Prosecution Insights
Last updated: April 19, 2026
Application No. 18/180,896

SYSTEM AND METHOD ENABLING ACCELERATED DEVELOPMENT AND APPLICATION OF AUTONOMOUS ECONOMIC AGENTS

Final Rejection §101
Filed
Mar 09, 2023
Examiner
PATEL, DIVESH
Art Unit
3696
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
UVUE LTD.
OA Round
4 (Final)
53%
Grant Probability
Moderate
5-6
OA Rounds
3y 0m
To Grant
92%
With Interview

Examiner Intelligence

Grants 53% of resolved cases
53%
Career Allow Rate
64 granted / 120 resolved
+1.3% vs TC avg
Strong +39% interview lift
Without
With
+39.1%
Interview Lift
resolved cases with interview
Typical timeline
3y 0m
Avg Prosecution
19 currently pending
Career history
139
Total Applications
across all art units

Statute-Specific Performance

§101
42.6%
+2.6% vs TC avg
§103
38.7%
-1.3% vs TC avg
§102
3.4%
-36.6% vs TC avg
§112
11.2%
-28.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 120 resolved cases

Office Action

§101
DETAILED ACTION Notice of AIA Status The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Status of Claims This action is in reply to the first amendment to non-final filed on December 4, 2025. Claims 21–30 have been added. Claims 1–20 have been canceled. Claims 21–30 are currently pending and have been examined. This action is made FINAL. Response to Amendment The amendment filed December 4, 2025 has been entered. Claims 21–30 remain pending in the application. Claim Rejections - 35 USC § 101 The following is a quotation of 35 U.S.C. 101: 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 21–30 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. First of all, claims must be directed to one or more of the following statutory categories: a process, a machine, a manufacture, or a composition of matter. Claims 21–25 are directed to a machine (“A system”), and claims 26–30 are directed to a process (“A method”). Thus, claims 21–30 satisfy Step One because they are all within one of the four statutory categories of eligible subject matter. Claims 21–30, however, are directed to an abstract idea without significantly more. For claim 1, the specific limitations that recite an abstract idea are: . . . a domain-independent protocol specification language defining a format, structure, and rules for communication . . .; . . . transform a protocol specification into an executable protocol implementation and configured to perform syntax and semantic validation of service-request messages defined by the protocol specification; and wherein the protocol specification further defines a dialogue-based bilateral interaction protocol comprising steps, conditions, and sequencing of message exchanges occurring in turns between . . . agents; . . . receive, from a client. . ., a service request specifying an action; generate, based on the service request, a protocol specification expressed in the domain-independent protocol specification language; generate an invocation message requesting protocol generation for the protocol specification; select, from among the external . . . models, a given external . . . model associated with the action; and transmit the invocation message and the protocol specification . . .; . . . receive the invocation message and the protocol specification; compute . . . an intermediate model output representing an insight; and transmit the intermediate model output representing an insight . . .; . . . receive the intermediate model output representing an insight and to transmit metadata comprising the protocol specification, the intermediate model output representing an insight, and data representing contextual information associated with the service request . . .; . . . upon receiving the metadata, to apply metadata, comprising the protocol specification, the intermediate model output representing an insight, and data representing contextual information associated with the service request, . . . to generate a computed model output representing an inference and to transmit the computed model output representing an inference . . .; wherein each . . . model is further configured to provide its learned representations . . .; . . . analyze the metadata and the learned representations of the plurality . . . with respect to each other by comparing learned patterns and features across the models and identifying commonalities and differences, and to generate the computed model output representing an inference related to at least the protocol specification based on the analysis; and . . . generate an implementation of the at least one protocol corresponding to the protocol specification using the computed model output representing an inference and the rules of the domain-independent protocol specification language, and . . . execute the generated protocol implementation to perform the action associated with the service request received from the client. . .. The claims, therefore, recite executing a service request, which is the abstract idea of certain methods of organizing human activity because they recite a commercial interaction. This is further evidenced by the specification, which indicates that the protocols recited in the claims relate to economic transactions and other interactions in various problem domains, including finance (U.S. Patent App. Pub. No. 2023/0281491, ¶ 60, 99: AEAs transact with each another for wide range of economic transactions; ¶ 59: problem domains include energy, finance, and supply chain, for example). The judicial exception recited above is not integrated into a practical application. The additional elements of the claims are various generic technologies and computer components to implement this abstract idea (“decentralized computing network”, “computing devices”, “processor”, “memory device”, “communication interface”, “software framework”, “autonomous economic agents (AEAs)”, “software modules”, “distributed computing node”, “protocol generator”, “external computing arrangement”, “distributed-ledger arrangement”, and “machine-learning (ML) models”). These additional elements are not integrated into a practical application because the invention merely applies the abstract idea to generic computer technology, using the computer to create and combine protocols to implement interactions between parties. Because the invention is using the computer simply as a tool to perform the abstract idea on, the judicial exception is not integrated into a practical application. Finally, the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, as discussed above, the additional elements in combination are at a high level of generality such that they amount to no more than mere instructions to apply the abstract idea using generic components. Because merely “applying” the exception using generic computer components cannot provide an inventive concept, the additional elements do not recite significantly more than the judicial exception. Thus, claim 21 is not patent eligible. Independent claim 26 is rejected as ineligible subject matter under 35 U.S.C. 101 for substantially the same reasons as independent system claim 21. There are no additional elements recited in these claims other than the generic technology and computer parts discussed above (“autonomous economic agents (AEAs)”, “decentralized computing network”, “computing devices”, “processor”, “memory device”, “communication interface”, “software framework”, “software modules”, “distributed computing node”, “protocol generator”, “external computing arrangement”, “distributed-ledger arrangement”, and “machine-learning (ML) models”). The only differences are that the features of claim 21 are implemented by a method in claim 26. Thus, because the same analysis should be used for all categories of claims, claim 26 is also not patent eligible. See Alice Corp. Pty. Ltd. v. CLS Bank Int'l, 134 S. Ct. 2347, 2354 (2014). Dependent claims 22–25 and 27–30 have been given the full two part analysis, analyzing the additional limitations both individually and in combination. The dependent claims, when analyzed individually and in combination, are also held to be patent ineligible under 35 U.S.C. 101. For claims 22 and 27, the additional recited limitations of these claims merely further narrow the abstract idea discussed above. These dependent claims only narrow the service request in claims 21 and 26 by further specifying the technological setup—“programming language”, “operating system”, “library”, “computational resources”, and “platform”. The limitations of these claims fail to integrate the abstract idea into a practical application because these claims do not introduce additional elements other than the generic components discussed above (“AEA”). These dependent claims, therefore, also amount to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitations of these dependent claims fail to establish that the claims provide an inventive concept because claims that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept. For claims 23, 24, 28, and 29, the additional recited limitations of these claims merely further narrow the abstract idea discussed above. These dependent claims only narrow the service request in claims 21 and 26 by further specifying the combination performed—“combination of one or more protocols, . . . skills, and . . . connections” and “swapping . . . adding . . . or removing a skill, protocol, or connection”. The limitations of these claims fail to integrate the abstract idea into a practical application because these claims do not introduce additional elements other than the generic components discussed above (“AEA”). These dependent claims, therefore, also amount to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitations of these dependent claims fail to establish that the claims provide an inventive concept because claims that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept. For claims 25 and 30, the additional recited limitations of these claims merely further narrow the abstract idea discussed above. These dependent claims only narrow the service request in claims 21 and 26 by further specifying the interactions performed—“interact in mixed cooperative and adversarial environments”. The limitations of these claims fail to integrate the abstract idea into a practical application because these claims do not introduce additional elements other than the generic components discussed above (“protocol generator” and “AEA”). These dependent claims, therefore, also amount to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitations of these dependent claims fail to establish that the claims provide an inventive concept because claims that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept. Response to Arguments Claim Rejections Under 35 U.S.C. § 101 Applicant’s arguments filed on December 4, 2025 have been fully considered but they are not persuasive. First, Applicant argues that the claimed invention improves the functioning of autonomous agent systems and multi-model machine-learning interfaces. Applicant cites the features of the newly added independent claims, and explains that the claims allows models to share information without exposing internal metadata. Applicant therefore argues that this is a technical arrangement that improves system reliability and model interoperability, while reducing data processing and transmission. These features highlighted by Applicant, however, merely specify how data is being communicated. The claims are therefore merely using the technology to transfer data more efficiently and securely, rather than improving the technology itself in any way. Applicant further argues that the claims recite a protocol specification defining steps, conditions, and sequencing of message exchanges, which is a rules-based mechanism for controlling automated interactions, which improves multi-agent technology. Again, however, the protocol of steps and sequences to communicate data are merely improvements to the abstract idea. The claims are making the service request more effective by applying certain protocols, using the technology as a generic tool, rather than improving the technology itself. Applicant further argues that the claims are directed to a distributed computing architecture, but even if they do recite a judicial exception, they are integrated into a practical application. As discussed above, however, the claims do recite the abstract idea of certain methods of organizing human activity because they recite the commercial interaction of executing a service request. And, the claims then merely apply this abstract idea to the generic technology recited, using it as a tool to make the abstract idea more efficient. Thus, claims 21–30 do not include additional elements sufficient to integrate the judicial exception into a practical application. Finally, Applicant argues that the claims recite significantly more than the judicial exception because they recite the ordered combination of the features discussed above. Applicant further explains that evidentiary support is required to support a conclusion that an additional element is not well-understood, routine, or conventional, and because no such evidence has been provided, the claims overcome Step 2B. See Changes in Examination Procedure Pertaining to Subject Matter Eligibility, Recent Subject Matter Eligibility Decision, USPTO Memo (April 19, 2018) (“Berkheimer Memo”). Although Applicant is correct about the requirements under the Berkheimer Memo, these standards are only required when establishing that an additional element is well-understood, routine, or conventional in the Step 2B analysis, under the current guidelines. See 2019 Revised Patent Subject Matter Eligibility Guidance, 84 Fed. Reg. 50, 56 n. 36 (Jan. 7, 2019) (“2019 PEG”). The analysis under previous Step 2A Prong Two does not evaluate whether additional elements are well-understood, routine, or conventional, so the Berkheimer Memo requirements need not be considered for this step. See 2019 PEG, 84 Fed. Reg. 50, 55. Furthermore, the Step 2A Prong Two considerations need not be reevaluated under Step 2B, unless the additional elements are concluded to be directed to insignificant extra-solution activity. See 2019 PEG, 84 Fed. Reg. 50, 56. Thus, it is not even necessary to consider whether the additional elements are well-understood, routine, or conventional because merely applying an abstract idea to a computer, as established in Step 2A Prong Two, cannot provide an inventive concept, as required under Step 2B. See MPEP 2106.05(f). The prima facie case of patent ineligibility therefore has been established because the rejection under 35 U.S.C. 101 clearly outlines the abstract idea and the generic computer components used to implement that abstract idea, and the rejection then explains that the invention as a whole merely uses those computer components to implement the abstract idea of executing a service request. Thus, claims 1, 3–11 and 13–20 do not include additional elements sufficient to amount to significantly more than the judicial exception. Prior Art Not Relied Upon The prior art made of record and not relied upon is considered pertinent to Applicant’s disclosure. Those prior art references are as follows: De Kadt et al., U.S. Patent No. 10,951,540, discloses dynamically determining task parameters. Jhoney et al., U.S. Patent No. 7,676,539, discloses a distributed environment with service providing agents. Chessell et al., U.S. Patent App. No. 2018/0285979, discloses storing service history information on a blockchain . High et al., U.S. Patent App. No. 2018/0349879, discloses a distributed blockchain system for executing contracts. Conclusion Applicant’s amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to DIVESH PATEL whose telephone number is (571) 272–3430. The examiner can normally be reached on Monday and Thursday 10:00 AM–8:00 PM EST. 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, Matthew Gart can be reached on (571) 272–3955. 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. /DIVESH PATEL/Examiner, Art Unit 3696
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Prosecution Timeline

Mar 09, 2023
Application Filed
Sep 30, 2024
Non-Final Rejection — §101
Dec 19, 2024
Response Filed
Apr 19, 2025
Final Rejection — §101
Jul 23, 2025
Request for Continued Examination
Jul 28, 2025
Response after Non-Final Action
Sep 29, 2025
Non-Final Rejection — §101
Dec 04, 2025
Response Filed
Jan 10, 2026
Final Rejection — §101 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

5-6
Expected OA Rounds
53%
Grant Probability
92%
With Interview (+39.1%)
3y 0m
Median Time to Grant
High
PTA Risk
Based on 120 resolved cases by this examiner. Grant probability derived from career allow rate.

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