DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on November 14, 2025 has been entered.
Status of Claims
Claims 1-14 and 16-20 were previously pending and subject to a final rejection dated August 15, 2025. In RCE, submitted November 14, 2025, claims 1, 10, 11, 19, and 20 were amended. Therefore, claims 1-14 and 16-20 are currently pending and subject to the following non-final rejection.
Response to Arguments
Applicant’s remarks on Pages 11-13 of the Response, regarding the previous rejection of the claims under 35 U.S.C. 101, have been fully considered and are not found persuasive.
On Page 12 of the Response, Applicant argues “Applicant respectfully submits that amended claim 1 goes well beyond such generality. The Specification describes a multi-API backend architecture that controls communication between the frontend dashboard (304), data API (310a), insights API (310b), and emissions-estimation API (310c), as illustrated in FIG. 3. The insights API call (308b,308c) obtains weather data from a third- party weather API (316); the estimation API call (308d) triggers the emissions-estimation API (310c) to recompute emissions using both the newly entered farm data and the retrieved climate data. The backend then updates the affected database entities (e.g., ‘client_land_use,’ ‘client_crop_activity,’ or ‘client_finance_lkp,’ as described in paragraph [0078]) in the system database (312) and returns theupdated emission scores to the frontend dashboard for display. This architecture achieves more than organizing information; it integrates the alleged abstract idea into a specific, structured technological process for exchanging, processing, and updating data across multiple networked components.
Examiner notes, as discussed further in the detailed rejection below, the frontend and the various “entities” of the “system database” (representative claim 1) are used simply as tools to perform the abstract processes of “exchanging, processing, and updating data” as well as the abstract “return[ing] the updated emissions scores … for display”. This analysis is supported by the generality with which the Applicants’ specification discloses the “frontend” as a user interface which “may be implemented on one of the user devices 104, and comprises a dashboard 304 that displays on the user device 104 client data, climate insights, and emissions estimations” (specification, para. 47), and the “entities” as merely sub-categories or sub-databases for storing particular types of data within the system database of the “the backend” which is generally disclosed as possibly “implemented on the servers 108 comprising part of the data center… is able to store in the system database 312 all the information sent to the data API 310a as discussed below” (specification, paras. 54, 78). These additional elements (i.e., the entities, the system database, and the backend) are recited as merely “apply it”, and fail to integrate the abstract idea into a practical application. Additionally, the additional elements of the “data API”, the “insights API”, the “emissions-estimation API”, the “insights API call”, the “weather API”, and the “estimation API call” are used to perform the abstract ideas such as “obtain[ing] weather data from a third-party” and “recomputing emissions using both the newly entered farm data and the retrieved climate data”. However, no detail is provided for how these APIs and API calls work to communicate and process this data beyond the general disclosures provided in the specification, such as in paras. 54-55. This supports the Examiner’s analysis that these additional elements merely generally link the recited abstract idea to the field of use of API communication technology but fail to integrate the abstract idea into a practical application. Thus, while structured technical elements are recited along side the abstract idea, they fail to bring the claims to eligibility at Step 2A, Prong Two.
On Page 12 of the Response, Applicant argues “Further, even assuming arguendo that a frontend, backend, and API calls generally are known in the art in isolation[.] … Here, the coordinated use of the frontend, backend computing environment, and distinct APIs operates in a specific combination used to generate the emissions estimate, and accordingly achieves such integration. Accordingly, amended claim 1 integrates any judicial exception into a practical application and is eligible under Step 2A, Prong 2.
Examiner notes, as discussed further in the detailed rejection below, the additional elements are analyzed both individually and as a whole/ordered combination. However, even in combination (such as the combinations depicted in Figs. 1, 2, 3, and 7A-B) the additional elements still amount to either “apply it” or generally linking, and therefore fail to integrate the abstract idea into a practical application at Step 2A, Prong Two.
On Pages 12-13 of the Response, Applicant argues “The claimed method specifies not only what data is processed, but how the processing is performed; namely, through coordinated API calls that iteratively update the system database with updated emission scores. The cooperation between the frontend, weather API, and backend APIs, each performing distinct processing functions and data transformations, demonstrates an inventive integration of specialized components rather than routine computer usage. The ordered combination thus provides ‘significantly more’ than an instruction to apply the concept of emissions estimation using a generic database. Applicant therefore submits that amended claim 1 satisfies the eligibility requirements under Step 2B. … For this reason as well, Applicant submits that amended claim 1 is patent eligible. Claims 2-14 and 16-18 depend directly or indirectly from claim 1. At least by virtue of its dependency, Applicant submits that each of claims 2-14 and 16-28 are patent eligible. Applicant has amended claims 19 and 20 analogously to claim 1, and accordingly submits they are patent eligible for reasons analogous to those presented for claim 1 above.”
Examiner notes, as discussed further in the detailed rejection below and similar to the discussion above regarding Step 2A Prong Two, the generality of the disclosure of the additional elements (such as the API calls, the front end, the weather API, and backend APIs) supports the analysis that they amount to “apply it” and generally linking, rather than “specialized components”. In order for these elements to be deemed anything more they would require significantly more detail within the specification, or else would merit a 112(a) rejection at the current level of generality. Therefore, at Step 2B these elements are still determined to be “apply it” or generally linking the abstract idea (such as “iteratively update[ing] the [data] with updated emission scores” and “performing distinct processing functions and data transformations” insofar as they are claimed) and fail to amount to “significantly more” when analyzed both individually and as a whole/ordered combination.
On Page 13 of the Response, Applicant argues “Further, Applicant notes that a recent decision from the Appeals Review Panel of the Patent Trial and Appeal Board also supports eligibility. Namely, in Ex parte Desjardins, Appeal no. 2024-000567, Application no. 16/319,040 (Sept. 26, 2025), USPTO Director Squires comments at p. 10, ‘This case demonstrates that §§ 102, 103 and 112 are the traditional and appropriate tools to limit patent protection to its proper score. These statutory provisions should be the focus of examination.’ In the case at hand, there is no dispute the application complies with §§ 102, 103 and 112. Applicant accordingly submits that the Office's most recent guidance on eligibility, Ex parte Desjardins, strongly support eligibility, as does the more established guidance under the M.P.E.P. Applicant accordingly respectfully requests withdrawal of all eligibility rejections.”
Examiner notes, while Director Squires’ comments are noted and place specific emphasis on analysis of the claims over 102, 103, and 112, however the comments do not negate the existence of 101 and its role in determining the eligibility of claims. The detailed rejection below as well as all previous Office Actions abide by the current applicable laws as codified in 35 U.S.C. 101, 102, 103, and 112, and follow the proper procedures as laid out within the MPEP to properly analyze the claims according the law. As currently legislated, indication that the claims are novel and non-obvious over the prior art has no bearing on the claims eligibility over 101 “[b]ecause they are separate and distinct requirements from eligibility, patentability of the claimed invention under 35 U.S.C. 102 and 103 with respect to the prior art is neither required for, nor a guarantee of, patent eligibility under 35 U.S.C. 101.” See MPEP 2106.05.
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 1-14 and 16-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Step 1
Claims 1-14 and 16-18 are directed to a method (i.e., a process); claim 19 are directed to a system (i.e., a machine); claim 20 are directed to a non-transitory computer readable medium (i.e., a machine). Therefore, claims 1-14 and 16-20 all fall within the one of the four statutory categories of invention.
Step 2A, Prong One
Independent claims 1 and 20 substantially recite (a) obtaining farm data comprising at least one of:
(i) revenue generated by a farm;
(ii) crop information for one or more crops grown on the farm; or
(iii) land use/farm practice data for land used on the farm to grow the one or more crops;
(b) determining an emissions estimate in response to the farm data;
(c) causing the emissions estimate that is determined to be displayed to a user;
(d) receiving, from the user, different values for the farm data;
(e) in response to each of the different values of the farm data, respectively determining different iterations of the emissions estimate;
(f) transmitting, for each of the different iterations, the corresponding farm data including:
(i) storing the farm data;
(ii) retrieving location-specific climate data; and
(iii) generating, using data from the system database and the retrieved climate data, an updated emissions estimate;
(g) updating the data with the updated emissions estimate for each of the different iterations and returning the updated emissions estimate; and
(h) displaying each of the different iterations of the emissions estimate to the user, wherein performing the method comprises accessing i) meta information about farmers, ii) finance information about the farmers, iii) crop information in the form of crop activity data, iv) information on land use/farm practices, v) emission scores, and vi) mapping and emission factors, and
wherein the revenue is stored in the finance information, the crop information is stored in the crop information, the land use/farm practice data is stored in the information on land use/farm practices, and the emissions estimate and the different iterations of the emissions estimate are stored in the emission scores.
Independent claim 19 substantially recites (i) obtain farm data comprising at least one of:
(A) revenue generated by a farm;
(B) crop information for one or more crops grown on the farm; or
(C) land use/farm practice data for land used on the farm to grow the one or more crops;
(ii) determine an emissions estimate in response to the farm data;
(iii) cause the emissions estimate that is determined to be displayed to a user;
(iv) receive, from the user, different values for the farm data;
(v) in response to each of the different values of the farm data, respectively determine different iterations of the emissions estimate;
(vi) receive, for each of the different iterations, the corresponding farm data including:
(D) storing the farm data;
(E) retrieving location-specific climate data; and
(F) generating, using data from the system database and the retrieved climate data, an updated emissions estimate;
(vii) updating the data with the updated emissions estimate for each of the different iterations and return the updated emissions estimate for each of the different iterations of the emissions estimate to be displayed to the user,
wherein performing the method comprises accessing i) meta information about farmers, ii) finance information about the farmers, iii) crop information in the form of crop activity data, iv) information on land use/farm practices, v) emission scores, and vi) mapping and emission factors, and
wherein the revenue is stored in the finance information, the crop information is stored in the crop information, the land use/farm practice data is stored in the information on land use/farm practices, and the emissions estimate and the different iterations of the emissions estimate are stored in the emission scores.
The limitations stated above are processes/functions that under broadest reasonable interpretation covers “certain methods of organizing human activity” (commercial or legal interactions) of agricultural greenhouse gas estimation. Therefore, the claim recites an abstract idea.
Step 2A, Prong Two
The judicial exception is not integrated into a practical application. Claims 1, 19, and 20 as a whole amount to: (i) merely invoking generic components as a tool to perform the abstract idea or “apply it” (or an equivalent), and (ii) generally links the use of a judicial exception to a particular technological environment or field of use. The claim recites the additional elements of: (i) a display (claim 19), (ii) one or more servers (claim 19), (iii) one or more databases (claim 19), (iv) a system database/a system database comprising respective entities for storing (claims 1, 19, 20), (v) an entity for finance information (claims 1, 19, 20), (vi) an entity for crop information (claims 1, 19, 20), (vii) an entity for information on land use/farm practices (claims 1, 19, 20), (viii) an entity for emission scores (claims 1, 19, 20), (ix) a backend computing environment (claims 1, 20), (x) a frontend (claims 1, 20), (xi) a plurality of application-programming-interface (API) calls (claims 1, 19, 20), (xii) a data API call to a data API (claims 1, 19, 20), (xiii) an insights API call to an insights API (claims 1, 19, 20), (xiv) a weather API (claims 1, 19, 20), and (xv) an estimation API call to an emissions-estimation API (claims 1, 19, 20).
The additional elements of (i) a display, (ii) one or more servers, (iii) one or more databases, (iv) a system database comprising respective entities for storing (claims 1, 19, 20), (v) an entity for finance information, (vi) an entity for crop information, (vii) an entity for information on land use/farm practices, (viii) an entity for emission scores, (ix) a backend computing environment (claims 1, 20), and (x) a frontend are recited at a high level of generality (see [0046] of the Applicants Specification discussing the display, one or more servers [0054] discussing the one or more databases, the system/the system database comprising respective entities for storing, and a backend computing environment, [0078] discussing the entity for finance information, the entity for crop information, the an entity for information on land use/farm practices, the entity for emission scores, [0047] discussing the frontend) such that, when viewed as whole/ordered combination, it amounts to no more than mere instruction to apply the judicial exception using generic computer components or “apply it” (See MPEP 2106.05(f)).
The additional element of (xi) a plurality of application-programming-interface (API) calls, (xii) a data API call to a data API, (xiii) an insights API call to an insights API, (xiv) a weather API, and (xv) an estimation API call to an emissions-estimation API are recited at a high level of generality (See [0054] of the Applicant' s PG Publication discussing the plurality of application-programming-interface (API) calls, data API call to a data API, insights API call to an insights API, weather API, estimation API call to an emissions-estimation API) such that when viewed as whole/ordered combination, do no more than generally link the use of the judicial exception to a particular technological environment or field of use (i.e., APIs) (See MPEP 2106.05(h)).
Accordingly, these additional elements, when viewed as a whole/ordered combination [See Figures 1, 2, 3, and 7A-B showing all the additional elements (i) a display, (ii) one or more servers, (iii) one or more databases, (iv) a system database comprising respective entities for storing, (v) an entity for finance information, (vi) an entity for crop information, (vii) an entity for information on land use/farm practices, (viii) an entity for emission scores, (ix) a backend computing environment, (x) a frontend, (xi) a plurality of application-programming-interface (API) calls, (xii) a data API call to a data API, (xiii) an insights API call to an insights API, (xiv) a weather API, and (xv) an estimation API call to an emissions-estimation API in combination], do not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Thus, the claim is directed to an abstract idea.
Step 2B
As discussed above with respect to Step 2A Prong Two, the additional elements amount to no more than: (i) “apply it” (or an equivalent), and (ii) generally link the use of a judicial exception to a particular technological environment or field of use, and are not a practical application of the abstract idea. The same analysis applies here in Step 2B, i.e., (i) merely invoking the generic components as a tool to perform the abstract idea or “apply it” (See MPEP 2106.05(f)); and (ii) generally linking the use of a judicial exception to a particular technological environment or field of use (See MPEP 2106.05(h)), does not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B. Thus, even when viewed as a whole/ordered combination, nothing in the claims adds significantly more (i.e., an inventive concept) to the abstract idea. Thus, the claims 1, 19, and 20 are ineligible.
Dependent Claims 2, 3, 5-9, 13, 14, 16, and 18 merely narrow the previously recited abstract idea limitations. For reasons described above with respect to claim 1 these judicial exceptions are not meaningfully integrated into a practical application or significantly more than the abstract idea. Thus, claims 2-9, 13-16, and 18 are also ineligible.
Step 2A, Prong Two
Dependent Claim 4 further narrows the previously recited abstract idea limitations. Claim 4 also recites the additional element of a financial information database, which is recited at a high-level of generality (See [0054] of the Applicants specification disclosing the financial information database) such that, when viewed as whole/ordered combination, it amounts to no more than mere instruction to apply the judicial exception using generic computer components or “apply it” (See MPEP 2106.05(f)).
Accordingly, the additional elements, when viewed individually and as a whole/ordered combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Thus, the claims are directed to an abstract idea.
Step 2B
As discussed above with respect to Step 2A Prong Two, the additional elements amount to no more than: (i) “apply it” (or an equivalent), and are not a practical application of the abstract idea. The same analysis applies here in Step 2B, i.e., (i) merely invoking the generic components as a tool to perform the abstract idea or “apply it” (See MPEP 2106.05(f)), does not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B.
Therefore, the additional element of the financial information database does not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B. Thus, even when viewed as a whole/ordered combination, nothing in the claim adds significantly more (i.e., an inventive concept) to the abstract idea. Thus, claim 4 is ineligible.
Step 2A, Prong Two
Dependent Claims 10 and 11 further narrow the previously recited abstract idea limitations. Claims 10 and 11 also recites the additional elements of a wide area network and an application programming interface, which is recited at a high-level of generality (See [0045] of the Applicants specification disclosing the wide area network, [0054] disclosing the application programming interface) such that when viewed as whole/ordered combination, the additional elements do no more than generally link the use of the judicial exception to a particular technological environment or field of use (i.e., network communication) (See MPEP 2106.05(h)).
Accordingly, the additional elements, when viewed individually and as a whole/ordered combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Thus, the claims are directed to an abstract idea.
Step 2B
As discussed above with respect to Step 2A Prong Two, the additional element amounts to no more than: generally linking the use of a judicial exception to a particular technological environment or field of use, and is not a practical application of the abstract idea. The same analysis applies here in Step 2B, i.e., (i) generally linking the use of a judicial exception to a particular technological environment or field of use (See MPEP 2106.05(h)), does not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B.
Therefore, the additional element of a wide area network and an application programming interface does not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B. Thus, even when viewed as a whole/ordered combination, nothing in the claim adds significantly more (i.e., an inventive concept) to the abstract idea. Thus, claims 10 and 11 are ineligible.
Dependent Claim 12 merely narrow the previously recited abstract idea limitations. For reasons described above with respect to claim 11 these judicial exceptions are not meaningfully integrated into a practical application or significantly more than the abstract idea. Thus, claim 12 is also ineligible.
Step 2A, Prong Two
Dependent Claim 17 further narrow the previously recited abstract idea limitations. Claim 17 also recites the additional element of Representative Concentration Pathway scenarios, which is recited at a high-level of generality (See [0048] of the Applicants specification disclosing the Representative Concentration Pathway scenarios) such that when viewed as whole/ordered combination, the additional elements do no more than generally link the use of the judicial exception to a particular technological environment or field of use (i.e., greenhouse gas emission projections) (See MPEP 2106.05(h)).
Accordingly, the additional elements, when viewed individually and as a whole/ordered combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Thus, the claims are directed to an abstract idea.
Step 2B
As discussed above with respect to Step 2A Prong Two, the additional element amounts to no more than: generally linking the use of a judicial exception to a particular technological environment or field of use, and is not a practical application of the abstract idea. The same analysis applies here in Step 2B, i.e., (i) generally linking the use of a judicial exception to a particular technological environment or field of use (See MPEP 2106.05(h)), does not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B.
Therefore, the additional element of a wide area network and an application programming interface does not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B. Thus, even when viewed as a whole/ordered combination, nothing in the claim adds significantly more (i.e., an inventive concept) to the abstract idea. Thus, claim 17 are ineligible.
Novel and Non-Obvious Over the Prior Art
Claims 1-14 and 16-20 are novel and non-obvious over the prior art; however, these claims are subject to the above rejections.
The closest prior art is U.S. Patent Application No. 2023/0106473 to Wambugu et al (hereafter Wambugu). Wambugu discloses estimating greenhouse gas emissions for provided farm data and using APIs for communicating data.
The next closest prior art is U.S. Patent Application No. 2013/0124146 to Hsu et al (hereafter Hsu). Hsu discloses the estimating and display of greenhouse gas emissions.
The next closest prior art is U.S. Patent Application No. 2007/0233502 to Richards et al (hereafter Richards). Richards discloses user adjustable data values for determining emission estimates.
The next closest prior art is U.S. Patent Application No. 2018/0152391 to Huh et al (hereafter Huh). Huh discloses users ability to change data regarding their farm in the same context as carbon emissions measurements.
The next closes prior art is U.S. Patent Application No. 2011/0320368 to Corrigan et al (hereafter Corrigan). Corrigan discloses use of databases including financial data and creating emissions estimates in relation to the stored financial data.
The next closes prior art is U.S. Patent Application No. 2021/0148891 to Beal et al (hereafter Beal). Beal discloses database with entities for storing farmer metadata and land practices
While the closest prior art above teaches the various aspects of the claimed invention individually, the combination of these references are not obvious in such a way that they would have been obvious to one of ordinary skill in the art at the time of invention. Specifically, Wambugu in view of Hsu and further in view of Richards and even further in view of Huh and even further in view of Corrigan and even further in view of Beal does not explicitly disclose the use of the specific API calls to specific APIs in order to retrieve and store farm data, climate data, and updating estimations. Therefore, the claims are rendered novel and non-obvious over the prior art.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to DAVID G GODBOLD whose telephone number is (571)272-5036. The examiner can normally be reached M-F 8-5.
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/DAVID G. GODBOLD/Examiner, Art Unit 3628
/SHANNON S CAMPBELL/Supervisory Patent Examiner, Art Unit 3628