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, 5, 7-9, 11-12, 16, and 18-20 are amended while claim 10 is cancelled. Claims 1-9 and 11-20 filed December 30, 2025 are pending and are hereby examined.
Double Patenting
Claims 1-9 and 11-20 of this application is patentably indistinct from claims 1-20 of Application No. 18/476716 and claims 1-20 of 18/476748. Pursuant to 37 CFR 1.78(f), when two or more applications filed by the same applicant or assignee contain patentably indistinct claims, elimination of such claims from all but one application may be required in the absence of good and sufficient reason for their retention during pendency in more than one application. Applicant is required to either cancel the patentably indistinct claims from all but one application or maintain a clear line of demarcation between the applications. See MPEP § 822.
Claim Rejections - 35 USC § 101
4. 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.
5. Claims 1-9 and 11-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
6. Step 1 Statutory Category: Claims 1-9 and 11 are directed to a system, claims 12-19 are directed to a method, and claim 20 is directed to a non-transitory computer readable medium, all of which are statutory. Claims 1-9 and 11-20 are statutory classes of invention.
7. Step 2A – Prong 1: Judicial Exception Recited: Nevertheless, independent claims 1, 12, and 20 recite an abstract idea of real-time payroll data validation.
The independent claims 1, 12, and 20 recite the following limitations which fall under commercial or legal interactions:
…;
…;
receive a first user input comprising at least one data value associated with an employee of a company, wherein the at least one data value is used to complete payroll transactions of the company in a first geographic location;
while receiving the first user input, validate in real-time the at least one data value of the first user input by:
determining a data type of the at least one data value;
retrieving a plurality of localization rules associated with the data type and the first geographic location;
and validating whether the at least one data value satisfies criteria provided by the plurality of localization rules;
in response to determining that the at least one data value does not satisfy the criteria, generate…and overlay an indication that the first user input requires review to complete the payroll transactions, wherein… displays a view of a geographical region and the indication is overlayed on a portion of the geographical region associated with the first geographic location;
receive… a selection of the indication;
generate… a view of the at least one data value visually marked for correction.
8. According to the MPEP, "Commercial interactions" or "legal interactions" include agreements in the form of contracts, legal obligations, advertising, marketing or sales activities or behaviors, and business relations. Clearly, real-time payroll data validation falls under sales activities, therefore commercial or legal interactions. If the claim limitations, under the broadest reasonable interpretation, covers performance of the limitations as a commercial or legal interaction, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
9. Step 2A – Prong 2: Practical Application: This judicial exception is not integrated into a practical application because the claim as a whole merely recites real-time payroll data validation with generally recited computer elements such as a memory, hardware processor, and graphical user interface, which in these steps are recited at a high-level of generality such that it amounts to more than mere instructions to apply the exception using a generic computer component, and are merely invoked as tools for real-time payroll data validation. Accordingly, these elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Simply implementing the abstract idea on a generic computing environment is not a practical application of the abstract idea, and does not take the claim out of the Commercial or Legal Interactions subgrouping of Certain Methods of Organizing Human Activity grouping. The claims are directed to an abstract idea.
10. Step 2B – Inventive Concept: The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when considered individually and as an ordered combination, they do not add significantly more (also known as “inventive concept”) to the exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements of a memory, hardware processor, and graphical user interface to perform these steps amounts to no more than mere instructions to apply the exception using a generic computer component. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Accordingly, these additional elements, do not change the outcome of the analysis, when considered individually and as an ordered combination as there is no inventive concept sufficient to transform the claimed subject matter into a patent-eligible application. The claims are not patent eligible.
11. Regarding dependent claims 2, 5, 7-9, 13, 16, and 18-19, although these claims recite a generally recited hardware processor, these claims merely narrow the abstract idea of real-time payroll data validation, and these claims neither integrate into a practical application nor contain additional elements which amount to significantly more than the abstract idea.
12. Regarding dependent claims 3, 11, and 14, these claims merely narrow the abstract idea of real-time payroll data validation, and these claims neither integrate into a practical application nor contain additional elements which amount to significantly more than the abstract idea.
13. Regarding dependent claims 4, 6, 15, and 17, although these claims recite a generally recited hardware processor and graphical user interface, these claims merely narrow the abstract idea of real-time payroll data validation, and these claims neither integrate into a practical application nor contain additional elements which amount to significantly more than the abstract idea.
14. Therefore, the limitations of the claims, when viewed individually and in ordered combination, are directed to ineligible subject matter.
Claim Rejections - 35 USC § 103
15. 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 (i.e., changing from AIA to pre-AIA ) 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.
16. 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.
17. 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.
18. Claims 1-9 and 11-20 are rejected under 35 U.S.C. 103 as being unpatentable over Suryanarayana et al (US 2023/0368214) in view of Mauricio (US 2020/0118219).
19. Re Claims 1, 12, 20: Suryanarayana discloses comprising:
at least one memory (see [0069] memory devices 116);
at least one hardware processor coupled with the at least one memory and configured, individually or in combination, to (see [0069] one or more processors 134):
receive a first user input comprising at least one data value associated with an employee of a company, wherein the at least one data value is used to complete payroll transactions of the company in a first geographic location (see [0077] receiving input);
while receiving the first user input, validate the at least one data value of the first user input in real-time by (see [0126] validating data):
determining a data type of the at least one data value (see [0126] determined based on various attributes and data associated with entities);
retrieving a plurality of localization rules associated with the data type and the first geographic location (see [0031, 0034, 0041] rules);
and validating whether the at least one data value satisfies criteria provided by the plurality of localization rules (see [0045, 0056-0058] validating dependent on rule);
receive, via the graphical user interface, a selection of the indication (see [0170]
selectable list of jurisdictions, [0173] selectable list of compliance rules and rules that can be selected for editing, [0176] selectable entry); and
generate, on the graphical user interface, a view of the at least one data value with specific data values visually marked for not satisfying the criteria (see [0178] marking compliance evaluation infraction).
However, Suryanarayana fails to explicitly disclose the following. Meanwhile, Mauricio teaches:
in response to determining that the at least one data value does not satisfy the criteria, generate, on a graphical user interface, an indication that the first user input requires review to complete the payroll transactions, wherein the graphical user interface displays a view of a geographical region and the indication is generated in a portion of the geographical region associated with the first geographic location (see [0031-0033] employer dashboard).
From the teaching of Mauricio, it would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to modify Suryanarayana’s compliance evaluation system with Mauricio’s teaching of generation of a graphical user interface in order for “… geographic location monitoring for tax compliance…. (see Mauricio [0002]).”
20. Re Claims 2, 13: Suryanarayana discloses wherein the at least one hardware processor is further configured to:
receive a second user input comprising at least one other data value associated with a different employee of the company, wherein the at least one other data value is used to complete payroll transactions of the company in a second geographic location (see [0077] receiving input);
and validate the at least one other data value using a different plurality of localization rules associated with the data type of the at least one other data value and the second geographic location (see [0126] validating data).
21. Re Claims 3, 14: Suryanarayana discloses wherein the at least one data value is a national identification number of the employee, and wherein determining that the at least one data value does not satisfy the criteria comprises determining that the national identification number has an invalid format, and wherein determining that the at least one other data value satisfies criteria of the different plurality of localization rules comprises determining that the national identification number is not required to complete the payroll transactions (see [0050] false outcome).
22. Re Claims 4, 15: Suryanarayana discloses wherein the at least one hardware processor is further configured to:
determine an amount of the criteria that the at least one data value satisfies, wherein the indication generated on the graphical user interface is a visual marker that depicts the amount of the criteria that the at least one data value satisfies (see [0178] mark compliance evaluation infraction).
23. Re Claims 5, 16: Suryanarayana discloses wherein the at least one data value comprises a first data value and a second data value, wherein the at least one hardware processor is further configured to determine that the at least one data value does not satisfy the criteria in response to determining that the first data value contradicts and the second data value (see [0050] false outcome).
24. Re Claims 6, 17: Suryanarayana discloses wherein the at least one hardware processor is further configured to generate, on the graphical user interface, at least one option to correct the at least one data value (see [0062, 0114] corrective actions).
25. Re Claims 7, 18: Suryanarayana discloses wherein the at least one hardware processor is further configured to:
receive a second user input comprising at least one corrected data value to replace the at least one data value (see [0077] receiving input);
validate whether the at least one corrected data value satisfies the criteria provided by the plurality of localization rules (see [0126] validating data).
26. Re Claims 8, 19: Suryanarayana discloses wherein the at least one hardware processor is configured to:
disable a payroll transaction for the employee in response to determining that the at least one data value does not satisfy the criteria (see [0167] disabling certain organizational resources).
27. Re Claim 9: Suryanarayana discloses wherein the at least one hardware processor is configured to:
enable a payroll transaction for the employee in response to determining that the at least one data value satisfies the criteria (see [0112] enables user to perform various operations involving organizational data).
28. Re Claim 11: Suryanarayana discloses wherein the first geographic location is a country, the geographic region is one or more continents, and the view of the geographical region comprises a map interface (see [0055] country, state).
Examiner Notes
29. The Examiner suggests clarifying some of the terms like user input and data value and localization rules (what is difference between user input and data value? What is difference between localization rule and criteria?). The Examiner suggests incorporating claims 3 (dependent on 2) and 7 (dependent on 6) together into the independent claims.
30. Finally, the Examiner suggests incorporating more hardware from the Specification and any unique arrangements of hardware, unique hardware, or unique ways the hardware is communicating. The aforementioned claim suggestions, in combination together, is suggested to help advance prosecution forward, although further search, examination, and consideration is required.
Response to Arguments
31. Applicant's arguments filed 12/30/25 have been fully considered and are not found to be convincing, therefore the 35 U.S.C. 103 rejection, double patenting rejection, and 35 U.S.C. 101 rejection are hereby maintained. With regards to the double patenting rejection, the argument is not found to be persuasive as the claimed subject matter in the present invention is similar to the claims of 18/476,716 and 18/476,748.
a) Argument #1: “while receiving the first user input, validate in real-time the at least one data value of the first user input” is not disclosed in Suryanarayana or Mauricio.
32. The Examiner respectfully disagrees. In [0084] of Suryanarayana, it discloses employee data being collected in real-time and uploaded to the computing system, as well as the compliance data in [0085]. Then in [0126], it discloses validating the organizational data from third-party applications, which are usually done in real-time.
b) Argument #2: “generate and overlay on a graphical user interface an indication that the first user input requires review to complete the payroll transactions, wherein the graphical user interface displays a view of a graphical region, and the indication is overlayed on a portion of the graphical region associated with the first geographical location; receive, via the graphical user interface, a selection of the indication; and generate, on the graphical user interface, a view of the at least one data value visually marked for correction” is not disclosed in Suryanarayana or Mauricio.
33. The Examiner respectfully disagrees. In Figures 1-5 of Mauricio, it teaches geographic regions and locations. Regarding correction, in [0178] of Suryanarayana, it discloses marking compliance evaluation infraction.
c) Argument #3: Claims do not recite a judicial exception because it is not directed to “certain methods of organizing human activity” and therefore not an abstract idea
34. With regards to the 35 U.S.C. 101 rejection, the Examiner respectfully disagrees. First, the applicant argues that the claims are not directed to an abstract idea. The Examiner respectfully disagrees as the claims are related to real-time payroll data validation, which would fall under certain methods of organizing human activity of commercial or legal interactions. According to MPEP 2106.04(a)(2), "commercial interactions" or "legal interactions" include agreements in the form of contracts, legal obligations, advertising, marketing or sales activities or behaviors, and business relations. Real-time payroll data validation is a form of marketing or sales activity or behavior, and is therefore an abstract idea.
d) Argument #4: Applicant argues that the abstract idea is integrated into a practical application under Step 2A, Prong 2 (improvement in technology)
35. The Examiner respectfully disagrees. In regards to improving the functioning of the computer/technology/technical field, the claims recite a memory, hardware processor, and graphical user interface, and they are recited at a high level of generality, and therefore are merely using computer processing components for monitoring devices. After further review of the Specification, there is no disclosure of technical enhancements to any of the computing components, as in multiple instances of the Specification it discloses generally recited elements. Interpreting the claims in view of the Specification, the claims recite the judicial exception are mere instructions to apply the exception of real-time payroll data validation (see MPEP 2106.05(f)). The elements recited above do not recite and are not directed to any elements or functions that improve underlying technology.
36. According to MPEP 2106.05(a), it states: “It is important to note that in order for a method claim to improve computer functionality, the broadest reasonable interpretation of the claim must be limited to computer implementation. That is, a claim whose entire scope can be performed mentally, cannot be said to improve computer technology. Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 120 USPQ2d 1473 (Fed. Cir. 2016) (a method of translating a logic circuit into a hardware component description of a logic circuit was found to be ineligible because the method did not employ a computer and a skilled artisan could perform all the steps mentally). Similarly, a claimed process covering embodiments that can be performed on a computer, as well as embodiments that can be practiced verbally or with a telephone, cannot improve computer technology. See RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1328, 122 USPQ2d 1377, 1381 (Fed. Cir. 2017) (process for encoding/decoding facial data using image codes assigned to particular facial features held ineligible because the process did not require a computer).”
37. Furthermore, in determining whether a claim integrates a judicial exception into a practical application, a determination is made of whether the claimed invention pertains to an improvement in the functioning of the computer itself or any other technology or technical field (i.e., a technological solution to a technological problem). Here, the claims recite generic computer components, a memory, hardware processor, and graphical user interface, i.e., that are recited at a high level of generality and are recited as performing generic computer functions customarily used in computer applications. The pending claims do not describe a technical solution to a technical problem. The pending claims are directed to solving the problem of real-time payroll data validation. The claims of the instant application describe an improvement to a business process i.e., real-time payroll data validation, not improvement in the functioning of the computer itself or an improvement to any other technology or technological field. Therefore, the claims do not integrate into a practical application either by improvement to a computer/technology/technical field.
38. The claims are not directed to any improvement in computer technology. The claims are directed to an abstract idea of real-time payroll data validation. The applicant must take into consideration that in order to view the claims as supplying an inventive concept the technological improvement must be present within the claims themselves (Accenture Global Servs., GmbH v. Guidewire Software, inc., 108 USPQ2d 1173 (Fed. Cir. 2013)), (Synopsys, inc. v. Mentor Graphics Corp... 120 USPQ2d 1473 (Fed. Cir. 2016). Additionally, the Specification does not provide any evidence that how the claims provide an improvement to functioning of computing systems or technology. The applicant failed to provide persuasive arguments supported by any necessary evidence to demonstrate that one of ordinary skill in the art would understand that the disclosed invention improves technology.
e) Argument #5: Applicant argues that the claim elements are significantly more than the abstract idea under Step 2B
39. Having determined under step one of the Mayo/Alice framework that claims 1, 12, and 20 are directed to an abstract idea, we next consider under Step 2B of the Guidance, the second step of the Mayo/Alice framework, whether the claims include additional elements or a combination of elements that provides an “inventive concept,” i.e., whether an additional element or combination of elements adds specific limitations beyond the judicial exception that are not “well-understood, routine, conventional activity” in the field (which is indicative that an inventive concept is present) or simply appends well-understood, routine, conventional activities previously known to the industry to the judicial exception. 2019 Revised Guidance, 84 Fed. Reg. at 56.
40. Under step two of the Mayo/Alice framework, the elements of each claim are considered both individually and “as an ordered combination” to determine whether the additional elements, i.e., the elements other than the abstract idea itself, “transform the nature of the claim” into a patent-eligible application. Alice Corp., 573 U.S. at 217 (citation omitted); see Mayo, 566 U.S. at 72-73 (requiring that “a process that focuses upon the use of a natural law also contain other elements or a combination of elements, sometimes referred to as an ‘inventive concept,’ sufficient to ensure that the patent in practice amounts to significantly more than a patent upon the natural law itself’ (emphasis added) (citation omitted)).
41. Here the only additional elements recited in claims 1, 12, and 20 beyond the abstract idea are: a memory, hardware processor, and graphical user interface, i.e., generic computer components. See Alice, 573 U.S. at 223 (“[T]he mere recitation of a generic computer cannot transform a patent-ineligible abstract idea into a patent-eligible invention.”). Applicant has not identified any additional elements recited in the claim that, individually or in combination, provides significantly more than the abstract idea.
42. Accordingly, there are no meaningful limitations in the claims that transform the judicial exception into a patent eligible application such that the claims amount to significantly more than the judicial exception itself. The dependent claims do not resolve the deficiency of the independent claims and accordingly stand rejected under 35 U.S.C. 101 based on the same rationale.
Conclusion
43. The prior art made of record and not relied upon is considered pertinent to applicant's disclosure: Ashraf et al (Big Data for Real-Time Processing on Streaming Data: State-of-the-art and Future Challenges, NPL) is found to be the most pertinent NPL prior art.
44. 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).
45. 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.
46. Any inquiry concerning this communication or earlier communications from the examiner should be directed to FAWAAD HAIDER whose telephone number is (571)272-7178. The examiner can normally be reached Mon-Fri 8 AM to 5 PM.
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48. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Florian Zeender can be reached on 571-272-6790. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/FAWAAD HAIDER/Primary Examiner, Art Unit 3627