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
This communication is in response to the amendment filed on 6 July 2026.
Claim 4 is canceled.
Claims 1, 2, 5, 6, 17, and 18 are amended.
Claims 1-3 and 5-18 have been examined.
Response to Arguments
In response to Applicant’s remarks filed on 6 July 2026:
a. Rejections of the pending claims under 35 U.S.C. 112(b) are withdrawn in view of Applicant’s amendments and remarks.
b. Applicant's arguments with respect to the 35 U.S.C. 101 rejections of the pending claims have been fully considered but are not deemed persuasive.
On pages 12-15 of Applicant’s remarks, Applicant argues against the 35 U.S.C. 101 rejections of the pending claims. Applicant argues that claim 1 does not recite an abstract idea under Step 2A, Prong One; does recite a practical application under Step 2A, Prong Two.
The Office respectfully disagrees with the above remarks. With regards to the analysis at Step 2A, Prong One; Applicant asserts that the human mind cannot practically perform the “determining a quality level” and “removing at least a portion” limitation across a corpus of at least 500 documents (remarks, page 13). However, claim 1 does not actually recite “determining a quality level” or “removing at least a portion” performed across the corpus of 500 documents. Rather, claim 1 first recites “extracting a plurality of textual entities from the at least 500 documents.” The claims do not specify nor place any limits upon the claimed “textual entities,” other than using the plural form of the word. Under the BRI, the claims encompasses a simple case of extracting just two textual entities from the documents. With the aid of pencil and paper, a human can mentally extract a couple of textual entities from a set of documents, even if the number of documents is 500. As an illustrative example, the “documents” could be SMS text messages or other short-form messages (e.g. Twitter/X messages). With the aid of pencil and paper, a human can extract a couple of entities from 500 short form documents such as SMS messages. Claim 1 goes on to recite “determining a quality level” and “removing at least portion” limitations that are performed with regards to the extracted textual entities. That is, under the broadest reasonable interpretation (BRI), claim 1 encompasses the simple case of performing “determining a quality level” and “removing at least a portion” on just two extracted textual entities. This is well within the capabilities of the human mind, especially with the aid of pencil of paper. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind (and/or with a pencil and paper) but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. Similarly, the claimed “retaining,” “categorizing,” “determining,” and “generating” limitations are mentally performable abstract ideas when the claim is interpreted under the BRI, as detailed below in the claim rejections under 35 U.S.C. 101. The recitation of “automatically, using one or more artificial intelligence models” is an additional element, beyond the abstract idea, that is analyzed at Step 2A, Prong Two. As detailed below in the claim rejections under 35 U.S.C. 101, this limitation is a high-level, generic invocation of artificial intelligence that amounts to mere instructions to apply the abstract idea on a general purpose computer, which cannot be deemed a practical application nor significantly more than the abstract idea. See MPEP 2106.05(f).
With regards to the analysis at Step 2A, Prong Two; Applicant asserts a practical application described as follows: “a combination of specific Al-executed steps that together produce a topic-specific knowledge graph that is more focused and more usable than prior art knowledge graphs,” and Applicant makes analogy to the Enfish ruling (remarks, page 14). In the Enfish ruling, the Court found the claims at issue to be “directed to a specific improvement to the way computers operate, embodied in the self-referential table” (Enfish, LLC v. Microsoft Corporation, page 12, first full paragraph). The Court added that “Here, the claims are not simply directed to any form of storing tabular data, but instead are specifically directed to a self-referential table for a computer database” (Ibid., page 14, last paragraph, emphasis is the Court’s). In other words, the Enfish ruling was based on a conclusion that the specific data structure recited in the claims was unique to computer databases. In the instant case, claim 1’s “knowledge graph” is in no way unique to computers. To the contrary, graph data structures comprised of nodes and edges (a.k.a. “connections” or “linkages”) such as the one recited in claim 1 have been the subject of theoretical study in mathematics for decades prior to the modern computer era1. Hence, contrary to Appellant’s assertion, instant claim 1 is not unique to the operation of computing systems, and analogy to Enfish is improper. Claim 1 does not recite an improvement to computer technology but rather broadly recites a data structure that has a history of extensive study and application outside of computer technology. Furthermore, the claim’s invocation of artificial intelligence is a high-level, generic recitation that amounts mere instructions to apply the abstract idea on a general purpose computer, which cannot be deemed a practical application nor an inventive concept. See MPEP 2106.05(f).
Claims 17 and 18 recite limitations similar to those of claim 1 and are ineligible under 35 U.S.C. 101 for the same reasons that claim 1 is ineligible, as set forth above.
Claims 2-3 and 5-16 are ineligible under 35 U.S.C. 101 for the same reasons that claims 1, 17, and 18 are ineligible, as set forth above, and for the additional reasons detailed below in the claim rejections under 35 U.S.C. 101.
b. Rejections of the pending claims under 35 U.S.C. 103 are withdrawn in view of Applicant’s amendments and remarks.
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 1-3 and 5-18 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
As to claims 1, 17, and 18, these claims recite “extracting a plurality of textual entities from the at least 500 documents.” Other than specifying the number as 500, the claims do not clarify nor place any limits upon the claimed “documents.” Under the broadest reasonable interpretation (BRI), these claims encompass simple documents each having just a few words or sentences. Furhtermore, the claims do not specify nor place any limits upon the claimed “textual entities,” other than using the plural form of the word. Under the BRI, the claims encompasses a simple case of extracting just two textual entities from the documents. With the aid of pencil and paper, a human can mentally extract a couple of textual entities from a set of documents, even if the number of documents is 500. As an illustrative example, the “documents” could be SMS text messages or other short-form messages (e.g. Twitter/X messages). With the aid of pencil and paper, a human can extract a couple of entities from 500 short form documents such as SMS messages. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind (and/or with a pencil and paper) but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas.
These claims also recite “determining a quality level of each of the plurality of extracted textual entities based on the one or more exemplary entities received from the user, wherein a quality level of a textual entity indicates a degree of similarity between the textual entity and each exemplary entity of the one or more exemplary entities.” The claimed determining of quality levels amounts to no more than a series of judgements/evaluations, i.e. judging/evaluating each extracted textual entity to determine its corresponding quality level, as claimed. A human could, with the aid of pencil and paper, mentally judge/evaluate textual entities based on their degree of similarity to examplary entities to produce a series of quality levels, as claimed. Hence, this limitation is also an abstract idea under the “Mental Processes” grouping.
These claims also recite “removing at least a portion of the plurality of textual entities based on a quality level the portion of the plurality of textual entities falling below a threshold quality level to eliminate irrelevant textual entities from representation in the knowledge graph.” The claimed removing of textual entities amounts to no more than a series of judgements/evaluations, i.e. judging/evaluating each textual entity to determine whether or not it should be removed, as claimed. A human could, with the aid of pencil and paper, mentally judge/evaluate textual entities for removal in the manner claimed. Hence, this limitation is also an abstract idea under the “Mental Processes” grouping.
These claims also recite “retaining a plurality of filtered textual entities from the plurality of textual entities based on the quality level of the filtered textual entities exceeding the threshold quality level.” The claimed retaining of filtered textual entities amounts to no more than a series of judgements/evaluations. A human could, with the aid of pencil and paper, mentally judge/evaluate textual entities based on their respective quality levels to retain some textual entities based a threshold quality level, as claimed. Hence, this limitation is also an abstract idea under the “Mental Processes” grouping.
These claims also recite “categorizing each the plurality of filtered textual entities according to one or more sub-topics associated with the topic.” Given that the BRI of the claims encompasses a simple case, as set forth above, a human could, with the aid of pencil and paper, mentally categorize filtered textual entities, as claimed. For example, a human could mentally judge/evaluate a couple of filtered textual entities and assign sub-topics to them. Hence, this limitation is also an abstract idea under the “Mental Processes” grouping.
These claims also recite “determining connection information indicating relationships between the one or more sub-topics based on documents of the one or more documents from which each of the plurality of filtered textual entities originated, wherein determining the connection comprises determining that a threshold number of filtered textual entities encompassed by each of the one or more sub-topics are present in at least a threshold number of the at least 500 documents.” Given that the BRI of the claims encompasses a simple case, as set forth above, a human could, with the aid of pencil and paper, mentally determine connection information as claimed. For example, a human could read a set of documents and mentally determine from it certain connections/relationships between sub-topics in the manner claimed. Hence, this limitation is also an abstract idea under the “Mental Processes” grouping.
These claims also recite “generating, based on the one or more sub-topics and the connection information, the first knowledge graph for the topic that represents the one or more sub-topics in the one or more documents and the relationships between said sub-topics.” Given that the BRI of the claims encompasses a simple case, as set forth above, a human could, with the aid of pencil and paper, mentally generate a knowledge graph as claimed. For example, a human could draw out on a piece of paper a knowledge graph in the manner claimed. Hence, this limitation is also an abstract idea under the “Mental Processes” grouping. Accordingly, the claim recites an abstract idea.
This judicial exception is not integrated into a practical application. Other than the abstract idea, the claims recite the following:
a) “receiving at least 500 documents from one or more information sources;”
b) “receiving an indication of one or more exemplary entities associated with the topic from a user;”
c) “automatically, using one or more artificial intelligence models”;
d) “one or more memories and one or more processors”; and
e) “A non-transitory computer readable storage medium storing instructions.”
Limitations (a) and (b) amount to no more than mere data gathering, which has been deemed by the courts to be insignificant extra-solution activity. See MPEP 2106.05(g). Limitation (c) is recited at a high level of generality and amounts to mere instructions to apply the abstract idea on a computer, which cannot provide a practical application. See MPEP 2106.05(f). Limitations (d) and (e) are recited at a high level of generality, i.e. as generic computer components performing generic computing functions. Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Looking at the additional elements as a whole adds nothing beyond the additional elements considered individually—they still represent insignificant extra-solution activity and/or generic computer implementation. Hence, the claim as a whole, looking at the additional elements individually and in combination, does not integrate the abstract idea into a practical application. The claim is directed to an abstract idea.
The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception. Limitations (a) and (b) amount to no more than mere data gathering, which has been deemed by the courts to be insignificant extra-solution activity. See MPEP 2106.05(g). In addition, the courts have deemed receiving data to be well-understood, routine, and conventional activity, as in the following cases: Symantec, 838 F.3d at 1321, 120 USPQ2d at 1362 (utilizing an intermediary computer to forward information); OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1093 (Fed. Cir. 2015) (sending messages over a network); buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014) (computer receives and sends information over a network); Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015) (storing and retrieving information in memory). See MPEP 2106.05(d)(II). Limitation (c) is recited at a high level of generality and amounts to mere instructions to apply the abstract idea on a computer, which cannot be deemed an inventive concept. See MPEP 2106.05(f). As discussed above with respect to integration of the abstract idea into a practical application, additional elements (d) and (e) amount to no more than mere field of use limitations and instructions to apply the exception using generic computer components. Mere instructions to apply an exception using conventional computer components and functions cannot provide an inventive concept. Looking at the additional elements as a whole adds nothing beyond the additional elements considered individually—they still represent insignificant extra-solution activity; well-understood, routine, and conventional subject matter; and/or generic computer implementation. Hence, the claim as a whole, looking at the additional elements individually and in combination, does not amount to significantly more than the abstract idea. These claims are not patent eligible.
As to dependent claim 2, this claim recites updating the plurality of filtered textual entities based on the feedback received from the user. Given that the BRI of the claims encompasses a simple case, as set forth above in the parent claim, a human could, with the aid of pencil and paper, mentally perform the claimed updating in the manner claimed. Hence, this limitation is an abstract idea under the “Mental Processes” grouping. This claim also recites “providing an indication of the plurality of filtered textual entities to the user” and “receiving feedback from the user indicating an accuracy of one or more of the plurality of filtered textual entities.” These limitations are insignificant extra solution activity in the form of mere data ouputting (“providing an indication” limitation) and mere data gathering (“receiving feedback” limitation). The courts have ruled mere data gathering to be insignificant extra solution activity, as set forth above in the parent claims. In addition, the courts have ruled mere data outputting to also be insignificant extra solution activity. See Mayo, 566 U.S. at 79, 101 USPQ2d at 1968; OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1092-93 (Fed. Cir. 2015); Electric Power Group, LLC v. Alstom S.A., 830 F.3d 1350, 1354-55, 119 USPQ2d 1739, 1742 (Fed. Cir. 2016). See MPEP 2106.05(g). Furthermore, Applicant’s specification provides few details about the claimed “providing an indication,” “receiving feedback,” or their functions (see para. 0032 of Applicant’s published specification). This indicates that these features are well known in the art. Cf Hybritech Inc. v. Monoclonal Antibodies, Inc., 802 F.2d 1367, 1384 (Fed. Cir. 1986) (explaining that "a patent need not teach, and preferably omits, what is well known in the art"). As a result, the written description adequately supports that the “providing an indication” and “receiving feedback” limitations are conventional and perform well-understood, routine, and conventional activities. See MPEP § 2106.07(a)(III)(A)2. Hence, these limitations cannot be deemed a practical application nor an inventive concept. Looking at the additional elements as a whole adds nothing beyond the additional elements considered individually—they still represent insignificant extra-solution activity; well-understood, routine, and conventional subject matter; and/or generic computer implementation. Hence, the claim as a whole, looking at the additional elements individually and in combination, does not amount to a practical application nor an inventive concept. This claim is not patent eligible.
As to dependent claim 3, this claim recites details of “determining the quality level of a textual entity of the plurality of textual entities.” This claim recites generating first and second vectors and computing a similarity score between the two vectors. These limitations amount to no more than a series of mathematical operations. Hence, this claim is an abstract idea under the “Mathematical Concepts” grouping. Alternatively, this claim may be deemed an abstract idea under the “Mental Processes” grouping, since a human could, with the aid of pencil and paper, mentally perform these limitations for the simple case encompassed by the BRI of the claims.
As to dependent claim 5, this claim recites “generating a matrix that indicates which documents of the one or more documents contain which filtered entities of the plurality of filtered textual entities.” The claimed generating of a matrix amounts to no more than mathematical operation(s). Hence, this claim is an abstract idea under the “Mathematical Concepts” grouping. Alternatively, this claim may be deemed an abstract idea under the “Mental Processes” grouping, since a human could, with the aid of pencil and paper, mentally perform this limitation for the simple case encompassed by the BRI of the claims.
As to dependent claim 6, this claim repeats the same limitations recited in claim 1 except that the limtiations of claim 6 are performed upon “a second set of one or more documents.” The limitaitons of claim 6 are directed to an abstract idea without significantly more for the reasons set forth above with regards to claim 1.
As to dependent claim 7, this claim recites “combining the first knowledge graph with the second knowledge graph.” A human could, with the aid of pencil and paper, mentally perform this limitation for the simple case encompassed by the BRI of the claims. Hence, this claim is an abstract idea under the “Mental Processes” grouping.
As to dependent claims 8-9, these claims recite details about how to combine he first knowledge graph with the second knowledge graph. Given that the BRI of the claims encompass a simple case, as set forth above, nothing in these claims goes beyond what a human could mentally perform with the aid of pencil and paper. Hence, these claims are also directed to an abstract idea under the “Mental Processes” grouping, without significantly more.
As to dependent claim 10, this claim recites “wherein the steps for generating the first knowledge graph are executed automatically upon receipt of a threshold number of documents from the one or more information sources.” Receipt of a threshold number of documents is mere data gathering which is insignificant extra solution activity, as set forth above in the parent claim. Furthermore, a human can mentally perform certain specified steps automatically based on a certain condition being met (e.g. receipt of a threshold number of documents). Hence, this claim is directed to an abstract idea under the “Mental Processes” grouping, without significantly more.
As to dependent claim 11, this claim recites “receiving a request for the first knowledge graph for the topic from the user,” which is insignificant extra solution activity in the form of mere data gathering, for the same reasons set forth above in the parent claim. Looking at the additional elements as a whole adds nothing beyond the additional elements considered individually—they still represent insignificant extra-solution activity; well-understood, routine, and conventional subject matter; and/or generic computer implementation. Hence, the claim as a whole, looking at the additional elements individually and in combination, does not amount to a practical application nor an inventive concept. This claim is not patent eligible.
As to dependent claim 12, this claim recites “wherein the plurality of textual entities extracted from the one or more documents belong to the same part of speech class.” This claim merely recites a particular type of data upon which to apply the invention. This amounts to a mere description of field of use and/or technological environment, which cannot provide a practical application nor an inventive concept. See MPEP 2106.05(h).
As to dependent claim 13, this claim recites “wherein the one or more artificial intelligence models comprise one or more natural language processing algorithms.” This claim is recited at a high level of generality and amounts to a mere description of field of use and/or technological environment, which cannot provide a practical application nor an inventive concept. See MPEP 2106.05(h).
As to dependent claim 14, this claim recites “wherein, in the first knowledge graph, the one or more sub-topics are represented as one or more nodes and the relationships between the one or more sub-topics are represented as one or more edges connecting said nodes.” Given that the BRI of the claims encompasses a simple case, as set forth above in the parent claim, a human could, with the aid of pencil and paper, mentally generate a knowledge graph that is as described in this claim. Hence, this claim is an abstract idea under the “Mental Processes” grouping.
As to dependent claims 15 and 16, these claims recite featuers for use of a graphical user interface. These limitations amount to mere instructions to apply the abstract idea on a computer and/or merely a description of technological environment, neither of which can provide a practical application or inventive concept. See MPEP 2106.05 subsections (f) and (h).
Conclusion
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 extension fee 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 date of this final action.
Contact Information
Any inquiry concerning this communication or earlier communications from the examiner should be directed to UMAR MIAN whose telephone number is (571)270-3970. The examiner can normally be reached Monday to Friday, 10 am to 6:30 pm.
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/Umar Mian/
Primary Examiner, Art Unit 2163
1 “graph theory, branch of mathematics concerned with networks of points connected by lines…The history of graph theory may be specifically traced to 1735, when the Swiss mathematician Leonhard Euler solved the Königsberg bridge problem.”
“graph theory.” Encyclopaedia Britannica. Published 23 May 2025 by Encyclopaedia Britannica, Inc. Accessed 6 Jan 2026 from https://www.britannica.com/topic/graph-theory
“The study of graphs is known as graph theory, and was first systematically investigated by D. König in the 1930s.”
Weisstein, Eric W. "Graph." From MathWorld--A Wolfram Web Resource. Accessed 6 Jan 2026 from https://mathworld.wolfram.com/Graph.html
2 MPEP § 2106.07(a)(III)(A) explains that a specification demonstrates the well-understood, routine, conventional nature of additional elements when it describes the additional elements as well-understood or routine or conventional ( or an equivalent term) or in a manner that indicates that the additional elements are sufficiently well-known that the specification does not need to describe the particulars of such additional elements to satisfy 35 U.S.C. § 112(a).
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