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 .
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 20 January 2026 has been entered.
Status of Claims
Claims 1, 9, and 17 have been amended.
Claims 4, 10, and 12 have been previously canceled.
Claims 1-3, 5-9, 11, and 13-20 are currently pending and have been examined.
Response to Applicant's Remarks
35 U.S.C. § 101
Applicant’s remarks, see Page(s) 11-20, filed 20 January 2026, with respect to the 35 U.S.C. § 101 rejections, have been fully considered, but are not persuasive.
Applicant submits that the claims of the current application do not recite an abstract idea and instead, the claims recite a practical, distributed workflow that spans independent servers and devices and are tied to a specific combination of computing systems, devices, and techniques. Applicant further submits that the claims of the current application are not directed to an abstract idea because the claims offer a technical improvement over prior systems by utilizing a modular, distributed architecture, where a first server operates independently of external data servers (e.g., travel product providers) and the web application, thereby enhancing interoperability between heterogeneous systems, improving scalability and resiliency, and reducing coupling and integration overhead.
Examiner respectfully disagrees, as the claims recite(s) a system and series of steps for recommending and booking transportation and lodging options, which under broadest reasonable interpretation, is analogous to commercial or legal interactions, such as advertising, marketing, or sales activities or behaviors. The limitation(s) as drafted, recite a process that, under broadest reasonable interpretation, is/are certain methods of organizing human activity. Accordingly, the claim(s) recite(s) an abstract idea.
The judicial exception is not integrated into a practical application. The claim(s) recite(s) the additional element(s) of ‘a first server’, ‘a web-based application’, ‘a computing device’, ‘one or more processors’, ‘one or more non-transitory computer-readable media’, ‘a travel and expense application’, ‘a travel database’, ‘a plurality of data servers’, ‘a graphical user interface’, ‘one or more application-programming-interface (API) calls’. These additional elements are recited at a high-level of generality such that in conjunction with the abstract limitations, they amount to no more than:
⦁ mere instructions to apply the exception using generic computer components (i.e., generic computer components performing generic computer functions) (‘a first server’, ‘a computing device’, ‘one or more processors’, ‘one or more non-transitory computer-readable media’, ‘a travel database’, ‘a plurality of data servers’). In their broadest reasonable interpretation, the additional element(s) comprise(s) only a processor, instructions in memory, a display, a receiver, and a transmitter, being used to implement the functions of the abstract idea. Accordingly, the claims do not amount to more than a recitation of the words "apply it" (or an equivalent) or more than mere instructions to implement an abstract idea or other exception in a generic computing environment (see MPEP 2106.05(f) Mere Instructions to Apply an Exception). Thus, even when viewed in combination, these additional elements do not integrate the recited judicial exception into a practical application and the claim(s) is/are directed to the judicial exception.
⦁ generally linking the use of the judicial exception to a particular technological environment or field of use (‘a web-based application’, ‘a travel and expense application’, ‘a graphical user interface’, ‘one or more application-programming-interface (API) calls’). Additionally, See also cxLoyalty, Inc. v. Maritz Holdings Inc., 986 F.3d 1367, 1377 (Fed. Cir. 2021) ("The claims apply the abstract idea on a computer by replacing the human intermediary with a GUI and API, but as the Board concluded, representative claim 1 'merely recites generic and conventional computer components (i.e., "processor," "GUI," and "API") and functionality for carrying out' the abstract idea.").
Additionally, the claim limitations are not indicative of integration into a practical application, such as an improvement to the functioning of a computer or other technical field, as considered below in view of MPEP 2106. In particular, an improvement in the judicial exception itself is not an improvement in technology. Applicant’s improvement in this case is not an improvement to the functioning of a computer, or to any other technology or technological field.
The following are examples of eligible subject matter based on technological improvements: see, e.g., McRO, 837 F.3d at 1315 ("The claimed process uses a combined order of specific rules that renders information into a specific format that is then used and applied to create desired results: a sequence of synchronized, animated characters."); Finjan, Inc. v. Blue Coat Sys., Inc., 879 F.3d 1299, 1304 (Fed. Cir. 2018) (finding patent eligible a claim drawn to a behavior-based virus scan that protects against viruses that have been "cosmetically modified to avoid detection by code-matching virus scans"); Enfish, 822 F.3d at 1330, 1333 (discussing patent eligible claims directed to "an innovative logical model for a computer database" that included a self-referential table allowing for greater flexibility in configuring databases, faster searching, and more effective storage); CardioNet, LLC v. InfoBionic, Inc., 955 F.3d 1358, 1368 (Fed. Cir. 2020) (explaining that the claims at issue focus on a specific means for improving cardiac monitoring technology; they are not "directed to a result or effect that itself is the abstract idea and merely invoke generic processes and machinery" (quoting McRO, 837 F.3d at 1314)).
To show that the involvement of a computer assists in improving the technology, the claims must recite the details regarding how a computer aids the method, the extent to which the computer aids the method, or the significance of a computer to the performance of the method. Merely adding generic computer components to perform the method is not sufficient. Thus, the claim must include more than mere instructions to perform the method on a generic component or machinery to qualify as an improvement to an existing technology (see MPEP 2106.05(a)).
Applicant further submits that the claims should be found eligible in view of the Office’s significant changes in subject matter eligibility policy, particularly the decision in Ex Parte Desjardins, Appeal No. 2024-000567 (PTAB September 26, 2025), and the Office's amendments to MPEP 2106 stated in the memorandum of Charles Kim dated December 5, 2025.
Examiner acknowledges the MPEP revisions and confirms that the claim eligibility assessments, under 35 U.S.C. 101, have been performed in accordance with the MPEP revisions.
35 U.S.C. § 103
Applicant’s remarks, see Page(s) 21, filed 20 January 2026, with respect to the 35 U.S.C. § 103 rejections, have been fully considered, and are persuasive, in view of the claim amendments. Therefore, the 35 U.S.C. § 103 rejections have been withdrawn.
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.
Claim(s) 1-3, 5-9, 11, and 13-20 is/are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
Claim(s) 1, 9, and 17 recite(s) a system and series of steps for recommending and booking transportation and lodging options, which under broadest reasonable interpretation, is analogous to commercial or legal interactions, such as advertising, marketing, or sales activities or behaviors. These concepts are grouped as certain methods of organizing human activity.
The limitation(s) of, ‘capturing a data file…’; ‘parsing the data file into data elements corresponding to trip input data…’; ‘populating a plurality of trip fields…’; ‘creating, for the new trip, a database search query…’; ‘displaying a plurality of panels corresponding to a plurality of optimizing options…’; ‘detecting one or more settings of one or more optimizing scales…’; ‘executing the database search query…’; ‘displaying the plurality of recommendations…’; ‘provide a plurality of recommendations comprising commute options and accommodation options…’; ‘receiving a selection of one of a commute option and an accommodation option’; ‘creating booking information corresponding to booking the commute option and the accommodation option…’; ‘updating an itinerary…’; ‘presenting the booking information and the plurality of recommendations…’, as drafted, recite a process that, under broadest reasonable interpretation, is/are certain methods of organizing human activity. Accordingly, the claim(s) recite(s) an abstract idea.
The judicial exception is not integrated into a practical application. The claim(s) recite(s) the additional element(s) of ‘a first server’, ‘a web-based application’, ‘a computing device’, ‘one or more processors’, ‘one or more non-transitory computer-readable media’, ‘a travel and expense application’, ‘a travel database’, ‘a plurality of data servers’, ‘a graphical user interface’, ‘one or more application-programming-interface (API) calls’. These additional elements are recited at a high-level of generality such that in conjunction with the abstract limitations, they amount to no more than:
⦁ mere instructions to apply the exception using generic computer components (i.e., generic computer components performing generic computer functions) (‘a first server’, ‘a computing device’, ‘one or more processors’, ‘one or more non-transitory computer-readable media’, ‘a travel database’, ‘a plurality of data servers’). In their broadest reasonable interpretation, the additional element(s) comprise(s) only a processor, instructions in memory, a display, a receiver, and a transmitter, being used to implement the functions of the abstract idea. Accordingly, the claims do not amount to more than a recitation of the words "apply it" (or an equivalent) or more than mere instructions to implement an abstract idea or other exception in a generic computing environment (see MPEP 2106.05(f) Mere Instructions to Apply an Exception). Thus, even when viewed in combination, these additional elements do not integrate the recited judicial exception into a practical application and the claim(s) is/are directed to the judicial exception.
⦁ generally linking the use of the judicial exception to a particular technological environment or field of use (‘a web-based application’, ‘a travel and expense application’, ‘a graphical user interface’, ‘one or more application-programming-interface (API) calls’). Additionally, See also cxLoyalty, Inc. v. Maritz Holdings Inc., 986 F.3d 1367, 1377 (Fed. Cir. 2021) ("The claims apply the abstract idea on a computer by replacing the human intermediary with a GUI and API, but as the Board concluded, representative claim 1 'merely recites generic and conventional computer components (i.e., "processor," "GUI," and "API") and functionality for carrying out' the abstract idea.").
Claim(s) 2, 3, 5-8, 11, 13-16, and 18-20 further recite(s) the system and series of steps for recommending and booking transportation and lodging options, which under broadest reasonable interpretation, is analogous to commercial or legal interactions, such as advertising, marketing, or sales activities or behaviors. These concepts are grouped as certain methods of organizing human activity. Accordingly, the claim(s) recite(s) an abstract idea.
The judicial exception is not integrated into a practical application. The claim(s) recite(s) the additional element(s) of ‘a first server’, ‘a web-based application’, ‘a computing device’, ‘one or more processors’, ‘one or more non-transitory computer-readable media’, ‘a travel and expense application’, ‘a travel database’, ‘a plurality of data servers’, ‘a graphical user interface’, ‘one or more application-programming-interface (API) calls’. These additional elements are recited at a high-level of generality such that in conjunction with the abstract limitations, they amount to no more than:
⦁ mere instructions to apply the exception using generic computer components (i.e., generic computer components performing generic computer functions) (‘a first server’, ‘a computing device’, ‘one or more processors’, ‘one or more non-transitory computer-readable media’, ‘a travel database’, ‘a plurality of data servers’). In their broadest reasonable interpretation, the additional element(s) comprise(s) only a processor, instructions in memory, a display, a receiver, and a transmitter, being used to implement the functions of the abstract idea. Accordingly, the claims do not amount to more than a recitation of the words "apply it" (or an equivalent) or more than mere instructions to implement an abstract idea or other exception in a generic computing environment (see MPEP 2106.05(f) Mere Instructions to Apply an Exception). Thus, even when viewed in combination, these additional elements do not integrate the recited judicial exception into a practical application and the claim(s) is/are directed to the judicial exception.
⦁ generally linking the use of the judicial exception to a particular technological environment or field of use (‘a web-based application’, ‘a travel and expense application’, ‘a graphical user interface’, ‘one or more application-programming-interface (API) calls’). Additionally, See also cxLoyalty, Inc. v. Maritz Holdings Inc., 986 F.3d 1367, 1377 (Fed. Cir. 2021) ("The claims apply the abstract idea on a computer by replacing the human intermediary with a GUI and API, but as the Board concluded, representative claim 1 'merely recites generic and conventional computer components (i.e., "processor," "GUI," and "API") and functionality for carrying out' the abstract idea.").
Additionally, the claims recite(s) the additional elements of receiving, transmitting, and storing data. These limitations are recited at a high level of generality (i.e., as a general means of receiving and transmitting data), and amount to mere data transmission and mere data storage, which is a form of insignificant extra-solution activity. Thus, the claim(s) is/are directed to the abstract idea.
As discussed above, the additional elements amount to mere data transmission, which is a form of insignificant extra-solution activity. As detailed in MPEP 2106, a conclusion that an additional element is insignificant extra-solution activity in Step 2A should be re-evaluated in Step 2B. Here, the reception, transmission, and storage of data was considered to be extra-solution activity in Step 2A, and thus it is re-evaluated in Step 2B to determine if it is more than what is well-understood, routine, conventional activity in the field.
The generic functions of receiving and transmitting data are considered to be well‐understood, routine, and conventional elements previously known to the industry, because the functions can be summarized as the generic computer functions of receiving or transmitting data over a network. This is similar to how ‘using the Internet to gather data’ was found to be a well-known, routine, and conventional function in the decision of Intellectual Ventures I LLC v. Symantec Corp. (Fed. Cir. 2015) (see MPEP 2106.05(d)(II) Elements That the Courts Have Recognized as Well-Understood, Routine, Conventional Activity in Particular Fields). Thus, these elements amount to well‐understood, routine, and conventional elements previously known to the industry, which does not add significantly more, and therefore remains insignificant extra-solution activity even upon reconsideration. Even when considered in combination, these additional elements represent mere instructions to apply an exception and insignificant extra-solution activity, which do not provide an inventive concept, and therefore, the claim(s) is/are not eligible.
The generic functions of storing received data in memory are considered to be well‐understood, routine, and conventional elements previously known to the industry, because the functions can be summarized as the generic computer functions of storing and retrieving information in memory. This is similar to how storing and retrieving information in memory was found to be a well-known, routine, and conventional function in the decision of Versata Dev. Group, Inc. v. SAP Am., Inc. (Fed. Cir. 2015) (see MPEP 2106.05(d)(II) Elements That the Courts Have Recognized as Well-Understood, Routine, Conventional Activity in Particular Fields). Thus, these elements amount to well‐understood, routine, and conventional elements previously known to the industry, which does not add significantly more, and therefore remains insignificant extra-solution activity even upon reconsideration. Even when considered in combination, these additional elements represent mere instructions to apply an exception and insignificant extra-solution activity, which do not provide an inventive concept, and therefore, the claim(s) is/are not eligible.
As analyzed above, the limitations as an ordered combination, are merely applying the abstract idea in a generic computing environment. In addition, the claims do not improve functionality of a computer or improve any other technology. Thus, claims 1-3, 5-9, 11, and 13-20 are ineligible as the claims do not recite additional elements which result in significantly more than the abstract idea itself.
Novel/Non-Obvious Subject Matter
The subject matter of claims 1-3, 5-9, 11, and 13-20 is not taught by the cited prior art and is considered novel/non-obvious. However, claims 1-3, 5-9, 11, and 13-20 remain rejected under 35 U.S.C. 101 as described above.
The closest prior art of record is Goldstein (U.S. Patent App. Pub. No. 20170178081), Stableford (U.S. Patent App. Pub. No. 20230306538), Kalnsay (U.S. Patent App. Pub. No. 20140129372), McSpadden (U.S. Patent App. Pub. No. 20190228347), Goldstein (U.S. Patent App. Pub. No. 20130046788), Agarwal (U.S. Patent App. Pub. No. 20200118226), Tarka (U.S. Patent App. Pub. No. 20090281875).
The cited prior art, taken either individually or in combination, fails to teach or suggest using a travel and expense application implemented in a first server, automatically capturing a data file from a web-based application implemented in a computing device of a candidate responsive to a registration of an event by the candidate, wherein the travel and expense application is independent from the web-based application; using the travel and expense application, parsing the data file into data elements corresponding to trip input data comprising an origin of travel, a destination of the travel, and a period of the event, the trip input data associated with an event record having an event identifier of the event; and using the travel and expense application, automatically executing the database search query for the new trip to provide a plurality of recommendations comprising commute options and accommodation options based on the plurality of search criteria, the plurality of optimizing options, and the one or more scaling factors associated with the one or more optimizing options.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to WAYNE S MURRAY whose telephone number is (571)272-4306. The examiner can normally be reached M-F 8am-5pm.
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/Wayne S. Murray/Examiner, Art Unit 3628