Prosecution Insights
Last updated: April 19, 2026
Application No. 18/439,158

METHODS AND SYSTEMS FOR SOFTWARE CODE GENERATION

Non-Final OA §101§102§103
Filed
Feb 12, 2024
Examiner
RIVERA, ANIBAL
Art Unit
2192
Tech Center
2100 — Computer Architecture & Software
Assignee
Box Inc.
OA Round
1 (Non-Final)
91%
Grant Probability
Favorable
1-2
OA Rounds
2y 6m
To Grant
99%
With Interview

Examiner Intelligence

Grants 91% — above average
91%
Career Allow Rate
674 granted / 743 resolved
+35.7% vs TC avg
Moderate +12% lift
Without
With
+12.1%
Interview Lift
resolved cases with interview
Typical timeline
2y 6m
Avg Prosecution
21 currently pending
Career history
764
Total Applications
across all art units

Statute-Specific Performance

§101
14.6%
-25.4% vs TC avg
§103
40.9%
+0.9% vs TC avg
§102
27.2%
-12.8% vs TC avg
§112
7.7%
-32.3% vs TC avg
Black line = Tech Center average estimate • Based on career data from 743 resolved cases

Office Action

§101 §102 §103
DETAILED ACTION This action is responsive to application filed on February 12, 2024. Claims 1-20 are pending and are presented to examination. The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . 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 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. Examiner Notes Examiner cites particular columns, paragraphs, figures and line numbers in the references as applied to the claims below for the convenience of the applicant. Although the specified citations are representative of the teachings in the art and are applied to the specific limitations within the individual claim, other passages and figures may apply as well. It is respectfully requested that, in preparing responses, the applicant fully consider the references in their entirety as potentially teaching all or part of the claimed invention, as well as the context of the passage as taught by the prior art or disclosed by the examiner. Drawings The drawings filed on February 12, 2024 are acceptable for examination purposes. Specification Applicant is reminded of the proper language and format for an abstract of the disclosure. The abstract should be in narrative form and generally limited to a single paragraph on a separate sheet within the range of 50 to 150 words in length. The abstract should describe the disclosure sufficiently to assist readers in deciding whether there is a need for consulting the full patent text for details. The language should be clear and concise and should not repeat information given in the title. It should avoid using phrases which can be implied, such as, “The disclosure concerns,” “The disclosure defined by this invention,” “The disclosure describes,” etc. In addition, the form and legal phraseology often used in patent claims, such as “means” and “said,” should be avoided. he abstract of the disclosure is objected to because includes phrase such as “…”. A corrected abstract of the disclosure is required and must be presented on a separate sheet, apart from any other text. See MPEP § 608.01(b). Claim objections Claims 8-20 are objected to because of the following informalities: Claims 8 and 15, “the computer source code” (see line 6 of claim 8 and line 4 of claim 15) lacks proper antecedent basis. Claims 9-14 and 16-20 depend on objected claims and inherit the same issue. Appropriate correction is required. 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 recites a judicial exception, is directed to that judicial exception, an abstract idea, as it has not been integrated into practical application and the claims further do not recite significantly more than the judicial exception. Examiner has evaluated the claims under the framework provided in the 2019 Patent Eligibility Guidance published in the Federal Register 01/07/2019 and has provided such analysis below. Step 1: Claims 1-7 are directed to methods and fall within the statutory category of processes; Claims 8-14 are directed to systems and fall within the statutory category of machines; and Claims 15-20 are directed to mediums and fall within the statutory category of manufactures. Therefore, “Are the claims to a process, machine, manufacture or composition of matter?” Yes. In order to evaluate the Step 2A inquiry “Is the claim directed to a law of nature, a natural phenomenon or an abstract idea?” we must determine, at Step 2A Prong 1, whether the claim recites a law of nature, a natural phenomenon or an abstract idea and further whether the claim recites additional elements that integrate the judicial exception into a practical application. Step 2A Prong 1: Claims 1, 8 and 15 as drafted, recite a process that, under its broadest reasonable interpretation, covers steps that could reasonably be performed in the mind, including with the aid of pen and paper, but for the recitation of generic computer components. That is, the limitations: a) “receiving, ” b) “creating, ” c) “transforming, ” d) “” For example, for limitations a)-c), a person using pen and paper can receive information to defining a code and is able to create a code based on the information representing a node/block, also a person using pen and paper can modify the code to create an intermediate representation. That is, nothing in the claim elements precludes the step from practically being performed in the mind or with a pen and paper, (i.e., “receiving”, “creating”, transforming”) can be performed in the human mind though observation, evaluation, judgment, opinion with the aid of pen and paper. Thus, these limitations fall within the “Mental Processes” grouping of abstract ideas. Therefore, Yes, claims 1, 8 and 15 recite judicial exceptions. The claims have been identified to recite judicial exceptions, Step 2A Prong 2 will evaluate whether the claims are directed to the judicial exception. Step 2A Prong 2: This judicial exception is not integrated into a practical application. The claims recite the following additional elements: “a processor”, “a code generation system”, “a memory”, “a system”; and “a non-transitory, computer-readable medium”. The additional elements are merely instructions to implement an abstract idea on a computer, or merely using a generic computer or computer components as a tool to perform the abstract idea (see MPEP 2106.05(f)). Further, “transpiling, by the processor of the code generation system, the intermediate, transformed coding node into software source code in a target programming language of a plurality of programming languages” amount no more than mere instructions to apply the xeception using a generic computer component. Accordingly, the additional elements recited in the claims do not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea, thus failing to integrate the abstract idea into a practical application. Therefore, “Do the claims recite additional elements that integrate the judicial exception into a practical application? No, these additional elements do not integrate the abstract idea into a practical application and they do not impose any meaningful limits on practicing the abstract idea. The claim is directed to an abstract idea. After having evaluating the inquires set forth in Steps 2A Prong 1 and 2, it has been concluded that claims 1, 8 and 15 not only recites a judicial exception but that the claim is directed to the judicial exception as the judicial exception has not been integrated into practical application. Step 2B: With respect to “transpiling, by the processor of the code generation system, the intermediate, transformed coding node into software source code in a target programming language of a plurality of programming languages.” when re-evaluated this element is well-understood, routine, conventional activity (see Morales US Pub. No. 2025/0342017, paragraph [0002]), therefor does not provide significantly more. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements “a processor”, “a code generation system”, “a memory”, “a system”; and “a non-transitory, computer-readable medium” are generic computer components used as tools to perform the abstract idea. Accordingly, the additional elements recited in the claims cannot provide an inventive concept. Thus, the claims are not patent eligible. Therefore, “Do the claims recite additional elements that amount to significantly more than the judicial exception? No, these additional elements, alone or in combination, do not amount to significantly more than the judicial exception. Having concluded analysis within the provided framework, Claims 1, 8 and 15 do not recite patent eligible subject matter under 35 U.S.C. § 101. With regards to claim 2 (and similar for claims 9 and 16), it recites “wherein the information defining the coding node comprises Javascript Syntax eXtension (JSX) code.”. which merely provide details for type of code of the coding node that is part of the mental process identified above with respect to claims 1, 8 and 15. Moreover, claim 2 does not recite any other additional elements and for the same reasons as above with regard to integration into practical application and whether additional elements amount to significantly more, claim 2 also fails both Step 2A prong 2, thus the claim is directed to the judicial exception as it has not been integrated into practical application, and fails Step 2B as not amounting to significantly more Therefore, Claim 2 does not recite patent eligible subject matter under 35 U.S.C. § 101. With regards to claim 3 (and similar for claims 10 and 17), it recites “wherein the information defining the coding node further comprises user defined information.”. which merely provide details of what the coding node contain that is part of the mental process identified above with respect to claims 1, 8 and 15. Moreover, claim 3 does not recite any other additional elements and for the same reasons as above with regard to integration into practical application and whether additional elements amount to significantly more, claim 3 also fails both Step 2A prong 2, thus the claim is directed to the judicial exception as it has not been integrated into practical application, and fails Step 2B as not amounting to significantly more Therefore, Claim 3 does not recite patent eligible subject matter under 35 U.S.C. § 101. With regards to claim 4 (and similar for claims 11 and 18), it recites “wherein creating the coding node comprises generating one or more of: a node type; one or more node attributes; or one or more child nodes for the coding node based on the received information defining the coding node.”. which merely provide details of the generating an additional node with the coding node that is part of the mental process identified above with respect to claims 1, 8 and 15. Moreover, claim 4 does not recite any other additional elements and for the same reasons as above with regard to integration into practical application and whether additional elements amount to significantly more, claim 4 also fails both Step 2A prong 2, thus the claim is directed to the judicial exception as it has not been integrated into practical application, and fails Step 2B as not amounting to significantly more Therefore, Claim 4 does not recite patent eligible subject matter under 35 U.S.C. § 101. With regards to claim 5 (and similar for claims 12 and 19), it recites “wherein creating the coding node further comprises performing a preliminary validation on the coding node.”. which merely provide details for generation of the coding node using a validation that is part of the mental process identified above with respect to claims 1, 8 and 15. Moreover, claim 5 does not recite any other additional elements and for the same reasons as above with regard to integration into practical application and whether additional elements amount to significantly more, claim 5 also fails both Step 2A prong 2, thus the claim is directed to the judicial exception as it has not been integrated into practical application, and fails Step 2B as not amounting to significantly more Therefore, Claim 5 does not recite patent eligible subject matter under 35 U.S.C. § 101. With regards to claim 6 (and similar for claims 13 and 20), it recites “wherein transforming the coding node into the intermediate, transformed coding node further comprises: gathering additional information defining a context for the coding node; validating the coding node for unresolved references and anomalies; modifying the coding node based on the information defining the coding node and the object tree; and propagating one or more code characteristics from the modified coding node to the intermediate, transformed coding node.”, as drafted, is a process that, but for the recitation of generic computing components, under its broadest reasonable interpretation, covers performance of the limitation in the mind. For example, a person using pen and paper can gather information, validate and modify code based on the information. Moreover, claim 6 does not recite any other additional elements and for the same reasons as above with regard to integration into practical application and whether additional elements amount to significantly more, claim 6 also fails both Step 2A prong 2, thus the claim is directed to the judicial exception as it has not been integrated into practical application, and fails Step 2B as not amounting to significantly more Therefore, Claim 6 does not recite patent eligible subject matter under 35 U.S.C. § 101. With regards to claim 7 (and similar for claim 14), it recites “wherein transpiling the intermediate, transformed coding node into the source code in the target programming language comprises selecting a transpiler from a plurality of available transpilers based on the target programming language..” as drafted, is considered mere instructions to implement an abstract idea or other exception on a computer (See MPEP 2106.05(f)). Moreover, claim 7 does not recite any other additional elements and for the same reasons as above with regard to integration into practical application and whether additional elements amount to significantly more, claim 7 also fails both Step 2A prong 2, thus the claim is directed to the judicial exception as it has not been integrated into practical application, and fails Step 2B as not amounting to significantly more Therefore, Claim 7 does not recite patent eligible subject matter under 35 U.S.C. § 101. Therefore, Claims 1-20 do not recite patent eligible subject matter under 35 U.S.C. § 101. Claim Rejections - 35 USC § 102 The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention. Claims 1-4, 8-11 and 15-18 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Cory Gackenheimer, “Introduction to React” – hereinafter Gackenheimer). With respect to claim 1, Gackenheimer teaches a method for automated generation of computer source code, the method comprising: receiving, by a processor of a code generation system, information defining a coding node, the coding node comprising a definition of an object within an object tree for the computer source code (See chapter 4 “Building a React Web Application” on pages 65-86. See at least listings 4-9-4.11, JSX definition file/code including nested objects. PNG media_image1.png 640 675 media_image1.png Greyscale See Chapter 3 “JSX Fundamentals” on pages 43-64 and listing 3.1-3.18, which shows JSX definitions and how to incorporate it in a workflow when building an application which transforms XML syntax to JavaScript in React. Lastly, this section presents multiple examples utilizing JSX to build templates and nested elements. Furthermore, see chapter 1 “What is React?” on pages 1-20. Examiner notes: definition and nested objects). creating, by the processor of the code generation system, the coding node based on the received information defining the coding node (See Chapter 3 “JSX Fundamentals” on pages 43-64 and all listings 3-1-3-18, which shows JSX definitions and how to incorporate it in a workflow when building an application which transforms XML syntax to JavaScript in React. Lastly, this section presents multiple examples utilizing JSX to build templates and nested elements. Furthermore, see chapter 1 “What is React?” on pages 1-20. Examiner notes: creating nested coding nodes). transforming, by the processor of the code generation system, the coding node into an intermediate, transformed coding node (See Chapter 3 “JSX Fundamentals” on pages 43-64 and all listings 3-1-3-18, which shows JSX definitions and how to incorporate it in a workflow when building an application which transforms XML syntax to JavaScript in React. Lastly, this section presents multiple examples utilizing JSX to build templates and nested elements. Furthermore, see chapter 1 “What is React?” on pages 1-20 and listing 1-7. Examiner notes: intermediate transformation to be transpiled in the next step) and transpiling, by the processor of the code generation system, the intermediate, transformed coding node into software source code in a target programming language of a plurality of programming languages (See page 11 first paragraph, “Listing 1-7 shows an interesting view of how React works. You will learn how this is implemented in the rest of the book, but the basics are in bold in the example. First, you see what looks like an HTML or XML element <TodoApp model={model}/>. This is the JSX, or the JavaScript XML transpiler, that was created to integrate with React.:”. See section “React Elements” on page 40, “You can create a React element using JSX, which you will see in detail in the next chapter, or you can create one using React.createElement. React.createElement is the same as JSX because that is what JSX uses after it is transpiled to JavaScript, as you saw at the beginning of this chapter.”. See page 45, third paragraph, “You see the benefits that JSX brings. It is more concise to write, yet it still lends itself to transpiling into robust JavaScript that is necessary to power your React applications. It is also, in general, more approachable to anyone who is familiar with HTML syntax. This is not only your leading JavaScript developers, but also the designers— if you split roles in such a way—of your project can have access to structuring the output of your React components with JSX”. Furthermore, see page 50 first paragraph and listing 3-6, “Here you see a GenericComponent, which is just a container div that holds another componented GreetingComponent. The GenericComponent is rendered by calling an attribute, similar to how Hello component in the previous example. However, here there is a secondary layer of ReactComponent that passes the this.props.name as an attribute to its child element. Naturally, you would not want to make an interface that looks like this in the real world, but you would not be in the business of making Hello components either. You can assume that this is just an example to showcase how JSX transpiles nested components. The result of the JSX transformation is shown in Listing 3-6.”. Examiner notes: transpiling step). With respect to claim 2, Gackenheimer teaches wherein the information defining the coding node comprises Javascript Syntax eXtension (JSX) code (See chapter 4 “Building a React Web Application” on pages 65-86. See at least listings 4-9-4.11, JSX definition file/code including nested objects. See Chapter 3 “JSX Fundamentals” on pages 43-64 and listing 3.1-3.18). With respect to claim 3, Gackenheimer teaches wherein the information defining the coding node further comprises user defined information (Based on paragraph [0057] of the instant application, “user defined information” appears to be an action of manually add information into the code. Examiner notes: the specification is silent to disclose what the user defined information actually is, making this requirement broad for other possible interpretations. In this case, applying a broadest reasonable interpretation, examiner interprets all the listings (e.g., code) shown in the prior art a step of adding manual data that can be modified by a user/developer when writing the code down). With respect to claim 4, Gackenheimer teaches wherein creating the coding node comprises generating one or more of: a node type; one or more node attributes; or one or more child nodes for the coding node based on the received information defining the coding node (based on figure 5 and paragraph [0052] of the instant application, “node type” is a “string type”. The prior art shows in various code listings string types, attributes and nested/child objects, for example, see listing 5-10 on page 103). With respect to claims 8-11, the claims are directed to a system that corresponds to the method recited in claims 1-4, respectively (see the rejection of claims 1-4 above; wherein Gackenheimer also teaches such system (e.g., machine) in page 46 which receives an installation step, one skilled person in the art would also know this machine must have a processor and memory in order to properly function). With respect to claims 15-18, the claims are directed to a non-transitory, computer-readable medium that corresponds to the method recited in claims 1-4, respectively (see the rejection of claims 1-4 above; wherein Gackenheimer also teaches such medium (e.g., memory) in page 46 which mention a machine, one skilled person in the art would also know this machine must have a processor and memory in order to properly function). Claim Rejections - 35 USC § 103 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. The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. Claims 5-6, 12-13 and 19-20 are rejected under 35 U.S.C. 103 as being unpatentable over Cory Gackenheimer, “Introduction to React” – hereinafter Gackenheimer) in view of Rattray (US Pat. No. 11,709,659). With respect to claim 5, Gackenheimer is silent to disclose, however in an analogous art, Rattray teaches wherein creating the coding node further comprises performing a preliminary validation on the coding node (see figure 4, blocks 410, 412 and 414. Examiner notes: validation step). Therefore, it would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to modify Gackenheimer’s teaching, by performing a preliminary validation when creating coding node as suggested by Rattray, as Rattray would provide a code generation tool that could generates and validates readable code in several languages (see column 2 lines 20-23). With respect to claim 6, Gackenheimer is silent to disclose, however in an analogous art, Rattray teaches gathering additional information defining a context for the coding node (see step 406); validating the coding node for unresolved references and anomalies (see step 410); modifying the coding node based on the information defining the coding node and the object tree (see step 404); and propagating one or more code characteristics from the modified coding node to the intermediate, transformed coding node (see step 408). PNG media_image2.png 832 576 media_image2.png Greyscale Therefore, it would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to modify Gackenheimer’s teaching, by performing a validation and transforming steps when creating coding node as suggested by Rattray, as Rattray would provide a code generation tool that could generates and validates readable code in several languages (see column 2 lines 20-23). With respect to claims 12-13, the claims are directed to a system that corresponds to the method recited in claims 5-6, respectively (see the rejection of claims 5-6 above). With respect to claims 19-20, the claims are directed to a non-transitory, computer-readable medium that corresponds to the method recited in claims 5-6, respectively (see the rejection of claims 5-6 above). Claims 7 and 14 are rejected under 35 U.S.C. 103 as being unpatentable over Cory Gackenheimer, “Introduction to React” – hereinafter Gackenheimer) in view of Gore et al. (US Pat. No. 10,733,303). With respect to claim 7, Gackenheimer is silent to disclose, however in an analogous art, Gore teaches wherein transpiling the intermediate, transformed coding node into the source code in the target programming language comprises selecting a transpiler from a plurality of available transpilers based on the target programming language (see column 3 lines 6-35, figure 1 and claim 6). Therefore, it would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to modify Gackenheimer’s teaching, by selecting a transpiler from a plurality of available transpilers based on the target programming language as suggested by Gore, as Gore would provide a way to convert source code from one high-level programming language (or version) to another. With respect to claim 14, the claim is directed to a system that corresponds to the method recited in claim 7, respectively (see the rejection of claim 7 above). Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Innocent Joseph et al. (“Software Framework Of An All-In-One Transpiler For Development Of WORA Applications”) discloses a method that deals with the translation of program from one high level language to another high level language. (see abstract). Any inquiry concerning this communication or earlier communications from the examiner should be directed to ANIBAL RIVERACRUZ whose telephone number is (571)270-1200. The examiner can normally be reached Monday-Friday 9:30 AM-6:00 PM. 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, Hyung S Sough can be reached at 5712726799. 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. /ANIBAL RIVERACRUZ/Primary Examiner, Art Unit 2192
Read full office action

Prosecution Timeline

Feb 12, 2024
Application Filed
Feb 20, 2026
Non-Final Rejection — §101, §102, §103 (current)

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Prosecution Projections

1-2
Expected OA Rounds
91%
Grant Probability
99%
With Interview (+12.1%)
2y 6m
Median Time to Grant
Low
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