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 .
THIS ACTION IS MADE FINAL.
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 mailing date of this final action.
Status of the Application
The following is a Final Office Action in response to Examiner's communication of 10/09/2025, Applicant, on 01/08/2026.
Status of Claims
Claims 1-20 are originals.
Claims 1-20 are currently pending following this response.
New matter
No new matter has been added to the amended claims.
Response to Arguments – Claim objection
The arguments have been fully considered, but they are not persuasive.
The Examiner is not convinced with Applicant’s arguments regarding the claim objections of claims 1 and 11. Please see further directions and explanation under claims 1 and 11 objections (below).
Response to Arguments - 35 USC § 101
The arguments have been fully considered, but they are not persuasive.
With respect to the use of machine learning techniques (Applicant’s arguments page 3), it is common practice that such computational models/techniques and algorithms are per se of an abstract mathematical nature, irrespective of whether they can be “trained” based on training data. Hence, a mathematical method may contribute to the technical character of an invention, if it serves as technical purpose or if it regards as specific technical implementation motivated by the internal function of a computer. Elements in the present claims do not solve a technical problem, but an administrative/business method, i.e. tracking a completion of a workflow. Since the mathematical algorithms or models used in the present application do not serve a technical purpose, but a business purpose, and their implementation does not go beyond generic technical implementation, the use of the artificial intelligence techniques, do not contribute to a technical character and they are to be part of the abstract idea.
USPTO Memorandum of August 4, 2025 considered the published two USPTO examples 39 and 47. Examples 39 illustrates claim limitations that merely involve an abstract idea and 47 shows limitations that recite an abstract idea. The claim limitation “training the neural network in a first stage using the first training set” of example 39 does not recite a judicial exception. Even though “training the neural network” involves a broad array of techniques and/or activities that may involve or rely upon mathematical concepts, the limitation does not set forth or describe any mathematical relationships, calculations, formulas, or equations using words or mathematical symbols. Contrast this with the limitation “training, by the computer, the ANN based on the input data and a selected training algorithm to generate a trained ANN, wherein the selected training algorithm includes a backpropagation algorithm and a gradient descent algorithm” of claim 2 of example 47. This limitation requires specific mathematical calculations by referring to the mathematical calculations by name, i.e., a backpropagation algorithm and a gradient descent algorithm, and therefore recites a judicial exception, namely an abstract idea.
The recitation of abstract idea in the instant claims is obvious at least in the language “receive a request at the at least one workflow initiating computing device to initiate the workflow comprising a document; receive data fields extracted from the document and necessary to complete the workflow; use a machine learning model trained on extracted data fields to auto-approve at least one step of the workflow, and track a state of the workflow until completion of the workflow”
Further, Applicant’s arguments regarding a technical improvement in network server topology and deployment architecture are not persuasive because the improvement in the instant claims is a business improvement of recognizing a ready workflow to go into production or a not ready workflow since the instant claims do not include technical details of interaction between the different systems which would make the arrangement an improvement over the prior art systems.
In conclusion, the Examiner maintains the rejections of the pending claims under 35 USC § 101 in the present office action.
Claim Objections
Claims 1 and 11 are objected to because of the following informality: the claims recite “use a machine learning model trained on extracted data fields to auto-approve at least one step of the workflow, and track a state of the workflow until completion of the workflow.” it should read “use a machine learning model trained on extracted data fields to auto-approve at least one step of the workflow; and track a state of the workflow until completion of the workflow.” Or “use a machine learning model trained on extracted data fields to auto-approve at least one step of the workflow, and track by the processor a state of the workflow until completion of the workflow.”.
The way the claim is written indicates that the machine learning model tracks the state of the workflow until completion where actually the processor is tracking.
Claims 2-10 and 12-20 depend from claims 1 and 11 and do not cure the noted deficiency. Therefore, they are also objected too.
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 non-statutory subject matter. Specifically, claims 1-20 are directed to an abstract idea without additional elements to integrate the claims into a practical application or to amount to significantly more than the abstract idea.
Claims 1-20 are directed to a process, machine, or manufacture (Step 1), however the claims are directed to the abstract idea of tracking stages of workflow execution.
With respect to Step 2A Prong One of the frameworks, claim 1 recites an abstract idea. Claim 1 includes limitations for “defining, initiating, and resolving workflows with a blue-green server topology, defining a series of steps in a workflow and which of the at least two servers will presently be designated as blue or green for the workflow; performing the series of steps; receive a request to initiate the workflow comprising a document; receive data fields extracted from the document and necessary to complete the workflow; use a machine learning model trained on extracted data fields to approve at least one step of the workflow, and track a state of the workflow until completion of the workflow”
The limitations above recite an abstract idea under Step 2A Prong One. More particularly, the limitations above recite certain methods of organizing human activity associated with managing personal behavior or relationships or interactions between people because the claimed elements describe a process for tracking stages of workflow execution. As a result, claim 1 recites an abstract idea under Step 2A Prong One.
Claim 11 recites substantially similar limitations to those presented with respect to claim 1. As a result, claim 11 recites an abstract idea under Step 2A Prong One for the same reasons as stated above with respect to claim 1. Similarly, claims 2-10 and 12-20 recite certain methods of organizing human activity associated with managing personal behavior or relationships or interactions between people because the claimed elements describe a process for tracking stages of workflow execution. As a result, claims 2-10 and 12-20 recite an abstract idea under Step 2A Prong One.
With respect to Step 2A Prong Two of the framework, claim 1 does not include additional elements that integrate the abstract idea into a practical application. Claim 1 includes additional elements that do not recite an abstract idea. The additional elements of claim 1 include “A system for”, “in a workflow management system”, “comprising: at least two servers in communication with at least one workflow defining computing device and with at least one workflow initiating computing device, the at least two servers comprising at least one designated as blue with respect to any particular workflow and at least one designated as green with respect to any particular workflow; and non-transitory memory comprising instructions that, when executed by one or more processors, cause the one or more processors to:”, “provide a first graphical user interface (GUI) to the at least one workflow defining computing device to be used in”, “provide a second GUI to the at least one workflow defining computing device to be used in creating a third GUI that will be used when”, “at the at least one workflow initiating computing device”, “auto-”. When considered in view of the claim as a whole, the step of “receiving” does not integrate the abstract idea into a practical application because “receiving” is an insignificant extra solution activity to the judicial exception. When considered in view of the claim as a whole, the recited computer elements do not integrate the abstract idea into a practical application because the computer elements are generic computer elements that are merely used as a tool to perform the recited abstract idea. As set forth in the 2019 Eligibility Guidance, 84 Fed. Reg. at 55 “merely include[ing] instructions to implement an abstract idea on a computer” is an example of when an abstract idea has not been integrated into a practical application. Therefore, the claim is directed to an abstract idea.
As a result, claim 1 does not include additional elements that integrate the abstract idea into a practical application under Step 2A Prong Two.
As noted above, claim 11 recites substantially similar limitations to those recited with respect to claim 1. Although claim 11 further recites “A computer-implemented method”, when considered in view of the claim as a whole, the recited computer elements do not integrate the abstract idea into a practical application because the computer elements are generic computer elements that are merely used as a tool to perform the recited abstract idea. As a result, claims 11 does not include additional elements that integrate the abstract idea into a practical application under Step 2A Prong Two.
Claims 2-10 and 12-20 do not include any additional elements beyond those recited by independent claims 1 and 11. As a result, claims 2-10 and 12-20 do not include additional elements that integrate the abstract idea into a practical application under Step 2A Prong Two.
With respect to Step 2B of the framework, claim 1 does not include additional elements amounting to significantly more than the abstract idea. As noted above, claim 1 includes additional elements that do not recite an abstract idea. The additional elements of claim 1 include “A system for”, “in a workflow management system”, “comprising: at least two servers in communication with at least one workflow defining computing device and with at least one workflow initiating computing device, the at least two servers comprising at least one designated as blue with respect to any particular workflow and at least one designated as green with respect to any particular workflow; and non-transitory memory comprising instructions that, when executed by one or more processors, cause the one or more processors to:”, “provide a first graphical user interface (GUI) to the at least one workflow defining computing device to be used in”, “provide a second GUI to the at least one workflow defining computing device to be used in creating a third GUI that will be used when”, “at the at least one workflow initiating computing device”, “auto-”. The step of “receiving” does not amount to significantly more than the abstract idea because “receiving” is well-understood, routine, and conventional computer function in view of MPEP 2106.05(d)(ll). The recited computer elements do not amount to significantly more than the abstract idea because the computer elements are generic computer elements that are merely used as a tool to perform the recited abstract idea. As a result, claim 1 does not include additional elements that amount to significantly more than the abstract idea under Step 2B.
As noted above, claim 11 recites substantially similar limitations to those recited with respect to claim 1. Although claim 11 further recites “A computer-implemented method”, the recited computer elements do not amount to significantly more than the abstract idea because the computer elements are generic computer elements that are merely used as a tool to perform the recited abstract idea. Further, looking at the additional elements as an ordered combination adds nothing that is not already present when considering the additional elements individually. As a result, claim 11 does not include additional elements that amount to significantly more than the abstract idea under Step 2B.
Claims 2-10 and 12-20 do not include any additional elements beyond those recited by independent claims 1 and 11. As a result, claims 22-10 and 12-20 do not include additional elements that amount to significantly more than the abstract idea under Step 2B.
Therefore, the claims are directed to an abstract idea without additional elements amounting to significantly more than the abstract idea. Accordingly, claims 1-20 are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter.
Conclusion
Applicant's arguments dated 01/08/2026 regarding the 35 USC § 101 rejections of the pending claims found not to be persuasive by the Examiner. 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).
Any inquiry concerning this communication from the Examiner should be directed to Abdallah El-Hagehassan whose contact information is (571) 272-0819 and Abdallah.el-hagehassan@uspto.gov The Examiner can normally be reached on Monday- Friday 8 am to 5 pm.
If attempts to reach the Examiner by telephone are unsuccessful, the Examiner’s supervisor, Rutao Wu can be reached on (571) 272-6045. The fax phone number for the organization where this application or proceeding is assigned is (571) 273-8300.
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/ABDALLAH A EL-HAGE HASSAN/
Primary Examiner, Art Unit 3623