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 .
Status of Claims
This action is in reply to the amendment filed on 10/08/2025.
Claims 1, 8, 10, and 15-20 have been amended and are hereby entered.
Claims 1-20 are currently pending and have been examined.
This action is made FINAL.
Response to Arguments
Applicant’s arguments, see page 13, filed 10/08/2025, with respect to the drawing objections have been fully considered and are partially persuasive. The drawn objections regarding characters "40, 46a, 46b, 46c, 41 d, 48a, 48b, 18c, 41 e, 49a, 49b, 49c, 102j, 102k" have been withdrawn, but the drawings still contain characters 186 and 710 that are not mentioned in the specification. Additionally, while Figs. 15 and 16 are described in the specification (paragraph beginning at the top of Page 13) as referring to each other to show details on building the customer carbon profile, Fig. 15 refers to Fig. 9 and Fig. 16 refers to Fig. 8. Accordingly, it appears as though the “Fig. 9” circle in Fig.15 should read “Fig. 16” and the “Fig. 8” circle in Fig. 16 should read “Fig. 15”. These drawing objections have been maintained.
Applicant’s arguments, see page 13, filed 10/08/2025, with respect to the specification objections have been fully considered and are persuasive. The specification objections have been withdrawn.
Applicant’s arguments, see page 14, filed 10/08/2025, with respect to the 35 U.S.C. 112(f) interpretation of “computer system” have been fully considered and are persuasive. The addition of “one or more processors” in Applicant’s amendment to claim 1 provides sufficient corresponding structure such that “computer system” no longer invokes 35 U.S.C. 112(f).
Applicant’s arguments, see pages 14-19, filed 10/08/2025, with respect to the 35 U.S.C. 101 rejections of claims 1-20 have been fully considered but are not persuasive. The 35 U.S.C. 101 rejections of claims 1-20 have been maintained.
Before analyzing the Alice/Mayo eligibility arguments below, Examiner notes that, while not specifically argued by Applicant, Applicant’s amendments to claims 15-20 cause the amended claims to fall within at least one of the four statutory categories. Accordingly, the program per se 35 U.S.C. 101 rejections of claims 15-20 have been withdrawn.
After citing and summarizing features of amended claim 1 across pages 14-16, Applicant argues that the amended claim 1 is allegedly eligible at Step 2A Prong 2 of eligibility analysis. Particularly, Applicant argues that the amended claim 1 integrates its judicial exception into a practical application because amended claim 1 allegedly reflects an improvement to the functioning of a computer or an improvement to technology and implements its judicial exception with a particular machine. Examiner respectfully disagrees.
On Pages 17-19, Applicant argues that amended claim 1 reflects an improvement to the functioning of a computer or an improvement to technology or technical field. Applicant argues that the claimed graphical user interface selectively displays and prioritizes certain specific information to allegedly ease how a user navigates the graphical user interface. Applicant also argues that known carbon calculator tools are cumbersome to use because they require additional effort on behalf of the user to acquire the requisite information on crops, fields, etc. Applicant argues that the claimed graphical user interface makes it clear to users which additional data might need to adjusted or added to suit their objectives. Applicant points to the pop-up windows depicted in Fig. 4 and 5 showing maps, estimated crop mixes, and a comparison of alternate planting strategies. In sum of Page 19 of Remarks, Applicant concludes “the graphical user interface selectively presents and prioritizes information to a user in a directed manner, such that the user can quickly and intuitively understand the effects of the inputted data, without being distracted by other information that may be less relevant to the topic at hand. Thus, the user can better understand and navigate the graphical user interface (e.g., compared to a graphical user interface that does not dynamically present and prioritize information in the claimed manner). Such improvements to a user interface are recognized by the courts as patent eligible subject matter”, citing to Core Wireless and Eligibility Example 37.
MPEP 2106.05(a) states “If it is asserted that the invention improves upon conventional functioning of a computer, or upon conventional technology or technological processes, a technical explanation as to how to implement the invention should be present in the specification. That is, the disclosure must provide sufficient details such that one of ordinary skill in the art would recognize the claimed invention as providing an improvement… Conversely, if the specification explicitly sets forth an improvement but in a conclusory manner (i.e., a bare assertion of an improvement without the detail necessary to be apparent to a person of ordinary skill in the art), the examiner should not determine the claim improves technology” (emphasis added). Regarding the additional effort and burden placed on users of conventional calculators to gather and enter the requisite data for carbon calculation, Applicant’s specification recites “The screenshot 41a is displayed, e.g., on a screen (not referenced) of the client computer device 16 and is prepopulated with data based on applying advanced analytics to internal bank data that define “items” from which a conventional carbon calculator calculates carbon emissions” (emphasis added, Page 6 lines 7-10) and “The advanced analytics operations that prepopulate the customer carbon profile data structure(s) 25 from the data from the data structures 15 can occur on the one or more server computers 12 and/or the client computer device 16” (Page 6 lines 2-5). The “advanced analytics”, recited in the above selections and elsewhere in specification, used to gather an input information into the calculator on behalf of the user is recited in a conclusory manner, as there is no detail presented in the specification or claims to would convey to one of ordinary skill in the art that the invention is providing a technical improvement. Instead, the previously manual process of data gathering and input is merely being applied to a generic computer using “advanced analytics”. Furthermore, MPEP 2106.05(a)I. states that increased speed in data analysis coming solely from the capabilities of a general purpose computer was not found sufficient to be an improvement to the functioning of a computer. See FairWarning IP, LLC v. Iatric Sys., 839 F.3d 1089, 1095, 120 USPQ2d 1293, 1296 (Fed. Cir. 2016).
Regarding the alleged improvements to the interfaces themselves, as discussed above the information pre-populated into the interface is disclosed in a conclusory manner as being done by “advanced analytics” as discussed above. Further, MPEP 2106.05(a) II. states “it is important to keep in mind that an improvement in the abstract idea itself (e.g. a recited fundamental economic concept) is not an improvement in technology. For example, in Trading Technologies Int’l v. IBG, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019), the court determined that the claimed user interface simply provided a trader with more information to facilitate market trades, which improved the business process of market trading but did not improve computers or technology” (emphasis added). While the user interfaces argued across pages 17-19 may provide the user with pertinent information regarding the carbon calculation for the farm, the interface and/or computer itself is not being improved. Instead, the abstract idea of calculating carbon emissions may be improved by surfacing pertinent information to the user in order to better suit the user’s calculation goals. In other words, instead of a technical improvement to the functioning of a user interface or a computer, the improvement deciding what information is pertinent to the user and choosing to show that information. Examiner notes that the benefits of deciding to present a user with pertinent information so the user can decide what information to add or adjust can be realized without the use of a user interface (i.e. by showing a written summary of pertinent information to a user). In such a scenario, the benefits to the user are still realized, but a user interface or computer is not improved. Furthermore, nothing in the specification points to the claimed invention overcoming a technical hurdle that prevented conventional user interfaces from displaying information like the claimed invention. Instead, the claimed invention is employing user interfaces as a tool to present information regarding the farm and carbon calculations. While Core Wireless and Example 37 recite improvements to the operation of a user interface itself, the improvement in the claimed invention is the abstract information itself, and the user interface is merely being used as a tool to display the information.
Finally, while Applicant argues that the user interfaces are “selectively presenting and prioritizing information” they present, Examiner notes that nowhere in claim 1 is a step for selecting or prioritizing which information is to be displayed to the user. Instead, the data to be displayed in the claimed interface/pop-up windows is simply dictated by the claim. In other words, instead of the claimed invention selectively presenting and prioritizing information which information to display in the interfaces, the claimed invention merely uses the interface as a tool to display predetermined information. Accordingly, for the reasons discussed above the Improvements consideration argued by Applicant does not apply to the claimed invention.
Applicant argues next on Page 19 that the claims allegedly recite “computer-specific elements that are integral to the claim” that perform the judicial exception with a particular machine. Examiner respectfully disagrees. Applicant argues that the use of “a specific ‘ customer carbon profile data structure’” is one of the features that makes the claimed invention a particular machine. However, Applicant’s specification recites “Advanced analytics prepopulates a customer carbon profile data structure(s) 25 based on data from the data structures 15 to provide to the conventional carbon emissions calculator 26. The customer carbon profile data structure 25 is configured according to the conventional carbon emissions calculator 26 used. As such, it is not necessary to describe in any detail the structure of the customer carbon profile data structure 25…” (emphasis added). Instead of a “specific” customer carbon profile data structure, Applicant’s specification explicitly does not provide detail on the customer carbon profile data structure. Additionally, the “advanced analytics” that generate the customer carbon profile data structure and prepopulate the user interfaces (which Applicant also argues make the claimed invention as a particular machine), is presented in a conclusory manner as discussed above regarding the Improvements consideration. Furthermore, the computing components themselves are generically recited in the specification. Examiner makes particular note of the general purpose processors suitable for performing the claimed functions recited in specification Page 16 line 14. MPEP 2106.05(b) I. recites that “It is important to note that a general purpose computer that applies a judicial exception, such as an abstract idea, by use of conventional computer functions does not qualify as a particular machine”. In the case of the claimed invention, the generality of the computing components and the generic computing components performing conventional computing functions like displaying information do not make the claim recite a particular machine. In view of the above, the claimed invention is still most accurately analyzed as Mere Instructions to Apply and Exception in MPEP 2106.05(f). Applicant’s arguments that the claimed invention is eligible at Step 2A Prong 2 are unpersuasive, and the 35 U.S.C. 101 rejections have been maintained.
Applicant’s arguments, see pages 20-22, filed 10/08/2025, with respect to the 35 U.S.C. 103 rejections of claims 1-20 have been fully considered but are moot. While Examiner respectfully disagrees with the particular claim limitations argued by Applicant as not being taught in the art, the resulting amendments as a whole do overcome the prior art of record for the reasoning discussed below. Specifically, Pepere teaches the determination of a carbon footprint for transactions including credit and debit in Col. 3-4, and Col. 7 lines 59-65 teach the calculation of greenhouse emission at least based on purchase electricity. Therefore, Examiner disagrees with Applicant’s argument on pages 20-22 that the limitation is not taught. However, the other amendments made to the amended independent claims, as a whole, nonetheless overcome the prior art. The 35 U.S.C. 103 rejections of claims 1-20 have been withdrawn.
Drawings
Additionally, the drawings are objected to as failing to comply with 37 CFR 1.84(p)(5) because they include the following reference character(s) not mentioned in the description: 186, 710. Corrected drawing sheets in compliance with 37 CFR 1.121(d), or amendment to the specification to add the reference character(s) in the description in compliance with 37 CFR 1.121(b) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance.
Furthermore, the drawings are objected to because it appears as though the “Fig. 9” circle in Fig.15 should read “Fig. 16” and the “Fig. 8” circle in Fig. 16 should read “Fig. 15”. According to page 13 of the specification, the operations of Figs. 15 and 16 are linked with each other. Corrected drawing sheets in compliance with 37 CFR 1.121(d) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. The figure or figure number of an amended drawing should not be labeled as “amended.” If a drawing figure is to be canceled, the appropriate figure must be removed from the replacement sheet, and where necessary, the remaining figures must be renumbered and appropriate changes made to the brief description of the several views of the drawings for consistency. Additional replacement sheets may be necessary to show the renumbering of the remaining figures. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance.
Claim Objections
Claims 8 and 15 are objected to because of the following informalities:
Claim 8 line 18 recites “…bank data of the customer;;” when it appears it should recite “…bank data of the customer;[[;]]” to correct a typographical error of multiple semicolons
Claim 15 lines 19-21 recite “estimate a total area under cultivation and a crop mix for the location of the farm corresponding to the customer” when it appears they should recite “estimating a total area under cultivation and a crop mix for the location of the farm corresponding to the customer” to match the verb tense used in the other recited steps of claim 15
Appropriate correction is required.
Claim Interpretation
As noted in the “Response to Arguments”, the claim 1 limitation of “computer system” is no longer being interpreted as invoking 35 U.S.C. 112(f).
Claim Rejections - 35 USC § 112
The following is a quotation of 35 U.S.C. 112(b):
(b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention.
Claims 15-20 are rejected under 35 U.S.C. 112(b) as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor regards as the invention.
Claim 15 recites the limitation "the internation bank data" in line 10. There is insufficient antecedent basis for this limitation in the claim. “Internation bank data” is not introduced earlier in claim 15, so the scope of claim 15 is indefinite.
As it appears Applicant is intending to refer back to “internal” bank data introduced in line 7 of the claim, for the purposes of examination Examiner is interpreting “the internation bank data” as “the internal bank data”.
Claims 16-20 are indefinite by virtue of their dependence on claim 15.
Additionally, claim 15 recites the limitation “the computer system” in lines 34 and 39. There is insufficient antecedent basis for this limitation in the claim. While “one or more computers” is introduced earlier in claim 15, it is unclear whether “the computer system” is referring to the “one or more computers” previously introduced or is introducing another system of computers. Accordingly, the scope of claim 15 is indefinite.
As it appears Applicant is intending to refer back to “one or more computers” introduced in line 2 of the claim, for the purposes of examination Examiner is interpreting “the computer system” as “the one or more computers”.
Claims 16-20 are indefinite by virtue of their dependence on claim 15.
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 an abstract idea without significantly more. The claims recite providing carbon emission estimates for agricultural clients of financial institutions.
As an initial matter, claims 1-7 fall into at least the process category of statutory subject matter. Claims 8-14 fall into at least the machine category of statutory subject matter. Finally, claims 15-20 fall into at least the manufacture category of statutory subject matter. Therefore, all claims fall into at least one of the statutory categories. Eligibility analysis proceeds to Step 2A.
In claim 1, the limitation of “A computer-implemented method comprises: generating an executable computer program configured to perform a set of computer operations comprising: accessing, by a computer system comprising one or more processors, internal bank data for a customer”, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components. That is, other than reciting “computer-implemented”, “an executable computer program configured to perform a set of computer operations”, and “a computer system comprising one or more processors,” nothing in the claim element precludes the step from practically being performed in the mind. Similarly, the limitations of “executing, by the computer system, one or more operations that use the internal bank data of the customer to identify sources of carbon emissions for a location of a farm corresponding to the customer, wherein identifying the sources of carbon emissions for the location of the farm comprises identifying at least one of (i) a fertilizer for the farm, (ii) farm supplies for the farm, (iii) electricity for the farm, or (iv) fossil fuels for the farm based on at least one of credit card transactions, debit account transactions, or credit memos of the internal bank data of the customer; estimating, by the computer system, a total area under cultivation and a crop mix for the location of the farm corresponding to the customer; rendering a graphical user interface, wherein the graphical user interface comprises a plurality of input elements representing parameters for determining a carbon emission estimate for the location of the farm, wherein at least some of the input elements represent the sources of carbon emissions for the location of the farm and are pre-populated with respective values based on at least one of the credit card transactions, the debit account transactions, and the credit memos, rendering, in the graphical user interface, a first pop-up window comprising: a map representing the location of the farm, an index representing the estimated crop mix of the location of the farm with respect to the map, and a graph representing the estimated crop mix of the location of the farm, generating, by the computer system, a customer carbon profile data structure based on values of the input elements, the estimated total area under cultivation and the crop mix for the location of the farm; inputting the customer carbon profile data structure to a carbon calculator to obtain a first carbon emission estimate for the location of the farm; determining, by the computer system, one or more second carbon emission estimates for the location of the farm based on one or more alternative planting strategies with respect to the location of the farm; and rendering, in the graphical user interface, a second pop-up window comprising the graphical representation of the first carbon emission estimate and the one or more second carbon emission estimates; and executing the executable computer program to generating to perform the set of computer operations”, as drafted, is a process that, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. Accordingly, the claims recite an abstract idea.
Additionally, claim 1 recites the concept of a financial institution gathering internal and external data to provide an agricultural client with carbon emission estimates which is a certain method of organizing human activity including commercial interactions. A method comprises: perform a set of operations comprising: accessing internal bank data for a customer; executing one or more operations that use the internal bank data of the customer to identify sources of carbon emissions for a location of a farm corresponding to the customer, wherein identifying the sources of carbon emissions for the location of the farm comprises identifying at least one of (i) a fertilizer for the farm, (ii) farm supplies for the farm, (iii) electricity for the farm, or (iv) fossil fuels for the farm based on at least one of credit card transactions, debit account transactions, or credit memos of the internal bank data of the customer; estimating a total area under cultivation and a crop mix for the location of the farm corresponding to the customer; rendering parameters for determining a carbon emission estimate for the location of the farm, wherein at least some of the sources of carbon emissions for the location of the farm and respective values based on at least one of the credit card transactions, the debit account transactions, and the credit memos, rendering: a map representing the location of the farm, an index representing the estimated crop mix of the location of the farm with respect to the map, and a graph representing the estimated crop mix of the location of the farm, generating a customer carbon profile data structure based on values of the input elements, the estimated total area under cultivation and the crop mix for the location of the farm; inputting the customer carbon profile data structure to a carbon calculator to obtain a first carbon emission estimate for the location of the farm; determining one or more second carbon emission estimates for the location of the farm based on one or more alternative planting strategies with respect to the location of the farm; and rendering the graphical representation of the first carbon emission estimate and the one or more second carbon emission estimates all, as a whole, fall under the category of commercial interactions. The claim falls into the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Mere recitation of generic computer components does not remove the claim from this grouping. Accordingly, the claim recites an abstract idea.
This judicial exception is not integrated into a practical application. In particular, the claim recites the additional elements of a “computer-implemented” method, generating an executable computer program configured to perform a set of computer operations, a computer system comprising one or more processors, rendering a graphical user interface comprising a plurality of input elements with at least some input elements being pre-populated, a first pop-up window, a second pop-up window, and executing the executable computer program configured to perform a set of computer operations. The recited additional elements are recited at a high-level of generality such that it amounts to no more than mere instructions to apply the exception using generic computer components. 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. The combination of these additional elements is also no more than mere instructions to apply the exception using generic computer components. Accordingly, even in combination, 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. The claim is directed to an abstract idea.
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements of “computer-implemented” method, generating an executable computer program configured to perform a set of computer operations, a computer system comprising one or more processors, rendering a graphical user interface comprising a plurality of input elements with at least some input elements being pre-populated, a first pop-up window, a second pop-up window, and executing the executable computer program configured to perform a set of computer operations amounts to no more than mere instructions to apply the exception using generic computer components. The combination of these additional elements is also no more than mere instructions to apply the exception using generic computer components. Mere instructions to apply an exception using generic computer components cannot provide an inventive concept. The claim is not patent eligible.
Claims 2-7 further limit the abstract idea of claim 1 without adding any new additional elements. Therefore, by the analysis of claim 1 above these claims, individually and as an ordered combination, do not integrate the abstract idea into a practical application nor amount to significantly more than the abstract idea. The claims are not patent eligible.
In claim 8, the limitation of “access internal bank data for a customer”, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components. That is, other than reciting “A computer system comprises: one or more processors; memory storing computer instructions for causing the one or more processor to: generate an executable computer program configured to perform a set of computer operations comprising,” nothing in the claim element precludes the step from practically being performed in the mind. Similarly, the limitations of “execute one or more operations that use the internal bank data of the customer to identify sources of carbon emissions for a location of a farm corresponding to the customer, wherein identifying the sources of carbon emissions for the location of the farm comprises identifying at least one of (i) a fertilizer for the farm, (ii) farm supplies for the farm, (iii) electricity for the farm, or (iv) fossil fuels for the farm based on at least one of credit card transactions, debit account transactions, or credit memos of the internal bank data of the customer;; estimate a total area under cultivation and a crop mix for the location of the farm corresponding to the customer; render a graphical user interface, wherein the graphical user interface comprises a plurality of input elements representing parameters for determining a carbon emission estimate for the location of the farm, wherein at least some of the input elements represent the sources of carbon emissions for the location of the farm and are pre-populated with respective values based on at least one of the credit card transactions, the debit account transactions, and the credit memos, render, in the graphical user interface, a first pop-up window comprising: a map representing the location of the farm, an index representing the estimated crop mix of the location of the farm with respect to the map, and a graph representing the estimated crop mix of the location of the farm, generate, by the computer system, a customer carbon profile data structure based on values of the input elements, the estimated total area under cultivation and the crop mix for the location of the farm; input the customer carbon profile data structure to a carbon calculator to obtain a first carbon emission estimate for the location of the farm; determine, by the computer system, one or more second carbon emission estimates for the location of the farm based on one or more alternative planting strategies with respect to the location of the farm; and render, in the graphical user interface, a second pop-up window comprising the graphical representation of the first carbon emission estimate and the one or more second carbon emission estimates; and execute the executable computer program to generating to perform the set of computer operations”, as drafted, is a process that, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. Accordingly, the claims recite an abstract idea.
Additionally, claim 8 recites the concept of a financial institution gathering internal and external data to provide an agricultural client with carbon emission estimates which is a certain method of organizing human activity including commercial interactions. Access internal bank data for a customer; execute one or more operations that use the internal bank data of the customer to identify sources of carbon emissions for a location of a farm corresponding to the customer, wherein identifying the sources of carbon emissions for the location of the farm comprises identifying at least one of (i) a fertilizer for the farm, (ii) farm supplies for the farm, (iii) electricity for the farm, or (iv) fossil fuels for the farm based on at least one of credit card transactions, debit account transactions, or credit memos of the internal bank data of the customer;; estimate a total area under cultivation and a crop mix for the location of the farm corresponding to the customer; render parameters for determining a carbon emission estimate for the location of the farm, wherein at least some represent the sources of carbon emissions for the location of the farm and respective values based on at least one of the credit card transactions, the debit account transactions, and the credit memos, render a map representing the location of the farm, an index representing the estimated crop mix of the location of the farm with respect to the map, and a graph representing the estimated crop mix of the location of the farm, generate a customer carbon profile data structure based on values of the input elements, the estimated total area under cultivation and the crop mix for the location of the farm; input the customer carbon profile data structure to a carbon calculator to obtain a first carbon emission estimate for the location of the farm; determine one or more second carbon emission estimates for the location of the farm based on one or more alternative planting strategies with respect to the location of the farm; and render the graphical representation of the first carbon emission estimate and the one or more second carbon emission estimates all, as a whole, fall under the category of commercial interactions. The claim falls into the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Mere recitation of generic computer components does not remove the claim from this grouping. Accordingly, the claim recites an abstract idea.
This judicial exception is not integrated into a practical application. In particular, the claim recites the additional elements of a computer system, one or more processors, memory storing computer instructions for causing the one or more processor to generate an executable computer program configured to perform a set of computer operations, rendering a graphical user interface comprising a plurality of input elements with at least some input elements being pre-populated, a first pop-up window, a second pop-up window, and executing the executable computer program configured to perform a set of computer operations. The recited additional elements are recited at a high-level of generality such that it amounts to no more than mere instructions to apply the exception using generic computer components. 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. The combination of these additional elements is also no more than mere instructions to apply the exception using generic computer components. Accordingly, even in combination, 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. The claim is directed to an abstract idea.
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements of a computer system, one or more processors, memory storing computer instructions for causing the one or more processor to generate an executable computer program configured to perform a set of computer operations, rendering a graphical user interface comprising a plurality of input elements with at least some input elements being pre-populated, a first pop-up window, a second pop-up window, and executing the executable computer program configured to perform a set of computer operations amounts to no more than mere instructions to apply the exception using generic computer components. The combination of these additional elements is also no more than mere instructions to apply the exception using generic computer components. Mere instructions to apply an exception using generic computer components cannot provide an inventive concept. The claim is not patent eligible.
Claims 9-14 further limit the abstract idea of claim 8 without adding any new additional elements. Therefore, by the analysis of claim 8 above these claims, individually and as an ordered combination, do not integrate the abstract idea into a practical application nor amount to significantly more than the abstract idea. The claims are not patent eligible.
In claim 15, the limitation of “accessing internal bank data for a customer”, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components. That is, other than reciting “One or more non-transitory computer-readable storage media storing instructions that when executed by one or more computers cause the one or more computers to perform operations comprising: generating an executable computer program configured to perform a set of computer operations comprising:,” nothing in the claim element precludes the step from practically being performed in the mind. Similarly, the limitations of “executing one or more operations that use the internation bank data of the customer to identify sources of carbon emissions for a location of a farm corresponding to the customer; wherein identifying the sources of carbon emissions for the location of the farm comprises identifying at least one of (i) a fertilizer for the farm, (ii) farm supplies for the farm, (iii) electricity for the farm, or (iv) fossil fuels for the farm based on at least one of credit card transactions, debit account transactions, or credit memos of the internal bank data of the customer; estimate a total area under cultivation and a crop mix for the location of the farm corresponding to the customer; rendering a graphical user interface, wherein the graphical user interface comprises a plurality of input elements representing parameters for determining a carbon emission estimate for the location of the farm, wherein at least some of the input elements represent the sources of carbon emissions for the location of the farm and are pre-populated with respective values based on at least one of the credit card transactions, the debit account transactions, and the credit memos, rendering, in the graphical user interface, a first pop-up window comprising: a map representing the location of the farm, an index representing the estimated crop mix of the location of the farm with respect to the map, and a graph representing the estimated crop mix of the location of the farm, generating, by the computer system, a customer carbon profile data structure based on values of the input elements, the estimated total area under cultivation and the crop mix for the location of the farm; inputting the customer carbon profile data structure to a carbon calculator to obtain a first carbon emission estimate for the location of the farm; determining, by the computer system, one or more second carbon emission estimates for the location of the farm based on one or more alternative planting strategies with respect to the location of the farm; and rendering, in the graphical user interface, a second pop-up window comprising the graphical representation of the first carbon emission estimate and the one or more second carbon emission estimates; and executing the executable computer program to generating to perform the set of computer operations”, as drafted, is a process that, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. Accordingly, the claims recite an abstract idea.
Additionally, claim 15 recites the concept of a financial institution gathering internal and external data to provide an agricultural client with carbon emission estimates which is a certain method of organizing human activity including commercial interactions. Accessing internal bank data for a customer; executing one or more operations that use the internation bank data of the customer to identify sources of carbon emissions for a location of a farm corresponding to the customer; wherein identifying the sources of carbon emissions for the location of the farm comprises identifying at least one of (i) a fertilizer for the farm, (ii) farm supplies for the farm, (iii) electricity for the farm, or (iv) fossil fuels for the farm based on at least one of credit card transactions, debit account transactions, or credit memos of the internal bank data of the customer; estimate a total area under cultivation and a crop mix for the location of the farm corresponding to the customer; rendering parameters for determining a carbon emission estimate for the location of the farm, wherein at least some represent the sources of carbon emissions for the location of the farm and respective values based on at least one of the credit card transactions, the debit account transactions, and the credit memos, rendering a map representing the location of the farm, an index representing the estimated crop mix of the location of the farm with respect to the map, and a graph representing the estimated crop mix of the location of the farm, generating a customer carbon profile data structure based on values of the input elements, the estimated total area under cultivation and the crop mix for the location of the farm; inputting the customer carbon profile data structure to a carbon calculator to obtain a first carbon emission estimate for the location of the farm; determining one or more second carbon emission estimates for the location of the farm based on one or more alternative planting strategies with respect to the location of the farm; and rendering the graphical representation of the first carbon emission estimate and the one or more second carbon emission estimates all, as a whole, fall under the category of commercial interactions. The claim falls into the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Mere recitation of generic computer components does not remove the claim from this grouping. Accordingly, the claim recites an abstract idea.
This judicial exception is not integrated into a practical application. In particular, the claim recites the additional elements of one or more non-transitory computer-readable storage media storing instructions, one or more computers that execute the instructions to perform operations, generating an executable computer program configured to perform a set of computer operations, rendering a graphical user interface comprising a plurality of input elements with at least some input elements being pre-populated, a first pop-up window, a computer system, a second pop-up window, and executing the executable computer program configured to perform a set of computer operations. The recited additional elements are recited at a high-level of generality such that it amounts to no more than mere instructions to apply the exception using generic computer components. 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. The combination of these additional elements is also no more than mere instructions to apply the exception using generic computer components. Accordingly, even in combination, 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. The claim is directed to an abstract idea.
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements of one or more non-transitory computer-readable storage media storing instructions, one or more computers that execute the instructions to perform operations, generating an executable computer program configured to perform a set of computer operations, rendering a graphical user interface comprising a plurality of input elements with at least some input elements being pre-populated, a first pop-up window, a computer system, a second pop-up window, and executing the executable computer program configured to perform a set of computer operations amounts to no more than mere instructions to apply the exception using generic computer components. The combination of these additional elements is also no more than mere instructions to apply the exception using generic computer components. Mere instructions to apply an exception using generic computer components cannot provide an inventive concept. The claim is not patent eligible.
Claims 16-20 further limit the abstract idea of claim 15 without adding any new additional elements. Therefore, by the analysis of claim 15 above these claims, individually and as an ordered combination, do not integrate the abstract idea into a practical application nor amount to significantly more than the abstract idea. The claims are not patent eligible.
Novel/Non-Obvious
As discussed in the 07/08/2025 Non-Final Rejection, the combination of Cogan et al. (U.S. Pre-Grant Publication No. 2024/0078561, hereafter known as Cogan. Examiner notes that the citations below all have support in provisional application 63/400690, and thus have an effectively filed date of 08/24/2022) in view of Pepere et al. (U.S. Patent No. 10,902,484; hereafter known as Pepere) taught the limitations of original claim 1. The combination of Cogan and Pepere still teach the majority of amended claim 1. Cogan teaches a computer-implemented method comprising generating an executable computer program and executing the computer program (Figs. 4 and 6 and [0062]-[0091] and [0097]-[0098] for method and [0046] for executable computer program) to access internal bank data of a farm customer to identify sources of carbon emissions (see [0063], [0045], and [0058]) including fertilizer and supplies (see Table 1). Cogan estimates a total area under cultivation ([0063] and [0085]-[0087]) and renders a graphical user interface with input parameters for determining a carbon emission estimate, with some of the parameters representing carbon sources and being pre-populated (Figs. 10A-10B, [0063] and [0100]). Cogan further teaches the generation of a customer carbon profile data in the for of customer database 312 that is updated with various information at steps 412, 436, and 456, with the information used to subsequently calculate carbon emission estimates. Cogan also teaches in [0096] the determination of alternate farming practices.
Pepere teaches the use of credit/debit transactions (Col. 4 lines 16-27 and 4 lines 46-59) to identify sources of emissions including electricity and fuel usage (Col. 7 lines 59-65).
Other prior art teaches the remaining limitations of amended claim 1 individually. Guo et al. (U.S. Pre-Grant Publication No. 2019/0228224, hereafter known as Guo) teaches graphical user interface comprising a map and index of a crop mix and depicting a farm in Fis. 3A and 3B.
Ghosh (“Mapped: The Anatomy of Land Use in America”, published 01/14/2020, hereafter known as Ghosh’) teaches a graph representing the crop mix of a land area on page 4 (“Crop Types”).
Ashtekar (U.S. Pre-Grant Publication No. 2022/0138767, hereafter known as Ashtekar) teaches in Fig. 13 a graphical user interface comprising a comparison of carbon footprints from baseline and regenerative farming practices.
Finally, Placella et al. (U.S. Pre-Grant Publication No. 2021/0029866, hereafter known as Placella) teaches displaying data in an agricultural management system in pop-up windows.
Therefore, all of the limitations in amended claim 1 are taught individually in the prior art. However, it would not have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine the teachings of Cogan, Pepere, Guo, Ghosh’, Ashtekar, and Placella in such a manner as to arrive at Applicant’s claimed invention. Accordingly, the amended claim 1 is non-obvious over the prior art of record.
Independent claims 8 and 15 are non-obvious over the prior art of record for similar reasoning described above regarding claim 1. Dependent claims 2-7, 9-14, and 16-20 are non-obvious over the prior art of record by virtue of their dependence on their respective non-obvious independent claims.
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.
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/M.C.M./Examiner, Art Unit 3628
/RESHA DESAI/Supervisory Patent Examiner, Art Unit 3628