2106.04(d) I.), failing step 2A prong 2. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception under step 2B. Regarding claim 5 Step 1: The claim recites a device; therefore, it falls into the statutory category of machine. Step 2A Prong 1: Step 2A Prong 2: This judicial exception is not integrated into a practical. In particular, the claim only recites additional elements that are mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea. See MPEP 2106.05(f). The additional element of “where the machine learning algorithm is random forest.”, as drafted, is reciting generic computer components. The generic computer components in these steps are recited at a high-level of generality (i.e., as a generic computer component performing a generic computer function) such that it amounts no more than mere instructions to apply the exception using a generic computer component. Accordingly, this additional element does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. The claim is directed to an abstract idea. Step 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into practical application, the additional element of using generic computer components to perform the abstract idea 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. Thus, the claim is not patent eligible. Regarding claim 6 Step 1: The claim recites a device; therefore, it falls into the statutory category of machine. Step 2A Prong 1: Step 2A Prong 2: This judicial exception is not integrated into a practical. In particular, the claim only recites additional elements that are mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea. See MPEP 2106.05(f). The additional element of “where the machine learning algorithm is KMeans”, as drafted, is reciting generic computer components. The generic computer components in these steps are recited at a high-level of generality (i.e., as a generic computer component performing a generic computer function) such that it amounts no more than mere instructions to apply the exception using a generic computer component. Step 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. The additional element of using generic computer components to perform the abstract idea 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, this additional element does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Regarding claim 7 Step 1: The claim recites a device; therefore, it falls into the statutory category of machine. Step 2A Prong 1: Step 2A Prong 2: This judicial exception is not integrated into a practical. In particular, the claim only recites additional elements that are mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea. See MPEP 2106.05(f). The additional element of “where the machine learning algorithm is distributed across a plurality of the opposing polarity machine learning devices.”, as drafted, is reciting generic computer components. The generic computer components in these steps are recited at a high-level of generality (i.e., as a generic computer component performing a generic computer function) such that it amounts no more than mere instructions to apply the exception using a generic computer component. Step 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into practical application, the additional element of using generic computer components to perform the abstract idea 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. Thus, the claim is not patent eligible. Regarding claim 8 Step 1: The claim recites a device; therefore, it falls into the statutory category of machine. Step 2A Prong 1: Step 2A Prong 2: This judicial exception is not integrated into a practical. In particular, the claim only recites additional elements that are mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea. See MPEP 2106.05(f). The additional element of “where the first machine learning model is trained on one of the opposing polarity machine learning devices and the second machine learning model is trained on another opposing polarity machine learning device”, as drafted, is reciting generic computer components. The generic computer components in these steps are recited at a high-level of generality (i.e., as a generic computer component performing a generic computer function) such that it amounts no more than mere instructions to apply the exception using a generic computer component. Step 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into practical application, the additional element of using generic computer components to perform the abstract idea 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. Thus, the claim is not patent eligible. Regarding claim 9 Step 1: The claim recites a device; therefore, it falls into the statutory category of machine. Step 2A Prong 1: The claim recites multiple mental processes, as explained below. The claim recites, inter alia: “where the instructions further include a subtraction of the first polarity confidence measure from the second polarity confidence measure to obtain the combined confidence measure.” This limitation is directed to the abstract idea of a mental process (including an observation, evaluation, judgement, opinion) which can be performed by the human mind, or by a human using pen and paper (see MPEP 2106.04(a)(2) III. C.). Thus, the judicial exception is not integrated into a practical application (see MPEP 2106.04(d) I.), failing step 2A prong 2. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception under step 2B. Regarding claim 10 Step 1: The claim recites a device; therefore, it falls into the statutory category of machine. Step 2A Prong 1: The claim recites multiple mental processes, as explained below. The claim recites, inter alia: “where the instructions further include an addition of a threshold to the combined confidence measure.” This limitation is directed to the abstract idea of a mental process (including an observation, evaluation, judgement, opinion) which can be performed by the human mind, or by a human using pen and paper (see MPEP 2106.04(a)(2) III. C.). Thus, the judicial exception is not integrated into a practical application (see MPEP 2106.04(d) I.), failing step 2A prong 2. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception under step 2B. Regarding claims 11-20 Claim 11-20 recite analogous limitations to claims 1-10 and therefore is rejected on the same ground as claims 1-10. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to VAN C MANG whose telephone number is (571)270-7598. The examiner can normally be reached Mon - Fri 8:00-5:00pm. 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, David Yi can be reached at 5712707519. 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. /VAN C MANG/Primary Examiner, Art Unit 2126
Read full office action

Prosecution Timeline

May 03, 2023
Application Filed
Dec 27, 2025
Non-Final Rejection — §101 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12591809
MACHINE LEARNING PLATFORM
2y 5m to grant Granted Mar 31, 2026
Patent 12591830
Machine Learning-Based Approach to Identify Software Components
2y 5m to grant Granted Mar 31, 2026
Patent 12586022
Machine Learning-Based Approach to Characterize Software Supply Chain Risk
2y 5m to grant Granted Mar 24, 2026
Patent 12579444
MACHINE LEARNING MODEL GENERATION AND UPDATING FOR MANUFACTURING EQUIPMENT
2y 5m to grant Granted Mar 17, 2026
Patent 12561555
NETWORK OF TENSOR TIME SERIES
2y 5m to grant Granted Feb 24, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

AI Strategy Recommendation

Get an AI-powered prosecution strategy using examiner precedents, rejection analysis, and claim mapping.
Powered by AI — typically takes 5-10 seconds

Prosecution Projections

1-2
Expected OA Rounds
75%
Grant Probability
99%
With Interview (+26.9%)
3y 10m
Median Time to Grant
Low
PTA Risk
Based on 241 resolved cases by this examiner. Grant probability derived from career allow rate.

Sign in with your work email

Enter your email to receive a magic link. No password needed.

Personal email addresses (Gmail, Yahoo, etc.) are not accepted.

Free tier: 3 strategy analyses per month