DETAILED ACTION
This office action is in response to the above identified application filed on June 26, 2026. The application contains claims 1-20.
Claims 6 and 16 were previously cancelled
Claims 1 and 11 are amended
Claims 1-5, 7-15, and 17-20 are pending
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 .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on June 26, 2026 has been entered.
Response to Arguments
Applicant's arguments and amendments filed on June 26, 2026 have been fully considered and the objections and rejections are updated accordingly.
Priority
Applicant repeated the same argument that was filed on May 19, 2025 without presenting any new argument or factual evidence to support their claim of priority to Provisional Application No. 63353006.
As explained in the response to arguments in the office action dated June 18, 2025, Fig. 4 paragraphs [0020]-[0040], [0099]-[0100], and [0124] did not even mention entity identifier (EID) and the related features as recited in the claims. In fact, Fig. 4 and paragraphs [0020]-[0040] discussed entity relationships in a data model and related entity properties and attributes, paragraphs [0099]-[0100] talked about merging and survivorship in relation to entity attributes at a high level of generality, and paragraph [0124] only mentioned that entity attributes could contain multiple values after an entity merge. As such, the disclosure of the prior-filed application, Provisional Application No. 63353006, fails to provide adequate support or enablement in the manner provided by 35 U.S.C. 112(a) or pre-AIA 35 U.S.C. 112, first paragraph for one or more claims of this application. Specifically, the prior-filed application fails to provide support for entity identifier (EID) and related features.
Specification
In view of Applicant’s amendments to the Abstract, the objection to the specification is withdrawn.
Claim Rejections - 35 USC § 112
In view of Applicant’s amendments to the claims and arguments, the 35 U.S.C. 112(b) rejections are withdrawn. However, the amendments raise new issues. The 35 USC § 112 claim rejections have been updated to reflect the issues that still remain. Please see below for details.
Claim Rejections - 35 USC § 101
Applicant’s amendments to the claims do not overcome the 35 U.S.C. 101 rejections.
In response to Applicant’s argument on page 3 of Applicant’s Arguments/Remarks Made in an Amendment as quoted below, the examiner disagrees.
“Such limitations are not abstract because they are not mental processes, nor are they mathematical concepts, nor are they certain methods of organizing human activity. Furthermore, such limitations would integrate any abstract idea into a practical application because they are not merely generic computing components, nor are they mere instructions to apply an exception, nor are they insignificant extra solution activity, nor are they merely limiting to a technology or field of use. See, e.g., MPEP 216.05. Moreover, the limitations above provide a technological improvement that does not exist outside of computing by providing a multitenant EID lineage-persistent RDBMS that enables data lineage and survivorship functionality that otherwise could not be performed.
The limitations above also provide a technical solution to a technical problem. More specifically, the technical problem is how to track and manage data lineage and survivorship in multi-tenant systems (e.g., in a multi-tenant system) so that previously merged data items can be subsequently unmerged without losing data or lineage information. The technical solution provides a specific lineage-persistent computing system that can unmerge previously merged data items using the survivorship rules and legacy EIDs retained in the legacy EID datastore of the multitenant EID lineage-persistent RDBMS.”
The above argument is about the newly introduced limitation that read “unmerging … the merged data item based on the survivorship rules …” in claims 1 and 11, respectively.
There are two issues with this limitation: one, as discussed in the 112(a) rejections below, this limitation has no support in the specification as originally disclosed; two, separating a piece of combined data into two based on labels and rules indicating their respective origins can be practically performed in the human mind with or without the help of a pen and paper; hence, the new limitation may be characterized as a mental process.
Per MPEP 2106.05(a), "It is important to note that in order for a method claim to improve computer functionality, the broadest reasonable interpretation of the claim must be limited to computer implementation. That is, a claim whose entire scope can be performed mentally, cannot be said to improve computer technology. Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 120 USPQ2d 1473 (Fed. Cir. 2016) (a method of translating a logic circuit into a hardware component description of a logic circuit was found to be ineligible because the method did not employ a computer and a skilled artisan could perform all the steps mentally). Similarly, a claimed process covering embodiments that can be performed on a computer, as well as embodiments that can be practiced verbally or with a telephone, cannot improve computer technology. See RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1328, 122 USPQ2d 1377, 1381 (Fed. Cir. 2017) (process for encoding/decoding facial data using image codes assigned to particular facial features held ineligible because the process did not require a computer).” Because the entire scope of the claimed invention can be all performed in the human mind, the broadest reasonable interpretation of the claimed invention is not limited to computer implementation. The RDBMS architecture recited in the claim merely generally links the abstract idea to the database management technological field without integrating the judicial exception into a practical application.
Please refer to the updated 35 U.S.C. 101 rejections below for details.
Examiner’s Note
The limitation recited in independent claims 1 and 11 respectively that reads “… in a multitenant EID lineage-persistent relational database management system (RDBMS), wherein the multitenant EID lineage-persistent RDBMS has a n-layer architecture, wherein the multitenant EID lineage-persistent RDBMS includes an industry-agnostic layer in a Layer 1 (L1) of the n-layer architecture, wherein the multitenant EID lineage-persistent RDBMS includes an industry-focused layer in a Layer 2 (L2) container of the n-layer architecture, wherein the multitenant EID lineage-persistent RDBMS includes a tenant layer in a Layer (L3) container of the n-layer architecture, wherein the L3 container inherits all data items from the L2 container, and wherein the first data item and the second data item are tenant data items in the L3 container and cross-tenant matching uses match rules defined in a metadata configuration of a tenant that inherits from the L2 container”. The RDBMS architecture recited in the above limitation is not integrated in any way with the remainder of the claimed invention, because the steps recited in the claimed invention appear to take place in the tenant-facing L3 container regardless of the inner architecture of the RDBMS.
Priority
Applicant’s claim for the benefit of a prior-filed application under 35 U.S.C. 119(e) or under 35 U.S.C. 120, 121, 365(c), or 386(c) is acknowledged. Applicant has not complied with one or more conditions for receiving the benefit of an earlier filing date under 35 U.S.C. as follows:
The later-filed application must be an application for a patent for an invention which is also disclosed in the prior application (the parent or original nonprovisional application or provisional application). The disclosure of the invention in the parent application and in the later-filed application must be sufficient to comply with the requirements of 35 U.S.C. 112(a) or the first paragraph of pre-AIA 35 U.S.C. 112, except for the best mode requirement. See Transco Products, Inc. v. Performance Contracting, Inc., 38 F.3d 551, 32 USPQ2d 1077 (Fed. Cir. 1994).
The disclosure of the prior-filed application, Provisional Application No. 63353006, fails to provide adequate support or enablement in the manner provided by 35 U.S.C. 112(a) or pre-AIA 35 U.S.C. 112, first paragraph for one or more claims of this application. Specifically, the prior-filed application fails to provide support for entity identifier (EID) and related features.
Claim Rejections - 35 USC § 112
The following is a quotation of the first paragraph of 35 U.S.C. 112(a):
(a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention.
The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112:
The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention.
Claims 1-5, 7-15, and 17-20 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for pre-AIA the inventor(s), at the time the application was filed, had possession of the claimed invention.
Claims 1 and 11 each recite the limitation “unmerging, by the data item update engine, the merged data item based on the survivorship rules and the legacy EID of the merged data item retained in the legacy EID datastore of the multitenant EID lineage-persistent RDBMS”. This limitation has no support in the original disclosure as filed. In fact, the specification never mentioned unmerging merged data items based on survivorship rule. Therefore, claims 1 and 11 are rejected under 35 U.S.C. 112(a).
Dependent claims 2-5 and 7-10 are also rejected for inheriting the deficiency from their corresponding independent claim 1.
Dependent claims 12-15 and 17-20 are also rejected for inheriting the deficiency from their corresponding independent claim 11.
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 1-5, 7-15, and 17-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
The 2019 PEG guidance for subject matter eligibility is applied in the following analyses:
At Step 1
The inventions of claims 1-5 and 7-10 are rejected for being directed to non-statutory subject matter as discussed above.
The inventions of claims 11-15 and 17-20 are directed to the statutory categories of a process.
The following analysis refers to representative claim 1, but the same analysis applies to independent claim 11, which recites similar limitations.
At Step 2A, Prong One
Claims 1 and 11 each recite abstract ideas in the following limitations:
“… assigning … a first EID to a first data item and a second EID to a second data item”. Assigning an identification to a data item may be performed in the human mind with or without the help of a pen and paper. Therefore, this limitation may be characterized as a mental process.
“… matching … the first data item with the second data item in real time”. Identifying similar data items involves observation, evaluation, and judgment that can all be practically performed in the human mind. Therefore, this limitation may be characterized as a mental process.
“… merging … the first data item with the second data item to create a merged data item …”. Gathering information from multiple sources and combining it into one data item may be performed in the human mind with or without the help of a pen and paper. Therefore, this limitation may be characterized as a mental process.
“… promoting … the first EID to a primary EID for the merged data item”. Reusing an existing ID as that of the merged data item may be performed in the human mind. Therefore, this limitation may be characterized as a mental process.
“… retaining … the second EID as a legacy EID of the merged data item distinctly in association with a portion of the merged data item obtained from the second data item …”. Saving the ID of a merged data item and the association of the ID with the data item for later retrieval is a mental process that has been practiced by the human beings for many years. Therefore, this limitation may be characterized as a mental process.
“… changing … the merged data item, and triggering survivorship rules …”. Merging data items based on predefined rules is a mental process that has been practiced by the human beings for many years. Therefore, this limitation may be characterized as a mental process.
“… unmerging … the merged data item based on the survivorship rules …”. Separating a piece of combined data into two based on labels and rules indicating their respective origins can be practically performed in the human mind with or without the help of a pen and paper. Therefore, this limitation may be characterized as a mental process.
At Step 2A, Prong Two
This judicial exception is not integrated into a practical application because the claims recite the additional elements of:
“… in a multitenant EID lineage-persistent relational database management system (RDBMS), wherein the multitenant EID lineage-persistent RDBMS has a n-layer architecture, wherein the multitenant EID lineage-persistent RDBMS includes an industry-agnostic layer in a Layer 1 (L1) of the n-layer architecture, wherein the multitenant EID lineage-persistent RDBMS includes an industry-focused layer in a Layer 2 (L2) container of the n-layer architecture, wherein the multitenant EID lineage- persistent RDBMS includes a tenant layer in a Layer (L3) container of the n-layer architecture, and wherein the L3 container inherits all data items from the L2 container, and wherein the first data item and the second data item are tenant data items in the L3 container and cross-tenant matching uses match rules defined in a metadata configuration of a tenant that inherits from the L2 container”, “in the L3 container”, “in a legacy EID datastore of the multitenant EID lineage-persistent RDBMS”, and “configured in metadata and evaluated at run time to determine operational values” may be characterized as generally linking the abstract idea to a technological area – database management, see MPEP 2106.05(h). Even though the above limitation appears to recite a RDBMS architecture, because all the steps recited in the remainder of the claim take place in the outer most tenant-facing layer regardless of the inner RDBMS architecture, the RDBMS architecture is not integrated in any way with the claimed invention. As such, the RDBMS architecture and the container and datastore recited in the claim merely generally link the abstract idea to the database management technological field without integrating the judicial exception into a practical application.
Even when viewed in combination, these additional elements do not integrate the recited judicial exception into a practical application and the claim is directed to the judicial exception.
At Step 2B
Claims 1 and 11 do not include additional elements that are sufficient to amount to significantly more than the judicial exception because as discussed above the claims do not recite any additional elements.
Therefore, claims 1 and 11 are rejected under 35 USC 101 as being directed to an abstract idea without significantly more.
Dependent claims 2 and 12 each recite additional elements of “receives/receiving … new dataset …”. These functions constitute insignificant extra-solution activity, particularly preliminary data gathering, in Step 2A Prong Two analysis, see MPEP 2106.05(g). In Step 2B analysis, the additional elements are well understood, routine, and conventional under 2106.05(d)(ii).
Dependent claims 3, 5, 7-10, 13, 15, and 17-20 each recite additional elements that may be performed in the human mind. Therefore, these limitations may be characterized as a mental process.
Dependent claims 4 and 14 each recite additional elements elaborating on the further details of the abstract idea in independent claims 1 and 11 that are still mentally performable.
Therefore, dependent claims 2-5, 7-10, 12-15, and 17-20 are also rejected under 35 USC 101 as being directed to an abstract idea without significantly more.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to XIAOQIN HU whose telephone number is (571)272-1792. The examiner can normally be reached on Monday-Friday 7:00am-3:30pm.
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/XIAOQIN HU/Examiner, Art Unit 2168
/CHARLES RONES/Supervisory Patent Examiner, Art Unit 2168
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