Prosecution Insights
Last updated: May 29, 2026
Application No. 18/204,286

SUBROUTINE OBJECTS FOR WORKFLOW IMPLEMENTATION

Non-Final OA §101§102
Filed
May 31, 2023
Priority
Feb 09, 2023 — provisional 63/483,974
Examiner
NGUYEN, VAN H
Art Unit
2199
Tech Center
2100 — Computer Architecture & Software
Assignee
Ramp Business Corporation
OA Round
1 (Non-Final)
89%
Grant Probability
Favorable
1-2
OA Rounds
3m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 89% — above average
89%
Career Allowance Rate
763 granted / 855 resolved
+34.2% vs TC avg
Strong +18% interview lift
Without
With
+18.5%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
15 currently pending
Career history
874
Total Applications
across all art units

Statute-Specific Performance

§101
7.0%
-33.0% vs TC avg
§103
44.1%
+4.1% vs TC avg
§102
36.1%
-3.9% vs TC avg
§112
2.6%
-37.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 855 resolved cases

Office Action

§101 §102
DETAILED ACTION 1. The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Applicant's election without traverse of Group I (Claims 1-11) in the replyfiled on 03/10/2026 is acknowledged. Claims 1-11 are pending in this application. Claims 12-20 are withdrawn from consideration. Applicant is required to cancel non-elected claims 12-20 in the next response to this office action. Information Disclosure Statement 2. The Applicants’ Information Disclosure Statements (filed 06/03/2024 and 04/03/2025) have been received, entered into the record, and considered. Copies of PTO 1449 forms are attached. Drawings 3. The drawings filed 05/11/2023 are accepted by the examiner. Specification 4. The specification has not been checked to the extent necessary to determine the presence of all possible minor errors. Applicant's cooperation is requested in correcting any errors of which applicant may become aware in the specification. Claim Rejections - 35 USC § 101 5. 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 1-9 and 11 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. Regarding claim 1, the limitations “identifying a plurality of components in the policy based on the definition”; “determining, for each component in the plurality of components of the policy, a corresponding subroutine that needs to be executed to fulfill the component”; “identifying, for each component in the plurality of components of the policy, a corresponding machine-code subroutine object that includes the instructions to execute the corresponding subroutine”; “generating a machine-code syntax tree to represent an executable workflow that implements the policy, the machine-code syntax tree connecting a plurality of identified machine-code subroutine objects that correspond to the subroutines that need to be executed to fulfill the components of the policy”; and “associating the machine-code syntax tree with the policy” as drafted, are functions that, under its broadest reasonable interpretation, recite the abstract idea of a mental process. The limitations encompass a human mind carrying out the function through observation, evaluation, judgment and /or opinion, or even with the aid of pen and paper. Thus, these limitations recite and fall within the “Mental Processes” grouping of abstract ideas under Prong 1. Under Prong 2, this judicial exception is not integrated into a practical application. The additional element “a computer-implemented” is recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using generic computer, and/or mere computer components, MPEP 2106.05(f) and “storing a plurality of machine-code subroutine objects, each machine-code subroutine object including instructions for a subroutine that is executable” and “receiving a definition of a policy” do nothing more than add insignificant extra solution activity to the judicial exception of merely storing and gathering data. Accordingly, the additional elements do not integrate the recited judicial exception into a practical application and the claim is therefore directed to the judicial exception. See MPEP 2106.05(g). Under 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 a practical application, the additional element of “a computer-implemented” amounts to no more than mere instructions, or generic computer/computer components to carry out the exception, and for the limitations “storing a plurality of machine-code subroutine objects, each machine-code subroutine object including instructions for a subroutine that is executable” and “receiving a definition of a policy” the courts have identified mere data storing and gathering is well-understood, routine and conventional activity. See MPEP 2106.05(d). The recitation of generic computer instruction and computer components to apply the judicial exception, and mere data storing and gathering do not amount to significantly more, thus, cannot provide an inventive concept. After considering all claim elements individually and as an ordered combination, it is determined that the claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception for the reasons given above with respect to integration of the abstract idea into a practical application. Therefore, the claim is not patent eligible. Regarding claim 2, the claim does not recite any mental process, however, the additional element “the machine-code syntax tree comprises the plurality of identified machine-code subroutine objects that are represented as vertices and the vertices are connected to form the executable workflow in one or more orders” is merely generic computer component, thus is neither a practical application under prong 1, or amount to significantly more under step 2B. After considering all claim elements individually and as an ordered combination, it is determined that the claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception for the reasons given above with respect to integration of the abstract idea into a practical application. Therefore, the claim is not patent eligible. Regarding claim 3, the limitation “determining that the transaction request is subject to the policy” encompasses a human mind carrying out the function through observation, evaluation, judgment and /or opinion, or even with the aid of pen and paper. Thus, the claim recites further mental process. The additional element “receiving a transaction request” do nothing more than add insignificant extra solution activity to the judicial exception of merely gathering data. The courts have identified mere data/information gathering is well-understood, routine and conventional activity. See MPEP 2106.05(d). The recitation of generic computer instruction and computer components to apply the judicial exception, and merely gathering data/information do not amount to significantly more, thus, cannot provide an inventive concept. The additional element “executing the machine-code syntax tree to determine whether the transaction request is compliant with the policy” is merely applying the judicial exception or abstract idea. After considering all claim elements individually and as an ordered combination, it is determined that the claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception for the reasons given above with respect to integration of the abstract idea into a practical application. Therefore, the claim is not patent eligible. After considering all claim elements individually and as an ordered combination, it is determined that the claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception for the reasons given above with respect to integration of the abstract idea into a practical application. Therefore, the claim is not patent eligible. Regarding claim 4, the limitations “storing the plurality of machine-code subroutine objects comprises storing an action subroutine object, the action subroutine object defining a particular subroutine that includes one or more actions to be performed to complete the particular subroutine” do nothing more than add insignificant extra solution activity to the judicial exception of merely gathering data. The courts have identified mere data/information storing is well-understood, routine and conventional activity. See MPEP 2106.05(d). The recitation of generic computer instruction and computer components to apply the judicial exception, and merely storing data/information do not amount to significantly more, thus, cannot provide an inventive concept. After considering all claim elements individually and as an ordered combination, it is determined that the claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception for the reasons given above with respect to integration of the abstract idea into a practical application. Therefore, the claim is not patent eligible. Regarding claim 5, the limitations “storing the plurality of machine-code subroutine objects comprises storing a condition subroutine object, the condition subroutine object defining a particular subroutine that includes one or more conditions to be checked to complete the particular subroutine” do nothing more than add insignificant extra solution activity to the judicial exception of merely gathering data. The courts have identified mere data/information storing is well-understood, routine and conventional activity. See MPEP 2106.05(d). The recitation of generic computer instruction and computer components to apply the judicial exception, and merely storing data/information do not amount to significantly more, thus, cannot provide an inventive concept. After considering all claim elements individually and as an ordered combination, it is determined that the claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception for the reasons given above with respect to integration of the abstract idea into a practical application. Therefore, the claim is not patent eligible. Regarding claim 6, the limitations “providing a list of candidate actions and/or conditions for a domain, each action or condition corresponding to a machine-code subroutine object that is stored” and “generating the machine-code syntax tree comprises: selecting a set of machine-code subroutine objects that correspond to the selection of actions and/or conditions that define the policy” encompass a human mind carrying out the function through observation, evaluation, judgment and /or opinion, or even with the aid of pen and paper. Thus, the claim recites further mental process. The additional element “receiving, from the domain, a selection of actions and/or conditions to define the policy, wherein a selected action or condition corresponds to a component of the policy” do nothing more than add insignificant extra solution activity to the judicial exception of merely gathering data. The courts have identified mere data/information gathering is well-understood, routine and conventional activity. See MPEP 2106.05(d). The recitation of generic computer instruction and computer components to apply the judicial exception, and merely gathering data/information do not amount to significantly more, thus, cannot provide an inventive concept. After considering all claim elements individually and as an ordered combination, it is determined that the claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception for the reasons given above with respect to integration of the abstract idea into a practical application. Therefore, the claim is not patent eligible. Regarding claim 7, the limitation “associating a second machine-code syntax tree with a second policy of a second domain that is different from the first domain” encompasses a human mind carrying out the function through observation, evaluation, judgment and /or opinion, or even with the aid of pen and paper. Thus, the claim recites further mental process. The additional element “the machine-code syntax tree is a first machine-code syntax tree that is associated with a first policy of a first domain” is merely generic computer component, thus is neither a practical application under prong 1, or amount to significantly more under step 2B. After considering all claim elements individually and as an ordered combination, it is determined that the claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception for the reasons given above with respect to integration of the abstract idea into a practical application. Therefore, the claim is not patent eligible. Regarding claim 8 the limitation “storing the plurality of machine-code subroutine objects is performed” do nothing more than add insignificant extra solution activity to the judicial exception of merely storing data. The courts have identified mere data/information storing is well-understood, routine and conventional activity. See MPEP 2106.05(d). The additional elements “a computing server that provides a software-as-a-service (SaaS) platform to a plurality of domain customers”, and “the first machine-code syntax tree and the second machine-code syntax tree that are associated with different domain customers share one or more machine-code subroutine objects that are stored by the computing server” are recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using generic computer, and/or mere computer components, MPEP 2106.05(f). After considering all claim elements individually and as an ordered combination, it is determined that the claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception for the reasons given above with respect to integration of the abstract idea into a practical application. Therefore, the claim is not patent eligible. Regarding claim 9, the limitations “modifying the machine-code syntax tree, wherein modifying the machine-code syntax tree comprises inserting a machine-code subroutine object to the machine-code syntax tree or removing a machine-code subroutine object from the machine-code syntax tree” encompass a human mind carrying out the function through observation, evaluation, judgment and /or opinion, or even with the aid of pen and paper. Thus, the claim recites further mental process. The additional elements “receiving a modification of the policy” and “storing a modified machine-code syntax tree as a modified workflow that implemented the policy as modified” do nothing more than add insignificant extra solution activity to the judicial exception of merely gathering and storing data. The courts have identified mere data/information gathering is well-understood, routine and conventional activity. See MPEP 2106.05(d). The recitation of generic computer instruction and computer components to apply the judicial exception, and merely gathering and storing data/information do not amount to significantly more, thus, cannot provide an inventive concept. After considering all claim elements individually and as an ordered combination, it is determined that the claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception for the reasons given above with respect to integration of the abstract idea into a practical application. Therefore, the claim is not patent eligible. Regarding claim 11, the limitation “generating parameters and executable routines of a subroutine function in a source code format” encompasses a human mind carrying out the function through observation, evaluation, judgment and /or opinion, or even with the aid of pen and paper. Thus, the claim recites further mental process. The additional elements “storing the plurality of machine-code subroutine objects” and “storing the one of the machine-code subroutine objects in a data store, wherein the one of the machine-code subroutine objects is available as a component of one or more policies” do nothing more than add insignificant extra solution activity to the judicial exception of merely storing data. The courts have identified mere data/information storing is well-understood, routine and conventional activity. See MPEP 2106.05(d). The recitation of generic computer instruction and computer components to apply the judicial exception, and merely storing data/information do not amount to significantly more, thus, cannot provide an inventive concept. The additional element “compiling the subroutine function into binary instructions as one of the machine-code subroutine objects” is well-understood, routine and conventional activity (see Specification [0015] and [0120]). After considering all claim elements individually and as an ordered combination, it is determined that the claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception for the reasons given above with respect to integration of the abstract idea into a practical application. Therefore, the claim is not patent eligible. Claim Rejections - 35 USC § 102 6. In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale or otherwise available to the public before the effective filing date of the claimed invention. Claims 1-11 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Egenolf et al. (US 20210279043). The reference was cited by Applicant in the IDS filed 06/03/2024. It is noted that any citations to specific, pages, columns, paragraphs, lines, or figures in the prior art references and any interpretation of the reference should not be considered to be limiting in any way. A reference is relevant for all it contains and may be relied upon for all that it would have reasonably suggested to one having ordinary skill in the art. See MPEP 2123. As to claim 1:Egenolf teaches a computer-implemented method, comprising: storing a plurality of machine-code subroutine objects, each machine-code subroutine object including instructions for a subroutine that is executable ([0044]: a system for generating logical data that represents physical datasets stored in a storage system or memory....a specification specifies an operation (e.g., computational logic) to be performed on the datasets or attributes of the datasets. The specification is compiled into or otherwise used to create a computer program (e.g., an executable dataflow graph) that is capable of execution on a computing system... the computer program includes executable machine code; see also, [0051] and [0169]); receiving a definition of a policy ([0064]: The graph generator 22 receives (342) the specification (102). The graph generator 22 generates (344) a dataflow graph using the specification and the logical data. Generally, a dataflow graph (or a persistent computer program) is generated from a specification as follows: A specification specifies a plurality of modules to be implemented by a computer program for processing one or more values of the one or more fields in structured data item (e.g., a data record). These plurality of modules may include rules, instructions, components of a dataflow graph; see also, [0056-0058]); identifying a plurality of components in the policy based on the definition (Fig.2C and [0056]: a business rules editor interface 32 is generated by the development environment 18 for defining business rules and other logical rules... the editor interface 32 includes an input portion 33 and a rule definition portion 34. The input portion 33 provides a visual representation of those attributes (e.g., fields) and datasets that are represented in the logical data 25 as well as other data sources); determining, for each component in the plurality of components of the policy, a corresponding subroutine that needs to be executed to fulfill the component; identifying, for each component in the plurality of components of the policy, a corresponding machine-code subroutine object that includes the instructions to execute the corresponding subroutine ([0044]: The logical data represents these physical datasets by including attributes of the physical datasets, by including pointers specifying an address of the storage location of these physical datasets, or by specifying other information that represents how to access the physical datasets, or combinations of them, among others. In this example, the logical data or portions of the logical data are accessible in a development environment to enable development of a specification that specifies which datasets (or attributes of the datasets) are used and accessed. Generally, a specification specifies an operation (e.g., computational logic) to be performed on the datasets or attributes of the datasets. The specification is compiled into or otherwise used to create a computer program (e.g., an executable dataflow graph) that is capable of execution on a computing system: [0084]: Initially, the graph generator 22 generates a dataflow graph 152 that is similar to the dataflow graph 134 shown in FIG. 5E, except for a transform component 1521 that includes logic to perform the rules specified in the modified specification 142. In this example, the transform component 1521 is different from the transform component 1341 (shown in FIG. 5E) because the rules specified in the modified specification 142 and implemented by the component 1521 are different than those specified in the specification 96a and implemented by the component 1341. The graph generator 22 applies the optimizer 132 to the dataflow graph 152 to generate a dataflow graph 154. In doing so, the optimizer 132 removes from the dataflow graph 154 components 134a, 134c, 134f, 134g, 134j, and 134i, as shown by the crossed out portions of the dataflow graph 154. The optimizer 132 determines to remove these components because these components are related to datasets that are not referenced or used by the rule specification 142. Note that, although the dataset serving as the root node (e.g., dataset 103 or component 134b in this example) is not referenced in the specification 140, it is not optimized out. The final result of the optimization is the dataflow graph 156 which is been optimized to remove all of the datasets that are not required to execute the rules specified by rule specification 142, as well as other components (e.g., sorts, joins, etc.) instantiated to access those datasets. The dataflow graph 156 is different from the dataflow graph 98a despite using the same logical data 94 source due to the different attributes relied on in the specifications 96a, 142 of the respective graphs; see also, [0091] and [0169]). generating a machine-code syntax tree to represent an executable workflow that implements the policy, the machine-code syntax tree connecting a plurality of identified machine-code subroutine objects that correspond to the subroutines that need to be executed to fulfill the components of the policy; and associating the machine-code syntax tree with the policy (Fig.5E, [0078]: an environment 130 shows an example of generating and optimizing a dataflow graph from the rule specification 96a and the logical data 94. The graph generator 22 receives the rule specification 96a and the logical data 94. The graph generator 22 applies an optimizer 132 to both the rule specification 96a and the logical data 94 in generating an optimized dataflow graph 98a. In this example, the graph generator 22 uses the rule specification 96a and the logical data 94 to generate a dataflow graph 134. In this example, the dataflow graph 134 includes components 134a through 134m. The graph generator 22 then applies the optimizer 132 to the dataflow graph 134. Generally, the optimizer 132 reduces redundancies in a dataflow graph (e.g., the dataflow graph 134) and eliminates data sources that are not being used by the dataflow graph. That is, if the rule specification 96a does not specify that a rule accesses a field from a particular data source (e.g., a dataset), then the optimizer 132 will remove that data source from the dataflow graph. In some examples, the optimizer 132 does this by minimizing select statements (e.g., when the source data is stored in a relational database) such that only those datasets and fields specified in the rule specification 96a and included in the logical data 94 are accessed; see also, [0079-0081]). As to claim 2:Egenolf teaches the machine-code syntax tree comprises the plurality of identified machine-code subroutine objects that are represented as vertices and the vertices are connected to form the executable workflow in one or more orders ([0088-0091] and [0094-0098]). As to claim 3:Egenolf teaches receiving a transaction request; determining that the transaction request is subject to the policy; and executing the machine-code syntax tree to determine whether the transaction request is compliant with the policy ([0148-0149]). As to claim 4:Egenolf teaches storing the plurality of machine-code subroutine objects comprises storing an action subroutine object, the action subroutine object defining a particular subroutine that includes one or more actions to be performed to complete the particular subroutine (Fig. 2C, [0056-0057]). As to claim 5:Egenolf teaches storing the plurality of machine-code subroutine objects comprises storing a condition subroutine object, the condition subroutine object defining a particular subroutine that includes one or more conditions to be checked to complete the particular subroutine (Fig. 2C, [0056-0057]).As to claim 6:Egenolf teaches receiving the definition of the policy comprises: providing a list of candidate actions and/or conditions for a domain, each action or condition corresponding to a machine-code subroutine object that is stored; receiving, from the domain, a selection of actions and/or conditions to define the policy, wherein a selected action or condition corresponds to a component of the policy, and wherein generating the machine-code syntax tree comprises: selecting a set of machine-code subroutine objects that correspond to the selection of actions and/or conditions that define the policy (Fig. 2C, [0056-0058] and [0077]). As to claim 7:Egenolf teaches the machine-code syntax tree is a first machine-code syntax tree that is associated with a first policy of a first domain, and the computer-implemented method further comprises associating a second machine-code syntax tree with a second policy of a second domain that is different from the first domain (Fig. 2C, [0056-0058] and [0077]). As to claim 8:Egenolf teaches storing the plurality of machine-code subroutine objects is performed by a computing server that provides a software-as-a-service (SaaS) platform to a plurality of domain customers, and the first machine-code syntax tree and the second machine-code syntax tree that are associated with different domain customers share one or more machine-code subroutine objects that are stored by the computing server ([0169] and [0172-0173]). As to claim 9:Egenolf teaches receiving a modification of the policy; modifying the machine-code syntax tree, wherein modifying the machine-code syntax tree comprises inserting a machine-code subroutine object to the machine-code syntax tree or removing a machine-code subroutine object from the machine-code syntax tree; and storing a modified machine-code syntax tree as a modified workflow that implemented the policy as modified (Fig. 2C, [0078-0081]).As to claim 10:Egenolf teaches executing the machine-code syntax tree, wherein executing the machine-code syntax tree comprises: executing a first set of machine-code instructions to communicate to a named entity for an authorization request; and executing a second set of machine-code instructions to compare a response of the authorization request to a condition defined in one of machine-code subroutine objects in the machine-code syntax tree ([0148-0149]). As to claim 11:Egenolf teaches storing the plurality of machine-code subroutine objects comprises: generating parameters and executable routines of a subroutine function in a source code format; compiling the subroutine function into binary instructions as one of the machine-code subroutine objects; and storing the one of the machine-code subroutine objects in a data store, wherein the one of the machine-code subroutine objects is available as a component of one or more policies ([0078-0087]). Conclusion 7. The prior art made of record, listed on PTO 892 provided to Applicant is considered to have relevancy to the claimed invention. Applicant should review each identified reference carefully before responding to this office action to properly advance the case in light of the prior art. Contact Information 8. Any inquiry or a general nature or relating to the status of this application should be directed to the TC 2100 Group receptionist: (571) 272-2100. Any inquiry concerning this communication or earlier communications from the examiner should be directed to VAN H. NGUYEN whose telephone number is (571) 272-3765. The examiner can normally be reached on Monday- Friday from 9:00AM- 5:30 PM. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, LEWIS BULLOCK can be reached at (571) 272-3759. The fax phone number for the organization where this application or proceeding is assigned is (571) 273-8300. Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /VAN H NGUYEN/ Primary Examiner, Art Unit 2199
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Prosecution Timeline

May 31, 2023
Application Filed
Apr 13, 2026
Non-Final Rejection mailed — §101, §102 (current)

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Prosecution Projections

1-2
Expected OA Rounds
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Grant Probability
99%
With Interview (+18.5%)
3y 3m (~3m remaining)
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