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
Claims 1-14 and 16-20 were previously pending and subject to a non-final rejection dated July 16, 2026. In Response, submitted July 14, 2026, claims 1, 11, 19, and 20 were amended. Therefore, claims 1-14 and 16-20 are currently pending and subject to the following final rejection.
Response to Arguments
Applicant’s remarks on Pages 12-15 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 Pages 13-14 of the Response, Applicant argues “Assuming arguendo that claim 1 recites a judicial exception, Applicant respectfully submits that amended claim 1 integrates that exception into a practical application such that claim 1, as amended, is patent eligible. More particularly, amended claim 1 recites a particular computer-implemented workflow … The Specification expressly describes this implementation, explaining that ‘the system 300 may automatically populate some of the data required for carbon estimation by leveraging satellite imagery (e.g., crop type; tillage practices, farm area).’ The Specification also discloses that the farm location may be expressed ‘in terms of longitude and latitude.’ The newly added limitations do not merely append satellite imagery to an otherwise abstract emissions calculation. They change how the computerized platform obtains and incorporates the farm data used in that calculation. In amended claim 1, specified farm characteristics are determined from remotely sensed imagery corresponding to the farm's geospatial location and automatically populated in the system database before the emissions estimate is generated. The claim therefore recites a particular computer-implemented process for deriving agricultural characteristics from location-corresponding satellite imagery and supplying those characteristics to the emissions-estimation process. Contrary to the Office Action's characterization, the claim does not merely recite the result of obtaining or processing farm data. Rather, it specifies the sequence by which the farm location is received, location- corresponding satellite imagery is obtained, specified farm characteristics are determined from that imagery, those characteristics are automatically populated into the system database, and the populated data is thereafter used in determining the emissions estimate. Viewed as a whole and as an ordered combination, amended claim 1 recites a particular computer- implemented technique for deriving specified agricultural characteristics from location-corresponding satellite imagery and incorporating those characteristics into the system database before emissions estimation. This workflow changes how the computerized platform obtains and prepares the farm data used in the estimation.”
Examiner notes, limitations referring “leveraging satellite imagery (e.g., crop type; tillage practices, farm area)” and “the farm location [being] expressed ‘in terms of longitude and latitude’” are not technical aspects but rather descriptions of the abstract data that is being used in computation in order to make determinations. That is, as currently claimed, these aspects are part of the abstract idea and not additional elements, and therefore unhelpful in bringing the claims to eligibility.
Examiner further notes, as discussed further in the detailed rejection below, chang[ing] how the computerized platform obtains and incorporates the farm data used in … calculation[s]” does not demonstrate an improvement or change to the computerized platform itself, but rather merely to the abstract ideas (i.e., obtaining, incorporating, and calculating data) the computerized platform is used to perform. That is, the claims site a specific abstract idea such as “deriving agricultural characteristics from location-corresponding satellite imagery and supplying those characteristics to the emissions-estimation process” and “specif[ying] the sequence by which the farm location is received, location-corresponding satellite imagery is obtained, specified farm characteristics are determined from that imagery, those characteristics [being] automatically populated …, and the populated data … thereafter [being] used in determining the emissions estimate” performed by the “computer-implemented process” but the components that make up the technical aspects (such as the system database, the frontend, and the backend computing environment) of the implementation are recited at levels that amount to merely apply it and generally link the abstract idea to fields of use. Analysis of these elements, and the others also recited, individually and as a whole/ordered combination, fail to integrate the abstract idea into a practical application.
On Page 14 of the Response, Applicant argues “the additional elements operate in a claimed combination that obtains, based on a particular farm's geospatial coordinates, satellite imagery corresponding to the farm, determines specified farm characteristics from that imagery, automatically populates the system database based on those determined characteristics, and then uses the populated data to generate an emissions estimate. The eligibility analysis must evaluate that claimed combination, rather than characterizing the limitations at a higher level of generality as merely obtaining and processing data. Applicant therefore submits that amended claim 1 integrates any alleged judicial exception into a practical application, such that amended claim 1 is patent eligible under Step 2A, Prong Two.”
Examiner first notes, well-understood, routine, and conventional analysis does not apply to Step 2A, Prong Two, only at Step 2B may this test affect the analysis. However, this is moot, as well-understood, routine, and conventional is only one of the tests provided to Examiners for the analysis at Step 2B and is not relied on this or the previous rejection of the claims over 101.
Examiner additionally notes, as discussed further in the detailed rejection below, the limitations insofar as they are claimed of “obtain[ing], based on a particular farm's geospatial coordinates, satellite imagery corresponding to the farm, determin[ing] specified farm characteristics from that imagery, automatically populat[ing] the … determined characteristics, and then us[ing] the populated data to generate an emissions estimate” is part of the recited abstract idea, and therefore unhelpful in bringing the claims to elibibility. The system database is disclosed at face value as a database in the specification, and the processes involved of a satellite gathering information for a specified location are beyond the scope of the claimed invention, rather the claimed invention discloses receiving a significant amount of data (in this case imagery that was captured by a satellite at some point of time beyond the scope of the claimed invention), then locating specific data within that received data. Therefore the “satellite” of the claimed invention serves only to modify the abstract imagery the system obtains, but does not amount to an additional element of the system itself. This interpretation is supported by the Applicant’s specification, where support only exists for “leveraging satellite imagery” (See specification, Para. 79), but not for any inclusion of the satellite specifically within the scope of the claimed invention. Therefore, the limitation “the satellite imagery being captured by a satellite” is interpreted to merely clarify the type of imagery being used, and not assert that the invention in some way directly causes the satellite to capture imagery, for which no support exists in the Applicant’s specification.
On Pages 14-15 of the Response, Applicant argues “Amended claim 1 recites more than simply estimating emissions; rather, it recites an ordered implementation in which location-corresponding satellite imagery is obtained, specified farm characteristics are determined from the imagery, the system database is automatically populated based on those characteristics, and the populated data is used in determining the emissions estimate. It represents a non-conventional and non-generic arrangement of operations which, even assuming arguendo were individually known, collectively represent an inventive manner of acquiring and processing farm data and consequently estimating emissions. … Accordingly, if not eligible under Step 2A, Applicant submits claim 1 is eligible under Step 2B. … Claims 2-14 and 16-18 depend directly or indirectly from claim 1. At least by virtue of their dependency, Applicant submits that each of claims 2-14 and 16-18 is 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. Applicant accordingly respectfully requests withdrawal of all eligibility rejections
Examiner notes, as discussed above, well-understood, routine, and conventional is only a single test available to examiners at Step 2B, and is not utilized in this analysis or the analysis provided in previous Office Actions. Therefore, these aspects of the argument are moot. Similar to the discussion above, usage of additional elements as generic tools to perform abstract ideas or generally link the recited abstract idea to a field of use do not amount to “significantly more” at Step 2B. In the instant case, “an ordered implementation in which location-corresponding satellite imagery is obtained, specified farm characteristics are determined from the imagery, the system database is automatically populated based on those characteristics, and the populated data is used in determining the emissions estimate” is part of the abstract idea, and is unhelpful in bringing the claims to eligibility.
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 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;
receiving a farm location for the farm, the farm location comprising longitude and latitude;
obtaining satellite imagery corresponding to the farm location, the satellite imagery being captured by a satellite;
determining based on the satellite imagery, at least one farm characteristic selected from: a crop type, a tillage practice, or a farm area;
automatically populating the farm data based on the determined at least one farm characteristic;
determining an emissions estimate in response to using the farm data as populated based on the determined at least one farm characteristic;
causing the emissions estimate that is determined to be displayed to a user;
receiving, from the user, different values for the farm data;
in response to each of the different values of the farm data, respectively determining different iterations of the emissions estimate;
transmitting, for each of the different iterations, the corresponding farm data including:
(i) storing the farm data;
(ii) retrieving, based on the farm location, location-specific climate data; and
(iii) generating, using data and the retrieved climate data, an updated emissions estimate;
updating with the updated emissions estimate for each of the different iterations and returning the updated emissions estimate; and
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 obtaining 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;
receive a farm location for the farm, the farm location comprising longitude and latitude;
obtaining satellite imagery corresponding to the farm location, the satellite imagery being captured by a satellite;
determining, based on the satellite imagery, at least one farm characteristic selected from: a crop type, a tillage practice, or a farm area;
automatically populating the farm data based on the determined at least one farm characteristic;
determining an emissions estimate in response to using the farm data as populated based on the determined at least one farm characteristic;
causing the emissions estimate that is determined to be displayed to a;
receiving, from the user, different values for the farm data;
in response to each of the different values of the farm data, respectively determining different iterations of the emissions estimate;
receiving, for each of the different iterations, the corresponding farm data including:
(D) storing the farm data;
(E) retrieving, based on the farm location, location-specific climate data; and
(F) generating, using data and the retrieved climate data, an updated emissions estimate;
updating 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 comprising respective entities for storing 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, 19, 20), (x) a frontend (claims 1, 19, 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 7 A-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, 3, 5-9, 13, 14, 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 a 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 Representative Concentration Pathway scenarios 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 as reflected in representative claim 1 limitations: “transmitting, for each of the different iterations, the corresponding farm data from the frontend to the backend computing environment via a plurality of application- programming-interface (API) calls including: a data API call to a data API for storing the farm data in the system database; an insights API call to an insights API; and an estimation API call to an emissions-estimation API” and claim 19 limitations: “receive, for each of the different iterations, the corresponding farm data from the display via a plurality of application-programming-interface (API) calls including: … a data API call to a data API for storing the farm data in the system database; … an insights API call to an insights API that retrieves, based on the farm location, location-specific climate data through a weather API; and… an estimation API call to an emissions-estimation API that generates, using data from the system database and the retrieved climate data, an updated emissions estimate;” in combination with the other limitations. Therefore, the claims are rendered novel and non-obvious over the prior art.
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to 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
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