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 .
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 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a mental process without significantly more.
Independent claim 1 recites:
“A method of managing a database stored to a data store, the method comprising:
receiving a definition of a partitioning scheme, the definition of the partitioning scheme having associated therewith a partitioning scheme identifier, a partition-defining query, and an indication of a primary table to be partitioned;
receiving a definition of a first table, the first table being the primary table, the definition of the first table having associated therewith at least first and second partition types by which the first table is to be partitioned, the second partition type being a query type for which the partitioning scheme identifier is passed as a parameter;
receiving a definition of one or more second tables, each said second table being defined so as to have associated therewith a partition type by which the respective second table is to be partitioned, the partition type of each said second table being a query type for which the partitioning scheme identifier is passed as a parameter,
wherein the partition-defining query includes one or more outer queries conditioned on an innermost query, the innermost query being a query on the first table, each of the one or more outer queries being a query on a table in the database other than the first table;
partitioning the first table based on the first partition type;
updating the database in response to an operation performed thereon; and
based on the operation, executing the partition-defining query, wherein the updating includes making a change to a partition of the first table and to a partition of each said second table based on an outcome of the partition-defining query that is executed.”
Independent claims 9 and 15 recite similar subject matter.
This is a mental process because the claimed invention receives data, wherein the data contains defined elements, partitions a table based on instructions, and updates a database in response to a change to a partition. A human being equipped with pen and paper or a generic machine is capable of performing these data analysis steps.
The additional elements in the claims include multiple steps of receiving definitions, a “non-transitory computer readable storage medium” (claim 9), and “a memory” coupled to a “hardware processor” (claim 15).
This judicial exception is not integrated into a practical application because the claimed additional elements do not appear to improve the processing of a computer, require the use of a specific machine, effect a transformation or reduction of a particular article to a different state or thing, or provide a technological solution to a technological problem.
“Receiving” a data definition appears to be a data gathering step and is thus mere insignificant pre-solution activity (see MPEP 2106.05(g). The “non-transitory computer readable storage medium” and “memory” coupled to a “hardware processor” are recited at a high level of generality. They appear to be generic computing hardware elements. The recitation of generic hardware is little more than using a computer to perform an abstract idea, see MPEP 2106.05(f)(2).
It is noted that none of the additional elements appear to improve the processing of a computer, require the use of a specific machine, effect a transformation or reduction of a particular article to a different state or thing, or provide a technological solution to a technological problem. As such, none of the additional elements appear to integrate the judicial exception into a practical application.
None of the additional elements are sufficient to amount to significantly more than the judicial exception, in part or in whole.
The recitation of generic hardware of “non-transitory computer readable storage medium” and “memory” coupled to a “hardware processor” is little more than using a computer to perform an abstract idea, see MPEP 2106.05(f)(2). The additional element of “receiving” a data definition appears to be a mere data gathering step, and is thus insignificant extra-solution activity data gathering and is well understood, routine, and conventional (see MPEP 2106.05(g)).
None of the additional elements, in part or in whole, appear to improve the processing of a computer, require the use of a particular machine, effect a transformation or reduction of a particular article to a different state or thing, or add a specific limitation other than what is well understood, routine, or conventional. As such, none of the additional elements appears to be, in part or in whole, significantly more than the judicial exception.
Dependent claims 2-8, 10-14, and 16- 20 are directed towards additional limitations that further define data types or further describe data analyses. It is noted that the claimed data definitions and data analysis steps do not appear to include additional elements that incorporate the claimed subject matter into a practical application. The dependent claims also do not include additional elements that, in part or in whole, appear to be significantly more than the abstract idea.
Claim Rejections - 35 USC § 103
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 (i.e., changing from AIA to pre-AIA ) 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 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
Claims 1-4, 6-11, 13-17, and 19-20 are rejected under 35 U.S.C. 103 as being unpatentable over Muniswamy-Reddy et al. (US Patent 9,489,443), in view of Gupta et al. (US Patent 7,356,542), and further in view of Baer et al. (US Pre-Grant Publication 2017/0109377).
As to claim 1, Muniswamy teaches a method of managing a database stored to a data store, the method comprising:
receiving a definition of a partitioning scheme, the definition of the partitioning scheme having associated therewith a partitioning scheme identifier, a partition-defining query, and an indication of a primary table to be partitioned (see Muniswamy 20:11-32. Muniswamy shows definitions of a partitioning scheme. Partitions include a partitioning scheme identifier (the Partition ID value of Muniswamy), a partition defining query (message ID values with certain content), and an indication of tables with partitioned content values. Muniswamy further discusses how partition IDs are unique in 26:16-34. Also see 17:21-37);
receiving a definition of a first table, the first table being the primary table, the definition of the first table having associated therewith at least first and second partition types by which the first table is to be partitioned, the second partition type being a query type for which the partitioning scheme identifier is passed as a parameter (see Muniswamy 17:21-37. The Create Table function, which defines a table, accepts several parameters, including any “partition identifiers” (plural). As noted above, the partition identifiers are associated with types of partitions and identify partition schemes, see 20:11-32);
receiving a definition of one or more second tables, each said second table being defined so as to have associated therewith a partition type by which the respective second table is to be partitioned, the partition type of each said second table being a query type for which the partitioning scheme identifier is passed as a parameter (see Muniswamy 17:21-37. The Create Table function, which defines a table, accepts several parameters, including any “partition identifiers” (plural). As noted above, the partition identifiers are associated with types of partitions and identify partition schemes, see 20:11-32. As noted in 18:37-51, multiple tables may be created in Muniswamy),
…
partitioning the first table based on the first partition type (see Muniswamy 20:11-32 for an example of a table that has been partitioned in a defined manner); and
updating the database in response to an operation performed thereon (see Muniswamy 3:5-13),
Muniswamy does not explicitly teach:
wherein the partition-defining query includes one or more outer queries conditioned on an innermost query, the innermost query being a query on the first table, each of the one or more outer queries being a query on a table in the database other than the first table;
wherein the updating includes making a change to a partition of the first table and to a partition of each said second table based on an outcome of the partition-defining query.
Gupta teaches:
receiving a definition of a partitioning scheme, the definition of the partitioning scheme having associated therewith an indication of a primary table to be partitioned (see 13:39-59 and 14:3-35. A partitioning query is received that includes an indication of a primary table to be partitioned);
wherein the partition-defining query includes one or more outer queries conditioned on an innermost query, the innermost query being a query on the first table, each of the one or more outer queries being a query on a table in the database other than the first table (see 13:39-59 and 14:3-35. There exist both inner and outer queries of a first and second table);
It would have been obvious to one of ordinary skill in the art before the earliest filing date of the invention to have modified Muniswamy by the teachings of Gupta because both references are directed towards managing partitions. Gupta simply provides to Muniswamy additional methods of generating partitions, which will increase the ability of users of Muniswamy to customize the partitions that they desire.
Baer teaches:
Updating the database in response to an operation performed thereon (see Baer paragraph [0055]. Baer shows that one may perform “partition maintenance” by changing the logical shape as well as physical attributes of a partition based on a query. Also see Baer paragraph [0068] and Figure 4, which explicitly show that a database may be updated as a result of a partition-defining query received via a command, or operation);
Based on the operation, executing the partition-defining query, wherein the updating includes making a change to a partition of the first table and to a partition of each said second table based on an outcome of the partition-defining query that is executed (see Baer paragraphs [0055], [0068], and Figure 4. Based on a command, a partition-defining query is executed. This can include executing operations to that provide specific configurations to a first and second partition. As noted in paragraph [0057], such commands include the ability to “[change] the logical shape as well as physical attributes of a partition” as part of “partition maintenance.” Paragraph [0057] include commands such as alter, move, split, and merge, along with filter expressions, all of which may be used to change multiple partitions in a statement. Paragraph [0081] discusses how a partition maintenance statement may result in “altered tables or partitions.” Thus, multiple partitions and tables may be altered).
It would have been obvious to one of ordinary skill in the art before the earliest filing date of the invention to have modified Muniswamy by the teachings of Baer because both references are directed towards managing partitions. Baer simply provides to Muniswamy additional methods of updating partitions, which will increase the ability of users of Muniswamy to have dynamic partitions that can react to changes in user needs.
As to claim 2, Muniswamy as modified teaches the method of claim 1, wherein the first partition type is a range or list type partition (see Muniswamy 20:11-32)
As to claim 3, Muniswamy as modified by Baer teaches the method of claim 1, wherein two or more second tables are included in the database (see Muniswamy 18:37-51), and
wherein the partition-defining query is nested such that a first outcome of a first query on one of the second tables is conditioned on an outcome of the innermost query (see Gupta 13:39-59 and 14:3-35), and
such that a second outcome on a second query on another one of the second tables is conditioned on the first outcome (see Baer Figure 4 and paragraph [0068], which show partitions are conditioned on a query outcome of a range specification).
As to claim 4, Muniswamy as modified teaches the method of claim 1, wherein each definition of each first table is provided in a respective create table statement (see Muniswamy 17:21-37).
As to claim 6, Muniswamy as modified teaches the method of claim 1, wherein the operation is an insert or update data operation (see Muniswamy 3:5-13).
As to claim 7, Muniswamy as modified teaches the method of claim 1, wherein the operation is an archive and/or purge operation where at least some data from the first and second tables is to be archived and/or purged (see Muniswamy 3:5-13)
As to claim 8, Muniswamy as modified by Baer teaches the method of claim 7,
wherein a first set of data is to be archived and/or purged from a first partition of the first table and a second set of data is to be archived and/or purged from a counterpart partition of the second table(s) (see Baer paragraphs [0020], [0053], and Figure 4. Notably, Baer teaches wherein rows may be excluded, or purged, from any number of partitions based on a command to exclude rows).
As to claims 9 and 15, see the rejection of claim 1.
As to claims 10 and 16, see the rejection of claim 2.
As to claims 11 and 17, see the rejection of claim 3.
As to claims 13 and 19, see the rejection of claim 7.
As to claims 14 and 20, see the rejection of claim 8.
Claims 5, 12, and 18 are rejected under 35 U.S.C. 103 as being unpatentable over Muniswamy-Reddy et al. (US Patent 9,489,443), in view of Gupta et al. (US Patent 7,356,542), and further in view of Baer et al. (US Pre-Grant Publication 2017/0109377), and further in view of Sasaki et al. (US Pre-Grant Publication 2005/0076094).
As to claim 5, Muniswamy as modified teaches the method of claim 1.
Muniswamy does not clearly teach wherein changes are made to the second table(s) provided that a flag indicates that changes are to be cascaded thereto.
Sasaki teaches wherein changes are made to the second table(s) provided that a flag indicates that changes are to be cascaded thereto (see paragraph [0090]. Sasaki shows cascade download processing in view of a flag).
It would have been obvious to one of ordinary skill in the art before the earliest filing date of the invention to have modified Muniswamy by the teachings of Sasaki because both references are directed towards managing data. Sasaki simply provides to Muniswamy additional methods of reflecting changes in data, which will ensure that users of Muniswamy maintain databases with updated data.
As to claim 8, Muniswamy as modified teaches the method of claim 7.
Muniswamy does not clearly teach wherein a first set of data is to be archived and/or purged from a first partition of the first table and a second set of data is to be archived and/or purged from a counterpart partition of the second table(s).
Sasaki teaches wherein a first set of data is to be archived and/or purged from a first partition of the first table and a second set of data is to be archived and/or purged from a counterpart partition of the second table(s) (see paragraph [0110]. Data may be deleted if a reference exists between object data and related data).
It would have been obvious to one of ordinary skill in the art before the earliest filing date of the invention to have modified Muniswamy by the teachings of Sasaki because both references are directed towards managing data. Sasaki simply provides to Muniswamy additional methods of reflecting changes in data, which will ensure that users of Muniswamy maintain databases with updated data.
As to claims 12 and 18, see the rejection of claim 5.
Response to Arguments
Applicant's arguments filed 29 October 2025 have been fully considered but they are not persuasive.
Response to Arguments made in view of 35 USC 101
Applicant argues that “The independent claims, and their respective dependents, are not "directed to" patent ineligible subject matter under step one of the Alice test because they at least integrate any otherwise judicially excepted subject matter into a practical application. The claims provide for improvements in database computer systems. In particular, claimed techniques provide a specific technological solution to a technical problem of maintaining data consistency across multiple related database tables during partition-level operations such as archiving and purging.”
In response to this argument, it is noted that the claims do not contain the feature of “archiving and purging.” As such, the independent claims do not comprise all of Applicant’s purported “improvements in database computer systems.” Applicant is reminded that unclaimed features from the specification have no patentable weight until claimed.
Additionally, Examiner requests that Applicant describe, with a citation to the specification, how the claimed techniques “provide a specific technological solution to a technical problem of maintaining data consistency across multiple related database tables during partition-level operations.”
Applicant continues, arguing that “The claims in this case are patent eligible for reasons similar to those Enfish, LLC v. Microsoft Corp … . The claimed techniques thus go beyond generic computer implementation by requiring specific structural relationships between tables (primary and secondary), nested query architecture (innermost query on the first table with conditional outer queries), and automatic propagation of partition operations based on query outcomes ("an outcome of the partition- defining query"). Such techniques do not recite judicially excepted subject matter. Instead, they set forth technical improvements in the area of databases an area of technology similar to that at issue in Enfish.”
Examiner notes that specific structural relationships between tables and a nested query architecture are, in and of themselves, mere arrangements of data and data analyses. The feature of “automatic propagation of partition operations,” which does not appear to be claimed, is similarly merely the automatic execution of a data analysis. All of these features appear to be “mental process” steps and thus cannot represent an “technical improvement in the area of databases.”
Additionally, Applicant is requested to provide a citation to the specification that discusses how any claimed additional elements beyond the mental process “set forth technical improvements.”
As noted in the rejection above, the only “additional elements” beyond data definitions, data analyses, and data judgements are the claimed receiving steps and the claimed generic hardware step. Applicant’s arguments do not appear to describe how these additional elements either provide a practical application or are significantly more than the abstract idea. Applicant also does not describe how any other elements of the claims are additional elements beyond the mental process and are not data definitions, data analyses, or data judgments.
Applicant argues that “In sum, the claims are patent eligible under § 101 because they are directed to a specific improvement in database computer technology rather than an attempt to monopolize an abstract idea using generic computer components. The claims integrate any otherwise judicially excepted subject matter into a "practical application" by providing a concrete solution to the technical problem of conditional multi-table partitioning, which results in measurable performance improvements including faster partition-level operations compared to row-by-row processing, reduced database overhead, etc.
In response to this argument, it is noted that Applicant has not identified which additional elements of the claims incorporate “a specific improvement in database computer technology” into the claims or incorporate a “practical application” into the claims. Applicant also has not described, with citations to the specification, how any the inclusion of additional element beyond the mental process “results in measurable performance improvements including faster partition-level operations compared to row-by-row processing, reduced database overhead.” As such, Applicant’s argument is unpersuasive.
Response to Arguments made in view of 35 USC 103
Applicant’s arguments with respect to claims have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument.
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to CHARLES D ADAMS whose telephone number is (571)272-3938. The examiner can normally be reached M-F, 9-5:30 EST.
Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Neveen Abel-Jalil can be reached at 571-270-0474. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000.
/CHARLES D ADAMS/ Primary Examiner, Art Unit 2152